The organisers of FEE, in cooperation with multiple UK Government departments, have defined the following policy on matters of compliance at FEE.
All products on display at FEE must comply with the UK Export Control Act 2002 (as amended) and it is solely the exhibitors' responsibility to obtain all necessary licenses and authorities. Compliance audits will take place throughout FEE and exhibitors who are in breach of this policy will forfeit their right to exhibit.
The controls on Category A goods apply to all forms of promotion, including general advertising. The act of distributing hard copy or electronic brochures or catalogues containing reference to any such product, or the inclusion of images of such products in stand displays, or any other form of other marketing of these products at FEE is prohibited unless authorised by a valid Standard Individual Trade Control Licence (SITCL), which must be obtained from UK DIT Export Control Joint Unit (ECJU) by the exhibitor or agent.
The Export Control Act 2002 covers the exportation of goods, the transfer of technology, the provision of technical assistance overseas and activities connected with trade in controlled goods.
Exhibitors whose activities may be impacted by this Act and associated control orders are to ensure they have the necessary licenses and mechanisms in place. www.gov.uk/guidance/beginners-guide-to-export-controls
ECJU guidance on the legislation affecting participation at exhibitions can be found on the www.gov.uk/trade-controls-military-goods-on-trade-fairs-and-exhibitions.
For further information on UK licencing issues exhibitors may contact the DIT ECJU Helpline on +44 20 7215 4594
A. Compliance and Eligibility to Exhibit
All exhibitors at FEE will be subject to the UK Export Control Act 2002 and the Export Control Order 2008 - which is secondary legislation under the Act that came into force on 6 April 2009. The Export Control Joint Unit (ECJU), part of the Department for Department of International Trade (DIT) are the UK government department responsible for licensing and controlling the export of strategic goods and technology, including all items specially designed or modified for military use, and many types of paramilitary goods. The Organisers of FEE work with and act in support of the ECJU to ensure that all Exhibitors' equipment, services, documentation and all other forms of visual promotion and display, exhibited or proposed, must comply with:
- UK law and the UK's international undertakings
- EU/UN Law and EU/UN international undertakings
The controls encompass export from the UK, and also certain UK involvement in movements of these goods between overseas countries where the deal is made in the UK or by a UK person based overseas. It is important that your organization is aware of all current UK trade controls and whether they affect your business prior to exhibiting at FEE. There is a requirement for a Trade Control Licence from the Export Control Joint Unit if the goods on display, or the related promotional material, fall under Category A of the Trade Controls.
Breach of any aspect of UK trade controls will be treated as breach of the FEE terms and conditions regarding Compliance and Eligibility to Exhibit.
The promotion of Category A items is prohibited at all Clarion Defence & Security Events. This restriction applies to all forms of promotion, including the distribution of brochures or other promotional material from your stand which features images or details of any Category A goods, even if your company does not intend to market these goods at the event.
Category A and prohibited goods include:
- Goods designed for the execution of human beings
- Goods banned by the EU because of evidence of their use in torture
- Restraints specially designed for restraining human beings.
- Riot control or self-protection devices designed or modified to administer an electric shock.
- Certain cluster munitions, including components.
- Land mines, anti-personnel mines and anti-material cartridges (Land mines act 1998)
If you are caught promoting category A or controlled goods without a relevant UK licence, you will be ejected from the event and could face enforcement action from relevant authorities.
General advertising and promotion of Military Listed Category B and Category C goods are exempt from the control and therefore are not controlled at trade fairs. Category B and C goods are of course subject to export controls and will require an export licence if exported.
- Part 1 Category A Goods - Certain Security and Para-military Police Equipment; Cluster munitions, explosive submunitions and explosive bomblets.
- Part 2 Category B Goods - Small arms and light weapons; Accessories and ammunition for small arms and light weapons within ML1 and ML2; Light weapons within ML4; Ammunition for light weapons within ML4; Hand Grenades; MANPADS, missiles for them, associated equipment and their specially designed components; Long range missiles; Components for all goods listed in Part 2.
- A full definition of the items included in Category A, B and C goods is contained within Schedule 1 of the Export Control Order:
B. Equipment, services and documentation exhibited or promoted
1) Equipment, services, documentation and all other forms of visual promotion and display, exhibited or proposed, must comply with current UK Law and the UK’s international undertakings, EU/UN Law and EU/UN international undertakings
2) The following equipment and services which fall under Category A of the UK’s trade control legislation are prohibited at FEE unless explicitly authorised by a valid Standard Individual Trade Control Licence, which must be obtained from DIT Export Control Joint Unit by the exhibitor or agent
- Goods designed for the execution of human beings - such as gallows and guillotines, electric chairs, air-tight vaults designed for the purpose of execution by the administration of a lethal gas or substances, automatic drug injection systems designed for the purpose of executing human beings by the administration of a lethal chemical substance
- Restraints specially designed for restraining human beings - leg-irons, gang chains, shackles and individual cuffs or shackle bracelets except those that are ‘ordinary handcuffs’ (handcuffs which have an overall dimension including chain, measured from the outer edge of one cuff to the outer edge of the other cuff, between 150 millimeters and 240 millimeters when locked and have not been modified to cause physical pain or suffering), restraint chairs unless designed for disabled persons, shackle board, thumb-cuffs and thumb-screws, including serrated thumb-cuffs, electric shock belts
- Portable devices designed or modified for the purpose of riot control or self-protection by the administration of an electric shock - such as electric-shock batons, electric-shock shields, stun-guns and electric-shock dart-guns - components specially designed or modified for the aforementioned
- Hand-held, spiked batons
- Cluster munitions, explosive sub munitions and explosive bomblets
- Landmines , anti-personnel mines and anti-material cartridges
3) All cluster and non-unitary munitions with the exception of those which comply with the provisions of the Oslo Declaration. Specifically they must have all of the following characteristics:
- each munition contains fewer than ten explosive sub-munitions.
- each explosive sub-munition weighs more than four kilograms.
- each explosive sub-munition is designed to detect and engage a single target object.
- each explosive sub-munition is equipped with an electronic self-destruction mechanism.
- each explosive sub-munition is equipped with an electronic self-deactivating feature.
All other non-unitary munitions, explosive sub-munitions and explosive bomblets, together with components specifically designed for such cluster munitions, explosive sub-munitions or explosive bomblets are prohibited. This exclusion does not, however, apply to conventional munitions which are designed to dispense flares, smoke, pyrotechnics or chaff, electrical or electronic effects or which are designed exclusively for an air defence role.
4) Pursuant to Section 1 (4) of the Landmines Act 1998, An anti-personnel mine is a landmine which
(a) is designed to be detonated by the presence, proximity or contact of an individual; and
(b) is capable of incapacitating, injuring or killing an individual.
A component of an anti-personnel mine is anything designed or adapted to form part of an anti-personnel mine. A prohibited object is an anti-personnel mine or any component of an anti-personnel mine.
1. Cluster munitions means conventional munitions designed to disperse or release explosive sub-munitions or bomblets.
2. Explosive sub-munitions means conventional munitions, weighing less than 20 kilograms each, which, in order to perform their task, are dispersed or released from another conventional munition and which are designed to function by detonating an explosive charge prior to, on or after impact. The Organisers reserve the right to make the final decision concerning the eligibility of exhibits and matters of compliance.
3. Explosive bomblets means conventional munitions, weighing less than 20 kilograms each, which are not self-propelled and which, in order to perform their task, are specifically designed to be dispersed or released by a dispenser affixed to an aircraft, and are designed to function by detonating an explosive charge prior to, on or after impact.
1. Compliance audits will take place before and throughout FEE to ensure that equipment, services, documentation and all other forms of visual promotion and display exhibited comply with the above-mentioned undertakings.
2. Exhibitors promoting or exhibiting prohibited items, either overtly or covertly during the exhibition will be in breach of their contract with the Organisers and will forfeit their right to exhibit at FEE. The Organisers will take appropriate action which may involve the removal of equipment, documentation and/or visual promotional material from the stand into safe custody. The ECJU and other relevant authorities will be informed by the Organiser of any breach which may result in legal action being taken against the exhibitor by these authorities. The stand may be closed immediately and the exhibitor will have no claim for redress against the Organisers, nor any refund for loss of fees.
3. Exhibitors will not be permitted to exhibit if their sole or predominant aim is to import for immediate resale.
4. The Organisers reserve the right to make the final decision concerning the eligibility of exhibits and matters of compliance.
Note: services in respect of the list of prohibited equipment are also prohibited.
C. Prohibited Activities
The UK’s trade control legislation affects anyone in the UK regardless of nationality. Trade controls licence the trading and transacting in controlled goods between two overseas countries where the deal is made in the UK.
The controls are intended to impact on ‘trafficking and brokering’ type activities that facilitate the movement of controlled military or paramilitary goods including the movement of goods to countries subject to sanctions, embargos or other restrictions. Updates about arms embargos and other trade control restrictions can be found on the www.gov.uk/current-arms-embargoes-and-other-restrictions.
All exhibitors must ensure that they have all necessary trade control licence in place before undertaking any controlled business or activity, in line with their statutory legal requirements under Part 4 of the Export Control Order 2008. For more information and to access a copy of the legislation, see the guide on the www.gov.uk/guidance/beginners-guide-to-export-controls
Any exhibitor engaging in controlled business or activity either overtly or covertly during the exhibition without all necessary trade control licenses being place will be regarded as a breach of their contract with the organisers and will forfeit their right to exhibit at FEE. The organisers will take appropriate action which may involve the removal of equipment, documentation and/or visual promotional material from the stand into safe custody. The ECJU and other relevant authorities will be informed of any breach which may result in legal action being taken against the exhibitor by these authorities. The stand may be closed immediately and the exhibitor will have no claim for redress against the Organisers, nor any refund for loss of fees.
D. Dangerous exhibits, prohibited weapons, firearms & hazardous equipment
Any exhibitor, who, by way of trade or business, manufacturers, sells, transfers, repairs, tests or proves or exposes for sale or transfer or has in his possession for sale, repair, test or proof any firearm or ammunition to which Sections 1 and 5 of the Great Britain Firearms Act 1968 (as amended) apply, must first obtain a Metropolitan Police Service Registered Firearms Dealer Certificate to cover their temporary exhibiting activities at Olympia. In addition, any exhibitor who has in his possession or purchases or acquires, or manufactures sells or transfers any firearm and ammunition to which Section 5 of the Act applies also requires a separate authority issued by the Home Office to cover their activities at Olympia (full details will be issued within EZONE). Failure to obtain a Registered Firearms Dealer certificate and Section 5 authority, as applicable, prior to arrival in the UK will preclude an exhibitor from exhibiting. Any exhibitor who attempts to exhibit or sell any firearm or ammunition without the appropriate certificate and authority will be liable to prosecution.
E. The Criminal Justice Act 1998 (Offensive Weapons (Amendment) Order 2004
The display of Offensive Weapons is strictly controlled under UK legislation
Section 141 of the Criminal Justice Act 1988 (CJA) provides that any person who manufactures, sells or hires or offers for sale or hire, exposes or has in his possession for the purpose of sale or hire, or lends or gives to any other person, a weapon to which that section applies shall be guilty of an offence.
The importation of any such weapon is also prohibited under the CJA.
The Criminal Justice Act 1988 (Offensive Weapons) Order 1988 specified descriptions of weapons to which section 141 of the Criminal Justice Act 1988 applies. This Order adds the weapons the stealth knife and straight, side-handled or friction-lock truncheons, to the list of specified weapons contained in the 1988 Order.
An exemption to the act is provided for those companies supplying the Crown and organisations from countries covered under the Visiting Forces Act 1952.
Please see the Government information regarding Offensive Weapons:
Visiting Forces Act 1952:
The Criminal Justice Act 1988 (Offensive Weapons) (Amendment) Order 2004:
F. Exhibitor registration & accreditation
All personnel attending FEE, including exhibitors’ stand personnel, representatives, guests, contractors/subcontractors (stand build and services) and security personnel who will be working on stands and hospitality areas, must be pre-registered to attend FEE. It is the responsibility of the exhibitor to check the bona fides of all personnel that they register to attend FEE. All exhibitors must inform the Organisers of any private security officers or security officers from their own company who may be onsite during FEE. The exhibitor takes responsibility for the bona fides of such security officers, including Security Industry Association licensing checks where applicable. Security Officers employed by exhibitors have jurisdiction on their tenancy areas only and are not permitted to carry out any duties elsewhere within Olympia. Information regarding exhibitors’ security and licensing is to be provided to the Organisers on request. Security Officers and Police Officers employed by the Organisers and Organisers Security Management have primacy in all matters concerning breaches of security and have right of access to all tenancy areas.