Updates to the UK Strategic Export Control List and Corresponding Legislation

The updates reflect both changes to control lists administered by multilateral export control regimes as well as updates to domestic export control measures.

Key Changes to Consolidated List

The Consolidated List specifies items that require export authorisation due to their potential use in military or dual-use applications. The Consolidated List is updated approximately twice a year to reflect changes in international agreements and UK regulations.

As announced today, the Consolidated List will be amended to include the following key changes:

• High-End Digital Processing ICs: an amendment to the technical parameters under PL9013a4, aimed at high-end digital processing integrated circuits (ICs) most suitable for AI training. PL9013a4 currently lists the following as items that require an export licence:

“Integrated circuits with an aggregate bidirectional transfer rate of 600 Gbyte/s or more over all inputs and outputs (excluding volatile memories) must meet one of the following criteria:

1. Digital Processor Units: Executing machine instructions with a total processing performance of 6000 or more.
2. Digital Primitive Computational Units: Excluding those contributing to machine instructions, with a total processing performance of 6000 or more.
3. Analogue Primitive Computational Units: Having a total processing performance of 6000 or more.
4. Combination of Units: Any combination of digital processor units and primitive computational units with a total processing performance of 6000 or more”;

While the text of this amendment has not been published yet, we expect this to focus on most advanced ICs that could be used for military or surveillance purposes. The amendment will likely refine the performance thresholds, such as processing speed, memory capacity, and power efficiency.

• Wassenaar Arrangement: amendments in line with updates to the List of Dual-Use Goods & Technologies and Munitions List as set out on the Wassenaar Arrangement website on 5 December 2024. The updates include changes to the following entries: ML10, 1C002, 1C005, 3A002, 3C005, 5A001, 5E001, 5A002, 6A005, 8A001, 8A002, 9A004, 9B, and 9E003.
• Nuclear Suppliers Group (NSG): amendments in line with changes agreed under the NSG guidelines, including to entries 0B004a, 0B004b, 1A202, 1A225, 1B228, and 6A225.
• Australia Group: amendments in line with changes agreed under the Australia Group website, relating to entry 2B352.
• Technical Notes and definitions: editorial amendments to Technical Notes and definitions, including new definitions for 'spacecraft', 'satellite', 'space probe', and 'space vehicle'.

Impact on Businesses

Businesses will need to assess the impact of these amendments on the items they export out of the UK and consider whether any additional items will now fall under these updated control entries. This is particularly important in the context of the upcoming amendment to control entry PL9013a4 which imposes licensing requirements on certain advanced ICs. More details about the above-mentioned updates to the UK Strategic Export Control List will be published in due course.