When Your Export Requires Government Permission
Not all exports from New Zealand are freely allowed. Certain goods—particularly those with potential military applications or dual-use capabilities—require an export permit from the Ministry of Foreign Affairs and Trade (MFAT) before they can leave the country.
What are strategic goods? Items that could be used for both civilian and military purposes, or goods that pose security risks if they fall into the wrong hands. Examples include:
- Encryption software
- Military-grade equipment
- Certain chemicals and biological materials
- Advanced manufacturing technology
- Navigation and surveillance systems
The law: New Zealand’s Export Control Act 2018 makes it illegal to export strategic goods without the required permit. Violations can result in fines up to $500,000 or imprisonment.
Our service: We help you determine if your products require an export permit and manage the entire MFAT application process on your behalf.
The Strategic Goods List (SGL)
New Zealand maintains a Strategic Goods List (SGL) that classifies thousands of products into categories subject to export controls. The SGL is based on international export control regimes that New Zealand participates in.
Legal Consequences of Non-Compliance:
- Criminal penalties: Fines up to $500,000 or imprisonment for up to 12 months for individuals
- Corporate liability: Companies can be fined up to $1 million for exporting controlled goods without permits
- Shipment seizure: Goods intercepted at border by customs without valid permits
- Export ban: Future export privileges can be suspended or revoked
- Reputational damage: Being flagged as a non-compliant exporter affects international business relationships
SGL Categories: What’s Controlled?
The Strategic Goods List is organized into categories based on the type of item and its potential applications.
Dual-Use Goods & Technology
Civilian items with military potential
- Electronics: High-performance computers, specialized microprocessors
- Software: Encryption software, cybersecurity tools, intrusion software
- Telecommunications: Secure communications equipment, jamming devices
- Sensors: Night vision, thermal imaging, radar systems
- Navigation: GPS equipment with military-grade accuracy
Military Equipment
Items designed for military use
- Weapons & Ammunition: Firearms, explosives, weapon parts
- Protective Equipment: Body armor, ballistic helmets, military-grade gear
- Military Vehicles: Armored vehicles, military aircraft parts
- Surveillance: Military drones, reconnaissance equipment
- Training Equipment: Military simulators, combat training systems
Chemicals & Biological Materials
Hazardous or weaponizable substances
- Precursor Chemicals: Substances used in weapons manufacturing
- Toxins: Biological agents with potential misuse
- Nuclear Materials: Radioactive substances and equipment
- Explosives: High-energy materials and propellants
- Composite Materials: Advanced materials with defense applications
Manufacturing Technology
Advanced production equipment
- 3D Printing: Additive manufacturing systems for metal parts
- CNC Machines: High-precision machining equipment
- Robotics: Automated systems for sensitive manufacturing
- Testing Equipment: Specialised inspection and quality control tools
- Software: CAD/CAM systems for weapon design
Types of Export Permits
MFAT issues different types of permits depending on the goods, destination, and end-use.
Individual Permit
For a single shipment of controlled goods to one specific end-user.
Use case: One-off sale of encryption software to a foreign company | Validity: Single use
Open General License (OGL)
Pre-approved license for low-risk destinations and products. No individual application needed.
Use case: Standard encryption exports to Australia, UK, USA | Validity: Ongoing
Global License
For companies with frequent exports of specific controlled goods to multiple destinations.
Use case: Tech company exporting encryption software globally | Validity: Up to 2 years
Our Permit Application Service
We handle the entire MFAT permit process—from product classification to final approval.
4-Step Permit Process
Product Classification
We review your product’s technical specifications and determine if it’s listed on the Strategic Goods List (SGL).
End-User Verification
We gather end-user statements and verify the legitimacy of the buyer and intended use.
MFAT Application
We prepare and submit the detailed permit application to MFAT’s Export Controls team with all supporting documentation.
Approval & Delivery
Once MFAT approves, you receive the permit and can legally export. We track the application throughout.
End-User Declarations & Compliance
One of the key requirements for strategic goods permits is proving that the end-user is legitimate and the goods won’t be diverted for unauthorized purposes.
What We Need for End-User Verification:
- End-User Statement: Signed declaration from the buyer stating the intended use of the goods
- Company Registration: Proof that the end-user is a legitimate registered business
- Non-Diversion Undertaking: Commitment that goods won’t be re-exported or used for prohibited purposes
- Destination Screening: We verify the destination country isn’t subject to NZ sanctions
International Export Control Regimes
New Zealand’s Strategic Goods List is aligned with international export control regimes that we participate in.
Key International Agreements:
🌐 Wassenaar Arrangement
Controls on dual-use goods and technologies, and conventional arms. Covers most high-tech exports including encryption and advanced electronics.
☢️ Nuclear Suppliers Group (NSG)
Controls nuclear materials and technology to prevent proliferation of nuclear weapons.
🧪 Australia Group
Controls exports of chemical and biological materials that could be weaponized.
🚀 Missile Technology Control Regime (MTCR)
Restricts transfers of missile and unmanned aerial vehicle technology.
Pricing
Individual Permit Application
$350
per application
For a single export shipment. Includes SGL classification, end-user verification, and MFAT application preparation.
- Strategic Goods List assessment
- End-user documentation gathering
- MFAT application submission
- Timeline: 3-6 weeks (MFAT processing)
Global License Application
MULTI-USEFrom $950
per license
For companies with ongoing exports of controlled goods. Covers multiple shipments and destinations for up to 2 years.
- Comprehensive SGL classification for all products
- Internal Compliance Programme setup
- MFAT liaison and application management
- Timeline: 2-4 months (comprehensive review)
Note: MFAT may charge government processing fees (typically $50-$200) on top of our service fee.
Frequently Asked Questions
How do I know if my product is on the Strategic Goods List?
The SGL is highly technical and organized by categories. Send us your product’s technical specifications (data sheets, software descriptions) and we’ll conduct a classification assessment. MFAT also offers free pre-application guidance.
What if I’m unsure whether I need a permit?
When in doubt, consult first. It’s better to apply for a permit you don’t strictly need than to risk penalties for exporting without one. We offer pre-export compliance reviews to assess your risk level.
How long does MFAT take to approve a permit?
Individual permits typically take 3-6 weeks depending on complexity and destination. High-risk destinations or sensitive technology may take longer. Global licenses can take 2-4 months. Plan ahead—don’t ship before the permit is approved.
Can MFAT reject my permit application?
Yes. MFAT can refuse permits if the end-user is questionable, the destination is sanctioned, or the goods pose a proliferation risk. We help you prepare strong applications with proper documentation to maximise approval chances.
Do I need a permit to export encryption software?
Most strong encryption (256-bit and above) is controlled under the SGL. However, Open General Licenses may cover exports to low-risk countries like Australia, UK, USA, and EU. We’ll determine if you qualify for an OGL or need an individual permit.
Ready for Export Permit Support?
Export Controlled Goods Legally. Stay Compliant.
Don’t risk penalties. Let us handle your MFAT permit applications and ensure full compliance with New Zealand export control laws.
Get Permit Support
Or call us at 021 025 15316