Do I need an export licence in Sweden to ship dual-use sensors to Türkiye?

Yes, possibly, and the first issue is classification. If the sensors fall within Annex I of the EU Dual-Use Regulation, an export authorisation is required for export from Sweden to any non-EU destination. Sweden's competent authority is ISP. For industrial sensors, the review often starts in Annex I Category 6, but the legal answer depends on the exact technical parameters and any related software or technology, not on the commercial product label.

Türkiye does not remove the control issue. You should not assume the shipment is licence-free just because the destination is Türkiye. EU001, the main Union general authorisation for low-risk destinations, does not include Türkiye. Some other EU general authorisations do include Türkiye for narrow scenarios, but they apply only if the exact item, use case and conditions fit that specific authorisation.

Even non-listed sensors can still require authorisation. Under the EU catch-all rules, a non-listed item may still need a licence if it is or may be intended for WMD-related use, certain military end-uses, or other prohibited uses. Sweden also applies national rules requiring authorisation where the exporter has grounds to suspect prohibited Article 4 end-uses, and Sweden has also notified national controls for non-listed cyber-surveillance items.

Before shipping, complete four checks. First, do a written classification review against Annex I and identify any related controlled software, firmware, source code or technical data. Second, verify the buyer, end-user, consignee and any intermediary, and screen them against the EU sanctions map and consolidated financial sanctions resources. Third, obtain a clear end-use statement describing the civilian use, installation site and commitment against unauthorised re-export or military/WMD use. Fourth, align the export paperwork so the technical description, customs code, invoice, packing list and shipping documents all match the classification analysis.

The core document pack usually includes: technical datasheets and product specifications, an internal classification memo, purchase order or contract, commercial invoice, packing list, end-user statement, end-user corporate details, routing and freight details, sanctions screening record, and, where needed, the ISP licence or prior ISP indication. ISP states that, for export licence applications, the end-user statement is generally required in original on the end-user's letterhead and signed by an authorised representative, and exporters must keep detailed export records for at least five years.

The answer: do not ship first and analyse later. If there is any real doubt on classification or end-use, request a preliminary assessment from ISP and, if required, file the licence application before dispatch. That is the safest way to avoid customs delay, sanctions exposure and mis-declaration risk.