On April 5, 2022, the Italian Unit for the Authorization of Armament Materials (the “UAMA Authority”) announced the launch of an e-licensing platform for dual goods, use of which will become mandatory as of July 1, 2022. This is in line with Recital 30 and Article 23 of EU Regulation No. 821/2021,[1] as well as Articles 12 and 13, which mention the need for Member States to adopt electronic licensing systems for uniform and consistent application of controls throughout the European Union.
The e-licensing platform was developed by the European Commission’s Directorate-General for Trade (“DG TRADE”) with the aim of adopting an identical structure within the European Union, enabling uniform and transparent procedures and the exchange of information and data between Member States and, where necessary, with partner countries.
The e-licensing platform will introduce a digital procedure, replacing a paper-based one, for the management of authorization procedures for the export of items such as dual-use goods and technologies,[2] goods subject to EU Regulation No. 215/2019 (known as anti-torture goods), and goods subject to EU restrictions on certain countries (e.g., Russia and Belarus).
In this way, exporters will be able to access the digital platform, submit the applications and the necessary documents, monitor progress, and receive quick responses from the UAMA Authority.
Each exporter[3] must have its own “ECAS Identity,” also known as an “EU Login.” This is the digital identity of every citizen of the European Union and is required for access to any EU digital program.
In addition, the e-licensing system will provide the necessary data protection, integrity, and confidentiality, as well as the operational continuity of the system—the system will be available to operators at any time and from any fixed or mobile location, thanks to personalized access to the system via dual-factor authentication mechanisms.[4]
[1] For a general overview of Regulation (EU) 2021/821, please refer to our article https://portolano.it/newsletter/portolano-cavallo-inform-compliance/european-union-adopts-new-regulation-no-2021821-on-dual-use.
[2] See Commission Delegated Regulation (EU) 2022/1 of 20 October 2021 amending Regulation (EU) 2021/821 of the European Parliament and of the Council with regard to the list of dual-use items.
[3] With reference to e-licensing, the term “exporter” indicates the authorized representative of an exporting company.
[4] For more information, please refer to https://webgate.acceptance.ec.europa.eu/frontoffice/welcome.
