|U.K. unmanned aircraft Export Controls||- Export Controls|
Above: head on view of the InView unmanned aircraft.
Form 680 (known as the 'F680') is used by the government to consider the release of classified information held by defence companies for use in export promotion. It also allows companies to obtain an indication of the government's view about a subsequent export licence application, which can help direct their marketing efforts.
What is Form F680?
If an exporter plans to sell, demonstrate, promote or export certain equipment, goods or classified information, then Ministry of Defence (MOD) clearance is needed.
Form 680 (known as the 'F680') is used by the government to consider the release of classified information held by defence companies for use in export promotion. To get the necessary approval, exporters should complete an F680 application. This process applies to MOD agencies and other parts of MOD.
The MOD F680 must be completed if you wish to seek approval for the release of information classified at Confidential or above in support of a marketing campaign. It is also required by List X companies to promote any goods unless they have written confirmation from MOD that the goods are private venture unclassified.
There are other reasons for seeking F680 approval. It is a requirement of certain Open General Licences (OGELs) where assets are classified at Confidential or above are to be exported, that F680 - or F1686 - approval is obtained from the MOD. In addition, for the OGEL Military Goods: For Demonstration, an F680 is required for any goods, regardless of classification.
For more information see our guide on Military Goods OGELS. If you are going to take equipment or goods to show at an exhibition, they must be unclassified. F680s cannot be issued where it is impossible to tell which countries are going to be in attendance. An F680 application is not necessary for Dual-Use goods.
Holding an F680 for the marketing of a product to a specified destination does not guarantee that an export licence will be granted for its subsequent export to that destination. However, applying for F680 clearance has advantages for businesses, in that it should give some indication as to whether there are likely to be difficulties in getting an export licence. It could also help speed up the assessment of any subsequent licence application if circumstances are unchanged since the F680 approval.
MoD F680 applications
Since 18 May 2009, all applications for Form 680 (F680) clearance are made via SPIRE. The F680 online form replicates the information needed in the old form.
Who assesses the F680?
The F680 system is run by the Ministry of Defence's (MOD's) Export Policy and Assurance team - formerly the Directorate of Export Services Policy.
Once an application is received, it is circulated to specialist advisers within the MOD, the Foreign and Commonwealth Office and the Department for International Development for comment. The MOD aims to respond to an application within 30 days of receiving it.
Download the instructions on completing Form F680 at https://www.spire.bis.gov.uk/docs/MODF680application.pdf .
The following table is derived from the U.K. Department for Business, innovation and Skills "Goods Checker".
See http://www.mtcr.info/english/ for the MTCR web site.
If the UAV has a range in excess of 300 km, and a payload in excess of 500 kg, then the UAV falls in Category I "Complete Delivery Systems" Item 1 Part 1.A.2 and getting export approval is that much more difficult.
If the UAV has a range in excess of 300 km, and a payload of less than 500 kg, as many unmanned aircraft do, then the UAV falls in Category II "Other Complete Delivery Systems" Item 19 Part 19.A.2 , and getting export approval is easier.
Thanks to Wing Commander Tony Smith at the UKTI Defence and Security organisation for reminding us of the MTCR.
If you wish to export a system and not contravene Export Control legislation, you need to be very careful if any of the intellectual property, components or software associated with your system have been developed with military funding.
A typical problem can occur if a development is started with company Private Venture and / or funding from civilian sources, after which further developments are introduced that have been funded by military bodies, such as a Ministry of Defence. Even if further development work then takes place with Private Venture or other civilian funding, there remains a component of the system with a traceable military lineage which could contravene Schedule 2 Section ML10.