Dual-use items at SLU are those which can be used for both civilian and military applications. They are intended for use as civilian products, however their properties mean they can be used for anything other than non-combat purposes. These items cannot be exported to non-EU countries without a permit. In certain cases, permits are also required for their transfer within the EU.
What applies at SLU?
SLU must guarantee that all dual-use items are handled in accordance with the applicable laws and regulations, and that no export-controlled items, information, technical assistance or other services may be exported abroad without first having established if permits are necessary. Anyone who exports or otherwise transfers such items and technology out of Sweden is required to find out if they are classified as dual-use. If dual-use items will be sent to an EU country, this is referred to as “transfer”. As a rule, this means they are not subject to authorisation. However, the recipient must be notified of their classification.
The vice-chancellor decided in 2022 that the SLU policy for strategically sensitive products shall be as follows:
"One of SLU’s primary goals is to be an internationally leading university that plays a key role in the transition towards a sustainable society in a changing world. As SLU’s 2021–2025 strategy specifically highlights a robust international commitment and being a university with a strong collaborative spirit, it is important to ensure that our university complies with national and international export control legislation. Our university must safeguard democracy and democratic principles, human rights and freedoms. Our knowledge and research infrastructure must therefore not intentionally contribute to the production and proliferation of weapons of mass destruction or otherwise intentionally compromise national and international security.
All employees and people otherwise connected to SLU’s operations must comply with national and international legislation and SLU’s guidelines for export control and the non-proliferation of strategically sensitive products.
Through effective controls on the export of dual-use items, we can prevent weapons of mass destruction and destabilising build-up of conventional weapons from falling into the wrong hands."
Guidelines at SLU
What items at SLU could be classed as export controlled?
Dual-use items at SLU can include certain chemicals, human and animal pathogens and toxins, plant pathogens, IR cameras, advanced computing or measuring equipment, and software that can be used for both civilian and military purposes. The term “dual-use items” can also refer to knowledge of their manufacture and use.
Classify dual-use items
The items are to be classified by the person using them or who has knowledge of the item, together with the head of department or responsible head of research. The list in Annex 1 of the EU Regulation (chose preferred language) forms the basis for classifying dual-use items. The Division of Service, Security and Environment is responsible for creating internal guidelines and informing the organisation about export controls and non-dissemination of strategically sensitive products. The division has an export control coordinator who can help you with classification of the products and, if necessary, assist with obtaining an export permit. In Sweden, applications for international exports are assessed by the National Inspectorate of Strategic Products (ISP). However, the Swedish Radiation Safety Authority assesses applications for nuclear products. You should contact ISP for advice if you are having difficulty establishing classification or sanction laws.
Particularly sensitive products
Certain products may also require a permit for their transfer within the EU. These are listed in Annex IV of the dual-use ordinance. Several products listed in Annex IV are relevant to SLU. These include:
- certain chemicals
The catch-all provision
A “catch-all provision” has been established in order to prevent exporters actively attempting to circumvent the law. This means that if the exporter is aware that the product/technology can be used in weapons of mass destruction, it is considered an item subject to export control even if it is not included on the control list.
As a rule, export is permitted unless special reasons prevent it. However, there may be sanctions in place against certain countries, companies or individuals meaning that the possibility of collaborating with them is further limited. Sweden adheres to the sanctions adopted by the UN, EU and the Organization for Security and Co-operation in Europe (OSCE). Typical sanctions include weapons embargos, financial sanctions or banning equipment that may be used for a country to oppress its own own population.
Inspectorate of Strategic Products: introduction to dual-use products (only in Swedish).
Current sanctions on the Swedish Government’s website (only in Swedish)