DENMARK Law and Practice Contributed by: Thomas Maaberg Hansen and Peter Sand, Gorrissen Federspiel
Danish Executive Order No 365 of 23 February 2026 on export control of Dual-Use Items and Technology (the “Danish Dual-Use Executive Order”). Together, these provide the national framework for the admin - istration and enforcement of the EU Dual-Use Regula - tion in Denmark. The relevant authority for authorisa - tions related to dual-use items, among other things, is the Danish Business Authority. 3.2 Scope of Controls: Military and Dual-Use Lists Defence Goods and Military Equipment The export of defence goods and military equipment from Denmark requires prior authorisation under Sec - tion 6 (1) of the Danish Weapons Act. The provision covers all items included on the Common Military List of the European Union, as amended from time to time – as well as, for example, ammunition, military simula - tion and training equipment, and explosives. Dual-Use Items The EU Dual-Use Regulation establishes an EU-wide framework for the control of the export, transfer, bro - kering and transit of dual-use items. Since February 2026, Denmark no longer maintains a separate nation - al control list for dual-use items that applies in addition The Danish Weapons Act generally prohibits the export, transfer, brokering and transit of controlled defence goods without authorisation. The applicable authorisation may take the form of a general, global or individual licence or an exemption or dispensation from the relevant prohibitions under the Danish Weap - ons Act. The main categories of licences available are set out in Sections 35‒37 of the Danish Weapons to the EU Dual-Use Regulation. 3.3 Licence Requirements Defence Goods and Military Equipment The categories of licences available are set out in Section 6 of the Danish Dual-Use Executive Order, as follows. • General national licence – this authorises the export of specified dual-use items to the Ukrain - Executive Order. Dual-Use Items
ian military, Greenland, and entities within the EU customs territory. • General EU licence – this authorises the export of specified dual-use items to countries outside the EU, as set out in Annex II to the EU Dual-Use Regulation. • Global licence – this authorises multiple exports of certain categories of dual-use items for civilian use. • Individual licence – this authorises a single export that is not covered by a general or global export licence. Applications for export licences are submitted to the Danish National Police using the prescribed digital application form. The information and supporting documentation required depend on the type of licence applied for and may include information on the goods or equipment, the recipient, the end user, and any transit countries, as well as an end-user undertaking and certain declarations. Processing times vary from case to case, depending on the foreign and security policy considerations relevant to the proposed export. Dual-Use Items Applications for export licences are submitted to the Danish Business Authority using the prescribed digi - tal application form. The information and supporting documentation required will depend on the type of export licence applied for and may include informa - tion on the dual-use items, the value of the export, the recipient, the end user, and any transit countries, as well as an end-user statement and a management statement. Processing times vary from case to case, depending on the foreign and security policy consid - erations relevant to the proposed export. 3.5 Criteria for Granting or Refusing Licences Defence Goods and Military Equipment Export licence applications are assessed on a case- by-case basis against the eight criteria set out in Coun - cil Common Position 2008/944/CFSP, as amended, which includes: • considerations relating to international obligations and commitments; 3.4 Licence Application Process Defence Goods and Military Equipment
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