Export zboží dvojího užití z ČR v roce 2026 - licence a povinnosti

What are dual-use goods and why is their export controlled?

Controlling the export of such sensitive items is necessary to prevent their misuse. The Czech Republic and other states therefore actively cooperate in international control regimes (e.g., the Wassenaar Arrangement, the Australia Group, etc.), which establish principles for trade in dual-use goods. Legal export is not prohibited, but each individual transaction is assessed – if there is a risk that the goods could contribute to illegitimate armament or the proliferation of weapons of mass destruction, you will not receive an export permit. This protects both national security and the business interests of honest companies that do not want to be involved (even unintentionally) in illegal activities.

All exporters from the Czech Republic are therefore bound by strict rules set by both EU and Czech legislation. Specifically, this involves Regulation (EU) 2021/821 (the current EU export control framework) and the related Act No. 594/2004 Coll. in Czech law. These regulations determine which goods require a permit, how the licensing procedure works, and what penalties apply for non-compliance. For you as an exporter, this entails a fundamental obligation: before exporting dual-use goods, you must obtain an export permit (license) from the competent authority.

Do you need a license to export dual-use goods?

Every entrepreneur who wants to export an item classified as a dual-use good from the Czech Republic must have a valid state permit in advance. In practice, this means that a license is necessary for export to any country outside the EU. While the free movement of goods generally applies within the EU, there are exceptions – for a few of the most sensitive items (listed in Annex IV of the EU regulation), authorities require a permit even for transfers between member states. Therefore, it cannot be said that intra-European trade is entirely without restrictions. Every exporter must verify whether their specific product or technology is subject to the control regime.

The key is to correctly identify whether your goods are on the list of controlled items. This list is highly technical (describing in detail the parameters of equipment, materials, and technologies) and is updated annually. A layperson may find it difficult to determine whether a specific product falls under the dual-use goods regime – for example, a minor change in technical specifications can decide whether a license is necessary or not.

That is why, in practice, exporters often turn to experts or directly to the Licensing Administration of the Ministry of Industry and Trade for confirmation. Need help with this? Our Prague-based export law specialists are ready to advise you – write to us at consultations@arws.cz.

Be aware that even goods not explicitly listed may require a permit if there is a risk of their misuse for undesirable purposes. This is known as the catch-all regime – authorities can insist on a license even for an unlisted item if they find it could be used, for example, in an arms program or for the production of nuclear, chemical, or biological weapons.

As an exporter, you even have an obligation to watch for such possibilities: if you know or suspect that a seemingly ordinary product could be used by the buyer to develop weapons of mass destruction, you must not export it without the authorities' consent.

In addition to the goods themselves, you must also monitor the destination and end-users. Some countries are subject to international sanctions or embargoes, so exports to them may be completely restricted (even with a license) or subject to special strict conditions. You must evaluate these circumstances before exporting. For example, exporting dual-use goods to countries like Iran, North Korea, or currently Russia involves additional prohibitions, and it is always necessary to thoroughly check the current status of sanctions regulations. Even in less problematic cases, authorities will request information about who the final recipient is and what the goods will be used for.

It is also worth noting that an export is not just the physical shipment of a product. The transfer of software or technical documentation electronically or by telephone abroad is also considered an export. Therefore, if you send sensitive data via email to a client outside the EU, the same regulations apply as for exporting equipment. Companies often forget this – thinking they have "just sent software online," they may unwittingly break the law.

How to obtain an export permit (license)?

Once you determine that you need a license, you will face an administrative procedure before the Licensing Administration of the Ministry of Industry and Trade (MIT). The application for an export permit is submitted in writing – today, most companies use electronic submission (via the MIT online portal, data box, or email), but you can also deliver it in paper form. The authority has a statutory period of 30 days to make a decision, calculated from the receipt of a complete application. During this time, it will request opinions from other bodies (e.g., the Ministry of Foreign Affairs, Ministry of Defence, and others depending on the nature of the goods) and assess whether the export is in line with international security policy. You will typically receive a decision within a few weeks.

For the application to be approved, you must provide all required documents. The basis is the application form (available on the MIT website), where you fill in information about yourself, the goods, and the planned transaction. You need to attach annexes: primarily a document from the foreign partner confirming the end-use of the goods. This can be an import certificate issued by the authorities of the importing country, or more commonly, an end-user statement, where your customer confirms in writing what the goods will be used for and that they will not be re-exported without the consent of the Czech authorities. You will also attach a copy of the contract or order with the partner (or at least a draft), an extract from the Commercial Register for your company, and possibly other specific permits – for example, for the export of nuclear materials, you must first obtain consent from the State Office for Nuclear Safety. The licensing authority should inform you about all these requirements, but it is good to know in advance what to prepare.

If the application meets all formal requirements and there are no security obstacles, the MIT will issue the permit. It may also set certain conditions (e.g., limited validity, an obligation to report when the export was carried out, etc.). The fee for granting the license itself is symbolic – CZK 500.

However, you need to be aware that if you make a mistake in the application or something is missing, the procedure will be prolonged, or you may not get the permit at all. Therefore, it pays to devote maximum care to the preparation. Our lawyers can prepare the application for you completely or review it to ensure everything goes smoothly. Need help with this? Contact us at consultations@arws.cz.

Frequent exporters should also consider an Internal Compliance Program (ICP). This is a set of internal processes, training, and rules through which your company systematically monitors compliance with export regulations. Having an established ICP significantly increases the authorities' trust – it is even a condition if you apply for a broader global authorisation for repeated exports or want to use EU general licenses. Specialised legal advisors can help you set up an ICP and your overall export compliance strategy. Looking for specialists in this area? Our lawyers are ready to help you – write to us at consultations@arws.cz.

Leave nothing to chance – contact us at consultations@arws.cz and let specialists handle this matter for you.

What are the penalties for illegal export or breach of obligations?

Despite all the awareness campaigns, some companies occasionally underestimate their obligations – whether out of ignorance or intentionally. However, the consequences can be devastating. Unauthorised export of dual-use goods is an offence in the Czech Republic, punishable by a fine of up to CZK 20,000,000, and in serious cases, it can even be a criminal offence with a prison sentence of up to 8 years. Penalties also apply to legal entities – in addition to a fine, a company may face other measures, such as forfeiture of seized goods, a ban on activities, or mandatory supervision.

The Customs Administration is primarily responsible for monitoring compliance, controlling exports at the borders and subsequently. Customs authorities can detain a suspicious shipment, check documentation, and, if a violation is found, initiate offence proceedings. This can result in a hefty fine. For a company, this means not only a financial loss but also a delay or failure of the business deal (if the goods do not reach the customer on time), and last but not least, significant reputational damage. It is difficult to explain to partners and authorities that your company has failed in an area as sensitive as the export of strategic goods.

Typical penalties and how to prevent them

As you can see, taking risks does not pay off. Although Czech authorities prefer prevention and education over imposing sanctions, they act uncompromisingly in cases of serious or intentional violations. Moreover, for entrepreneurs, ignorance of the law is no excuse – the argument that you did not know about the need for a license will not absolve you of responsibility. The Customs Administration may also target your company for more frequent inspections. In short, the export agenda is so complex and sensitive that any mistake can have fatal consequences for your business.

Worry-free exporting: how lawyers from ARROWS can help you

The obligations associated with exporting strategic goods can seem daunting at first glance. For companies without specialised legal support, it is difficult to keep track of all the laws, amendments, and current sanctions – let alone fully understand and apply them in practice. This is precisely where the lawyers from ARROWS come in, as they have long specialised in international trade and export controls.

We can quickly analyse your situation and propose a tailor-made legal solution. Thanks to our experience from dozens of similar cases, we know exactly what to watch out for and what pitfalls may arise. Our portfolio includes more than 150 joint-stock companies, 250 limited liability companies, and dozens of public institutions – which also attests to our broad expertise and the trust of our clients.

Furthermore, ARROWS operates internationally: in over ten years, we have built a network of partner offices (ARROWS International) around the world. We handle cases with an international element on a daily basis, so we can ensure a smooth process even for transactions heading to distant countries or involving foreign entities.

If necessary, we can also connect your dealings with local authorities or experts to ensure you meet all the requirements of the given country. Maximum discretion and responsibility are a matter of course – our law firm is insured for up to CZK 500,000,000 in case of damages.

We provide our clients with a complete service: from the initial consultation and analysis, through the preparation of all documents and communication with authorities, to final representation during inspections or potential disputes. We can act as an external partner to your company's legal department or take over the entire matter on a turnkey basis.

We will handle the licensing procedure for you, set up internal compliance guidelines, and train your team – in short, we will do everything to ensure your export runs smoothly and without risks. Moreover, if you are looking for new business opportunities or investors in this area, we can connect you with other partners from our business network. We are also happy to listen to your interesting business ideas and help you bring them to life.

Do not hesitate to contact our office – consultations@arws.cz. We will be happy to hear the details of your case and suggest the most appropriate next steps. With us, you will minimise risks and gain the certainty that your export will proceed in accordance with the law – allowing you to focus on your business.