Summary
The Export Control (Amendment) (No. 2) Order 2019 amends the Export Control Order 2008 to add PL9012, prohibiting the export or electronic transfer of submersible vessels, subsea systems, and related components/software/technology to Russia. It covers submersible vehicles, subsea ploughs, marine acoustic systems, navigation equipment, propulsion systems, umbilicals, tethers, underwater vision/communication systems, sensors, launch/recovery equipment, trenching tools, control systems, manipulators, cable handling equipment, syntactic foam, pressure housings, and azimuth propulsion systems (propeller >2m). The controls include exceptions referenced in Article 18.
Reason
This export control restricts British companies' ability to engage in lawful commercial activity with Russia, driving trade to competitors in non-allied nations who face no such restrictions. Export controls represent government intervention that distorts market allocation of goods and services. While national security concerns may be cited, the broad scope of this regulation—covering civilian-grade submersible technology, standard marine equipment, and dual-use components—imposes significant compliance costs on British exporters and may simply redirect Russian procurement to less efficient suppliers rather than achieve meaningful security objectives. The regulations governing exceptions (Article 18) suggest this could be better addressed through targeted licensing rather than blanket prohibition.