The service is part of the European Union’s rules and procedures to regulate the export of dual use products, ensure international security, and prevent the proliferation of weapons.
This third-party assessment does not replace in any way the need for an export authorisation, which in Italy falls under the exclusive competence of UAMA (Unità per le Autorizzazioni dei Materiali di Armamento) within the MAE (the Ministry of foreign affairs).
Upon completion of the assessment, the report forms an integral part of the technical documentation required when applying for export authorization from the Ministry.
Additionally, it serves as a valuable reference for companies when exporting their products.
The control of exports for dual-use products is regulated by Regulation (EC) 2021/821 and its subsequent amendments (ex n. 428/2009). Annex I of this regulation lists all the goods that may have both civil and military uses, and is updated annually by the European Commission.
In addition to this specific legislation, there are also regulations that impose restrictions on certain embargoed countries, such as
- Iran - Reg. (EU) 267/2012 and subsequent amendments
- Russia - Reg. (EU) 833/2014 and subsequent amendments
- Syria - Reg. (EU) 36/2012 and subsequent amendments
- Libya - Reg. (EU) 204/2011 and subsequent amendments
- North Korea - Reg. (EC) 329/2007 and subsequent amendments,
- etc.
The regulation requires that the export of these goods has to authorised by the competent authorities of the member states.
In Italy, the application of these regulations is determined by Italian Legislative Decree No. 221/2017, which specifies that a request for export authorization must be accompanied by appropriate technical documentation related to the product being exported.
RINA, in collaboration with a specialised law firm and the University of Genoa, offers a service for the assessment of non-EU export products,.
This service is characterized by its independence and impartiality as a third-party, and results in the release of a Technical Report.
The report includes:
- a technical report on product features discovered during laboratory analysis and/or inspection visit
- an opinion from the Law Firm on whether the product falls under the Dual Use categories (based on the findings of the previous phase)
- a report from the University of Genoa on the product's potential military uses
- a preliminary opinion on whether an export authorization request or an information letter should be submitted to the Ministry (based on all three previous steps). The information letter may be required for goods that do not fall under the Dual Use categories, but still have potential military applications.
RINA also provides support for implementing internal compliance programs in accordance with Recommendations (EU) 2019/1318 and 2021/1700.
In 2016, the collaboration between RINA and the University of Genoa (UNIGE) received approval from the competent Ministry, resulting in a memorandum of understanding between UNIGE, RINA, and the Ministry of Economic Development (MISE).
Although this memorandum is no longer in force, communication channels with institutions such as the Ministry of Foreign Affairs (MAE) and the Customs Agency remain active. With our team's extensive experience across various sectors and the support of the Polytechnic School of Genoa, we have the expertise to prepare technical-scientific reports and preliminary opinions that help define your product's status under the EU's Dual Use rules. We can also assist your company in setting up its own internal compliance program.
