https://importexportlicensing.blog.gov.uk/2016/08/24/digitising-the-end-user-undertaking/

Digitising the end-user undertaking

World map (public domain image)

One of an exporter’s more onerous tasks is the completion of an end-user undertaking. These are commonplace across the export control community and usually come in the form of paper documents that an exporter has to get their customers to fill out in advance of trade, outlining what the end user plans to do with the exported items.

There’s no doubting the importance of an end-user undertaking; nobody wants the items listed in the UK Strategic Export Control Lists to end up in the wrong hands, to be used in ways that can cause harm to innocent parties. We need to know where things are going so we can ensure safe trade – it’s the absolute purpose of export control.

That said, the process can be a real pain for exporters because of how an EUU has to be filled out, and how documents need to be shifted back and forth between the parties to the deal. Delays, miscommunication, documents lost, all these and others can add to the difficulty of an already tricky business.

So we’re going to digitise it - with your help.

EUU and you

Our plan is to include a digital end-user undertaking as part of the implementation of SIELs and other licence types in the new licensing system. OGELs don’t normally require an end-user undertaking, and as we’re moving those across from SPIRE first our work on the EUU is in its infancy, but we’re now at the stage where we need input from exporters.

Can you answer these questions for us?

  • How often do you need to get an EUU?
  • What do you find most painful about the paper-based EUU system?
  • What do you want to see in a digital version of the EUU?

So we can make a system that works for exporters, we need to know what you don’t like about how the EUU works now. We already have an idea from previous research where issues often arise while completing an EUU but at this point we need those assumptions either confirmed or challenged, and the more feedback we can get the better.

An example of the type of information we’re after involves emails. With a digital system, it seems a retrograde step to ask you to fill out the end user’s details and then print out a form to physically send to them – our assumption is that our users will want the end user to fill out their part of the documentation online as well.

But will this cause any problems? Do you work with customers who don’t have an email address, meaning we need to retain some form of paper-led service, or does virtually everyone in the import/export field in 2016 communicate electronically?

We're also looking for people who actually fill out the end-user undertakings. If you complete EUUs either as an importer or in any other capacity, we'd very much like to hear your views on the process. We're interested in:

  • at what stage in the lifecycle of a deal you would expect to receive an EUU request
  • how long it takes to complete an EUU
  • whether there's anything you need to complete an EUU that you don't normally have to hand (ie details that you have to go and find out)

If you, or anyone you know, has filled out EUUs in the past, we'd love to know all about it.

Suggestions and requests

If you can help us out in this area, you can either respond with what you need from the EUU in the comments beneath this blog, or get in touch with our researcher Andrea (andrea.agueci@digital.bis.gov.uk). We’re aiming to have a prototype of the digital EUU ready soon, at which point we’ll be looking for users to help us test it so if you’re willing to get involved with that please indicate that when you get in touch.

Also, if you have any contacts who you have sent an EUU request to in the past, who you think might be willing to discuss the process with us, please ask them to contact Andrea at the address above. Hopefully we can smooth this process out for both exporter and end user, but we'll need your help to get there.

25 comments

  1. Comment by Chris Edwards posted on

    How often do you need to get an EUU? 5 to 6 times a year
    What do you find most painful about the paper-based EUU system? ensuring the details on the EUU match those in the SIEL application
    What do you want to see in a digital version of the EUU? simplicity

    Reply
  2. Comment by Gerry O'Driscoll posted on

    We only have 2-3 EUU per year.
    The biggest frustrations are delays in getting the information and the potential customers not understanding what they are being asked for.

    Reply
  3. Comment by Rob Pinkney posted on

    Digital system on line is a massive step in the right direction. However , if you think a Director or legal signature will want to log in and complete this task, I think its highly unlikely. More often than not they are very busy and see these tasks as mundane. You will have to make it very simple and quick, but I applaud the efforts in this area as its a major hinderance, We already have multiple documents in contracts, exporter letter of assurance, high risk diversion screening, but understand the need for the EUU.

    Reply
  4. Comment by Christel Compliance PEI posted on

    How often do you need to get an EUU?
    -->in average once a week.
    What do you find most painful about the paper-based EUU system?
    -->We deal with customers from all over the world, many whom do not understand how to fill this form or even how much information is required in section 3. They would often also forget to mention about 3 rd part and the ultimate end user.
    Of course, the other painful thing is the fact that we need the "original" undertaking" and the paper version may get lost, delayed and so on... so great news that this pain would disappear with the move to electronic application.
    What do you want to see in a digital version of the EUU?
    Key words: Clarity & Simplicity. We cannot expect everyone to understand UK legislation and UK export control requirement.
    A step by step process, which trigger the customer to answer simple / clear questions. It could be "do you use a freight forwarder?" Yes... then a new box appear asking the customer(end user) to complete here the info. then "do you use a 3rd party/consignee" yes, then again another box appear asking to add the relevant info. Do you know the ultimate end user? yes, then fill in name address website and so on. When technical words are used (such as consignee, end user, ultimate end user, forwarder...), to be able to hoover above them for a quick popup window with definition of the term. To have also a validity / check for error before submission (like we currently have for our SIEL applications on Spire).

    Finally, I imagine that with the new electornic application, the exporter will be automatically informed (mail?) by the ECJU when the end user has completed the undertaking?

    Reply
    • Replies to Christel Compliance PEI>

      Comment by Paul Carter posted on

      The comment from Christel Compliance covers similar issues I have, the biggest problem is getting the customer to return the EUU in good time to get a licence approval before the dispatch schedule, and mostly with third country customers the understanding of what detail is needed.
      What I feel would be advantageous is a data base with clear instructions for the completion of the form in different languages that could be linked to the form.

      Reply
  5. Comment by Beth James posted on

    How often do you need to get an EUU? - 2 - 3 times a year
    What do you find most painful about the paper-based EUU system? - It is not particularly painful at present, but the customers rarely provide sufficient detail around end use and often don't fill in the other boxes so that they mirror the details in the shipping paperwork . I don't see that this will change with a digital system.
    What do you want to see in a digital version of the EUU.- Ability to set up a template would be good.

    All customer communication in our business is done electronically so I would not see an issue with asking customer's to complete the document on line. That being said the current process works as well as can be expected for us and I don't see an electronic system doing much to change our experience. Maybe I will be pleasantly surprised?!

    Reply
  6. Comment by Martin Trigg-Hogarth posted on

    How often do you need to get an EUU?

    About 20 per year.

    What do you find most painful about the paper-based EUU system?

    Having to get originals

    Doing the OGEL for Military Goods the EUU is quite complex and the customers often end up filling out the wrong section or putting in the wrong info.

    What do you want to see in a digital version of the EUU

    Some form of error checking and making the filling out a work flow that if you give one answer then takes you to next right step

    Someone else said about hover over technical terms to define or have ? next to then to explain would be good.

    A way of going from a EUU to a licence application that takes the info from the EUU and pops it into the right fields on the licence application to make it easy to go from EUU to application.

    Maybe error checking to check the EUU to the licence if it is an OGEL for example check the destinations are allowed in the licence, maybe also the ML reference

    Reply
  7. Comment by Keith Fletcher posted on

    Why are we even asking for End User Undertakings in the 21st century, why can we not have some wording that can be used in the customer contract which fulfils the requirements, contracts and pre-contracts are usually signed for at a senior level an extra bit of legal up front is less of a problem than an annual undertaking and then we have lifetime contract cover..

    Also if the companies are related and it’s for intercompany transfer is a EUU needed at all.

    Reply
    • Replies to Keith Fletcher>

      Comment by James Curran posted on

      Thanks for your feedback Keith, I know we spoke to techuk around putting this in contracts etc and that is still an option. However, our user research also shows that in cases it can be a lot quicker to do this as a web form as part of your application for a licence. Saying that we'll also look into this and would be grateful for any help.

      Reply
  8. Comment by Tracy Kendle posted on

    How often do you need to get an EUU - 10-20 per year

    What do you find most painful about the paper-based EUU system? Length of time for EUU to be returned can be quite long.
    Customers don't complete properly even when very clear instructions are given or form already completed for them still get it wrong.
    Don't know quite what it is that they are signing therefore causing problems.
    Obtaining originals can be hard from some Middle East customers.

    What do you want to see in a digital version of the EUU?
    Simple instructions in plain English in a step by step process ie work flow, would be advantageous for most of our foreign customers.

    Reply
  9. Comment by Ray Kane posted on

    How often do you need to get an EUU?
    2 - 3 times a year
    What do you find most painful about the paper-based EUU system?
    Couriering copies back and forth for signing etc.
    What do you want to see in a digital version of the EUU.
    Simple, plain, non-ambiguous words and sentence construction with minimum text to satisfy the law.

    Reply
  10. Comment by Raquel Budimir-Hall posted on

    We probably average about 4 a month EUU requests/ applications. We find that the most difficult part of the EUU is that we have to reject the EUU due to incomplete or incorrect information. Technically, we already work digitally through emails as it can take quite a few back and forth emails to advise and explain the difference between End User and Consignee, or sometimes addresses are incomplete or inattentiveness on certain details. In reference to a previous comment, it would be beneficial to have a simplified version of directions. In addition, if a digital version is introduced, will a print out on letterhead and original signature still be required on site, prior to shipment of goods?

    Reply
    • Replies to Raquel Budimir-Hall>

      Comment by Howard Taylor posted on

      DIGITISING THE END USER UNDERTAKING - COMMENTS
      How often do you need to get a EUU?
      • Approximately 5 EUUs requested per month.
      What do you find most painful about the paper-based EUU System?
      • Waiting for the End User to complete, sign and return the EUU and subsequently requesting further information on what the goods will be used for.
      What do you want to see in a digital version of the EUU?
      • Everything that is on the current EUU and additionally the Ultimate End User name and address.

      Reply
  11. Comment by David Spencer-Healey posted on

    We instrument turbine parts that deliver the conditions occurring within an engine.
    All of this is hardware bits and process works of uncontrolled items but could be on customer parts that in itself has a level of control.
    We provide OEM equipment that interprets delivered conditions in data and we then manipulate it, and present it with meaning for use but again unless something like the software we are using assumes a control condition, then all hardware is still uncontrolled.
    However, this is all technology, that can be dual-use in turbines that are civil and maybe have a military use (or miss-use).
    Example. I currently have a friendly multi-national wanting to reuse with a modification a probe we supplied seven years ago. A metal pyrometer probed into an engine to scan blade surface temperatures but now to be used in a so, so secret military application, that they are struggling to release certain data to enable us to complete a design review for them of the modification required.
    I have a signed EUU that has been run past their Export control and legal committee that is approved to say nothing as follows; "Probes are to be modified .... for re-use in the testing of a development engine ... that if successful, might be used on either a civil aircraft turbine or military turbine".
    I assume this may not be adequate for a licence to be given, will have to submit it for likely rejection but who would I go to and how do I get the information the ECO might require?

    My point here would be, that at the moment such as I take the pain of trying to get to the end-user responsible but getting them to give and release any details "leaves us chasing shadows". You have to help us get to the end-user responsible, and that they must know by the boxes that must be completed in the new process that they must give the information required for the ECO decision. Such as I could be half way through the actual job in anticipation of a licence being granted but still left chasing the end-user with a stick (joke) to get the information required for the licence decision.
    Best Regards,

    Dave.

    Reply
  12. Comment by Lesley posted on

    At what stage would you deal How often do you need to get an EUU?
    Various
    At what stage in the lifecycle of a deal you would expect to receive an EUU request ?
    Upon each order receipt we require the EUU(when applicable) as until a licence is granted we can not accept the order.
    What do you want to see in a digital version of the EUU?
    Customers many whom do not understand how to fill this form or even what information is required. At each section a drop down box with a clear explanation in plain English of what is required.ie.
    Consignee - who will the goods be delivered to?
    End User - who will be using the goods?
    Third party - if shipping to an address which is not the End User of the goods who is this?
    Section 3 What are the goods to be used in or on? Please advise product type and purpose?
    A step by step process, which trigger the customer to answer simple / clear questions.
    To have also a validity / check for error before submission and not to be able to proceed until all information has been supplied.
    I totally agree with Christel's comments above.

    Reply
  13. Comment by Victoria Gosden posted on

    I request an EUU approx. 20 times a year.
    I agree the EUU needs to be simple and intuitive to complete as a lot of our customers have difficulty filling in this form despite trying to communicate with them to give them guidance. There seems to be confusion over the meaning of 'consignee' for example, which has caused me long delays trying to help the end user understand this, as it has a different interpretation for them.
    Definitions are definitely a problem, so being able to hover over wording for a simple definition would be helpful. And obtaining the original document from the client can be an issue, especially the middle east.

    Reply
  14. Comment by Andrea Agueci posted on

    Just wanted to say thanks to everyone who took the time to answer our questions!

    We have received a huge amount of useful feedback and I will try to get back to you individually in the next few days.

    Reply
  15. Comment by Charlie Farrow posted on

    A Digital EUU is great! In my opinion it would be great if:

    It was form based with maybe just one page that needed to be uploaded with a signature, or they complete the online form which when they print they can sign.

    It's really important that the digital EUU should match the application - so we should do the application and then the customer should complete the EUU on the back of it, so the application information can be pre-filled into the EUU.

    It should be part of the process, rather than a separate interaction with the customer, so the exporter should be able to see it and make sure it been done, but we shouldn't have to physically handle it, just make our end customer do it to 'complete and submit the application'.

    Manual signed EUU's should be abolished. It's a real pain!!

    Reply
  16. Comment by Clare Devlin posted on

    We do about 80 EUU's a year.

    Main issues are:
    - overseas customers not understanding what is needed
    - confusion over end users and ultimate end users
    - we work with a lot of research organisations who often state the individual doing the research rather than the organisation, and multiple addresses depending on which dept it is and then not being able to get the right person to sign them
    - the need for a hard copy seems ridiculous these days
    - I can see potential issues with getting an authorised signatory to log on to sign them

    Reply
  17. Comment by Lisa Lucas posted on

    We need to obtain EUU's mainly on a day to day basis depending on the order. What we find frustrating is the customer not fully completing the EUU's correctly or them not understanding the process. Also when we have a licence issued it can take a very long time to receive the signed original back and causes further delays. In the digital version it would be beneficial for customers to be clear on what they are having to complete whether it be highlighted and not be able to be processed until all fields have been completed. It is difficult to stop all problems/issues associated with obtaining EUU's but the digital system may eliminate the majority.

    Reply
  18. Comment by Denise Taylor posted on

    How often do you need to get an end-user undertaking (EUU)? On a very regular basis i.e. with every Defence product we sell abroad.

    What do you find most painful about the paper-based EUU system? Getting the consignee to understand that it is the End Customer that is required to complete this form and to be very specific in section 3.

    What do you want to see in a digital version of the EUU?
    Main issues are:
    - overseas customers not understanding what is needed
    - confusion over end users and ultimate end users
    - the need for a hard copy seems ridiculous these days
    - I can see potential issues with getting an authorised signatory to log on to sign them

    Reply
  19. Comment by Mary Edwards posted on

    How often - usually between OGL EUU and SIEL EUU approx. 3 a month. However, in the last 2 weeks I have initiated 7 with customers.
    Painful - I have taken to typing out as much of the information as I can for my customers, ask them to check and change accordingly. Some are great and others come back with a completely changed EUU, which takes up more time as I have to go through it again with them. Some actually disagree with the EUU and ask for a BIS contact so they can speak to them directly.
    Digital Version - this needs to clearly describe what is needed in an EUU, especially 1) Who is the end user. 2) the EUU relates to the end user only. 3) a section for the ultimate end users information to be filled in. 4) maybe a drop down menu for section 3, which will force companies to enter application, usage, programme/project name. Have a few in there like, tanks, cameras, ships and then an other text box, that way they will have an idea of the info needed.
    EUU FORM: Can this be a single entry point and depending on the information supplied the supplier (myself) can determine if an OGL or a SIEL is required and I can select a button accordingly which will automatically populate that form. I am finding that I will have my customer complete one EUU and when they return it I can actually use an OGL G,S&T or visa versa.
    Lifecycle - I request EUU once I have a firm order.
    Completing an EUU - this doesn't take long at all. The time is taken up with customers changing the information because they read it differently. (A clear explanation before each section of the requirements may help). Question: If the form is going digital does not mean we no longer have to ask the customer for the original? How will this be audited?

    Reply
  20. Comment by Simon Rigby posted on

    -How often do you need to get an EUU?
    Potentially once or twice a year. It also depends on if there is a Stockist and/or Ultimate End User involved.
    -What do you find most painful about the paper-based EUU system?
    Having to produce a “guidance” template showing the end-user exactly how the document needs to be filled out. Bearing in mind that English is (at best) their second language and will most likely not complete it according to the requirements.

    Having to go back to them to explain the bits they need to change and why.

    Having to go through the above procedure often in advance of receiving the purchase order The exact product descriptions and breakdown of goods may not match the purchase order entries and therefore our invoices.

    - What do you want to see in a digital version of the EUU?
    A process that is flexible depending on the access end users have to IT/ emails/ the internet etc.

    -At what stage in the lifecycle of a deal you would expect to receive an EUU request
    It depends on the product and the destination country as well as the nature of the end user. It has been the case that we would want to be 100% sure that a licence will be granted before we sign/commit to sales contracts and performance bonds. So the export licence EUU could be virtually at the front of the purchasing process.

    - How long it takes to complete an EUU (ie. how long does it take to get one back, completed?)
    It depends on the complexity of the purchase/sale process. Anything from 2days to 12months plus.

    Reply
  21. Comment by Joanna posted on

    How often do you need to get an EUU? - upto 6 times a year

    What do you find most painful about the paper-based EUU system?

    Customers don't understand the rules & regulations needed with filing EUU,
    I am not British ,english is my 2nd language - but i think the guidance is straight forward, but unfortunately not for our American friends.
    And most painful is getting back the original file

    What do you want to see in a digital version of the EUU?
    A process that is flexible depending on the access and option to amend details if required if any mistakes made

    Reply
  22. Comment by Claire Dawson posted on

    We are usually obtaining between 15 and 20 EUU's per annum, but as we are looking to expand our exports, this could increase over the next year. Applying for SIEL's, I find the current system relatively easy to use as an exporter, but we do experience issues on occasions with the consignee and End Users not completing the EUU forms correctly. Usually with a bit of help and an extra indication of what information is required and where on the form, they always manage to complete it in the end. I don't believe the process would be helped by expecting the end user/consignee to log in to a UK online system to complete EUU's, especially when English may not be their first language. What the customers find most frustrating is having to wait for the licences to be issued. I do explain about your stringent 8 stage checking procedure and why it is so involved, and that usually calms it down. I would echo comments by others that requiring MD/Director level involvement at any stage of an EUU or licence application could hold up the process due to their other responsibilities within a business.

    Reply

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