EU dual-use catch-all: how do you document the 'knowledge' standard in practice?

James O'Connor ieGlobal Trade Lead · Shannon MedTechAsked 22 Jul 2026

Article 4 catch-all controls apply when you are 'aware' the items may be intended for WMD or military end-use. Our auditors want to see how we evidence the absence of such awareness for routine orders. Do you keep a written end-use assessment for every export, or only for flagged lanes? What does your paper trail look like?

4 replies

Hans Müllerde3d agoExpertITI member

Documenting a negative ('we were not aware') is the wrong frame, document the process instead. Ours: (1) every order passes a red-flag checklist embedded in order entry; (2) flagged lanes get a written end-use assessment with a named reviewer; (3) unflagged orders inherit the lane-level assessment, refreshed annually. Auditors have accepted this twice. A per-export memo for every routine shipment is neither required nor sustainable.

James O'Connorie3d agoAuthorITI member

This is the frame I was missing: document the process, not the negative. Would you share what the lane-level assessment template covers?

David Chensg3d ago

Same structure here. One addition: keep the red-flag checklist versioned. When a rule changes you can show exactly what your team was screening against on any past date.

James O'Connorie3d agoAuthorITI member

This is exactly what I needed, the lane-level inheritance idea solves the volume problem. Taking this to our auditors next month, will report back.