Now this is a juicy one and one that I know you have all been waiting for!
As you may or may not know, our payload’s thermal infrared camera is a FLIR Tau 2 and this is covered under something called dual-use. This is essentially something that is used in both commercial and military applications and as a result, it requires an export license in order for it to be taken out of the UK.
If you were wondering, the penalties for attempting to export dual-use items without a valid export license can involve [source]:
- your licence being revoked
- goods being seized
- a fine and/or imprisonment for up to 10 years
As you can imagine, we didn’t fancy pushing our luck with these! In the lead-up to the campaign, it was our Project Manager’s job to navigate the murky waters of export laws, licenses and systems. Since we have now gone through the process unscathed, we thought that we should document it in case future teams need to as well!
In the UK, the first thing that you need to do is sign up to SPIRE which is the UK government’s export control organisation’s online licensing system. Interestingly, it is the same one that you would use to take an F35 out of the country! After a quick chat with the friendly export control joint unit we determined that we needed to apply for a Standard Individual Export License (SIEL). This essentially allowed us to take Pathfinder out of the country for up to 12 months.
Following the form through, we were guided through the steps to fill out the application. The form was registered under the University of Bristol so that different team members would be allowed to travel with Pathfinder and the OGEL checker was used to determine the exact restrictions that covered our items: 6A003b4b. The consignee and end user were set as the University of Bristol, C/O Luxemburg Airport and the University of Bristol, C/O European Space Agency respectively. This was because the team were still in control of the items whilst they were being transported.
The conditions of the license were that it was to remain in the possession of the team and so when taken on planes, the items had to come into the cabin. It was also found that the team needed to declare the goods to customs. After some more back and forth, it was discovered that this was not to be as easy of a process as it perhaps should be. The easiest way for a customs declaration to be made is to hand the goods over to a third party to ship the goods for you and in the process, they handle the declarations. Since the team were carrying the goods with them, this wasn’t a possible option. Therefore, an ATA Carnet was used. This can be thought of as a passport for goods. We applied for one through the London Chamber of Commerce as it was quicker to set up an account with them as opposed to the Bristol Chamber and at this stage, we only had 2 weeks until we were due to travel. This application involved declaring Pathfinder’s whole list of constituent components that the team were transporting including serial numbers, quantity and value. Whilst this process was much quicker than the SIEL, it came at a steep financial cost!
Fast forward to the day of travel. This was a day that we had dreaded – the whole campaign relied on this going smoothly and whats more our Project Manager was travelling alone since the other team members had left it too late to book the same flight! The first step at the airport is normally to check in a bag, but for us it was to pay the customs team a visit. We entered a small office with only a red doomsday landline in it, rang the number and then waited for a customs agent to arrive. We then filled in the green pages of the Carnet and after everything was ticked off were able to go about our business as usual in the airport. Thankfully, once the security team had been reassured that the Dewalt hard carry case contained Pathfinder alone and no drills, we were let through with ease. This was made a lot simpler since we contained no batteries, a fact that we discovered when ringing the airline beforehand!
Once we landed in Luxembourg, we had the excitement of heading through the red channel. After being greeted by a friendly armed customs agent, we filled out the yellow section of the carnet and were allowed through, into the EU!
On our return, we had to do the same in reverse. Our lead electronics engineer filled in the carnet paperwork at Luxembourg airport before passing through security. He then passed back through the red channel at Heathrow and filled in the final green page. We then concluded the process by sending the remaining paperwork back to the London Chamber of Commerce.
All in all, the process went smoothly. It took us nearly 3 months to receive the SIEL from the export control joint unit and a further 2 weeks to organise the ATA Carnet. We would particularly like to thank the ESA Education Office for their support with securing the Carnet, Mimi at the export control joint unit for her support with our SIEL application and the London Chamber of Commerce for their quick turnaround time with the Carnet, Matt Watson and of course – our wonder Project Manager for all of his work in writing the applications!