Permit Regulation of Dual-Use Goods
Dual-use goods — items usable for both civil and military purposes — are regulated through the catalogue of permit types in the licensing law. In this category the catalogue defines five types: the permit for the import of dual-use products; for export; for transit; for brokerage services on such products; and for technical assistance. The division is deliberately detailed: the state does not control abstract „trade“ but each movement and service separately — import, export, transit, brokering and technical assistance each require their own permit.
General Licenses for Military Production
Part of the same system are the general licenses for military production: manufacture, production, repair (including modernization and on-site service) and trade. These activities are carried out by a legal entity or individual entrepreneur holding the respective general license. The general licenses are issued by the Ministry of Defence of Georgia on the basis of a recommendation of the standing military-technical commission. The seeker must submit, together with the documentation determined by law: registry data; a list of the persons in direct contact with military production — name, surname, date of birth, profession, workplace and residence, with certificates of criminal record, absence from narcological registration and mental condition; a list of buildings with addresses; a fire-safety compliance document issued by the respective divisions of the Emergency Management Service; a technical-safety compliance document; a protection and security document; and the commission’s recommendation.
Brokerage Services
The license for brokerage services on military products is likewise issued by the Ministry of Defence. The seeker and holder of this license may be a resident as defined by the Tax Code, and the seeker must submit the commission’s recommendation together with the statutory documentation. The brokerage regime exists for the situation where a person is neither carrier nor manufacturer but participates in arranging the transaction — the state controls that role too.
What These Norms Do Not Contain
These norms do not contain the list of which specific goods count as dual-use products — that list is established by separate legislation and control lists, and it changes. Nor are application deadlines or procedural details here — they are resolved by the general norms of the licensing law. Therefore, when planning a specific transaction, the classification of the goods must first be verified, and then the requirements of the respective permit type.
Practical Recommendations
First, establish your role in the transaction — importer, exporter, transit carrier, broker or provider of technical assistance — since each role is served by its own permit type. Second, verify the goods’ classification in the current control lists. Third, for military-production general licenses prepare early — the commission’s recommendation and the buildings’ safety documents are pre-requisites. Fourth, for brokering remember the residency requirement. Fifth, a transaction without a permit creates not only administrative but international sanctions risks — use a qualified legal assessment.
The detail of the documentation is deliberate: for general licenses on military production the state vets not only the person but also the environment — the fire-safety, technical-safety, protection and security documents of the buildings attest precisely to that. The list of persons, with certificates of criminal record, absence from narcological registration and mental condition, ensures that direct contact with the production is held only by vetted persons. The commission’s recommendation is the central knot of the system — since it performs the technical assessment, obtaining it is often the most time-consuming part of the process and requires planning in advance.
The division into five types has one more practical consequence: a permit is issued for a specific type of action, not for a person in general. If your business model combines several actions on the same products — for instance import followed by re-export, or transit together with brokerage — each direction requires its own permit. Therefore, when designing business processes, first draw up the list of actions and then attach the respective type to each: that is cheaper than suspending a transaction over a defect.
One more note on the process: the difference between the general licenses and the brokerage license is fundamental. The general license covers an industrial function — manufacture, production, repair and trade; brokerage covers an intermediary role — arranging transactions between persons who themselves perform those functions. Both roles are legitimate, but under different licenses, and obtaining one gives no means to exercise the other.
The manufacture, production, repair — including modernization and on-site service — of military products and trade in them proceed on the basis of a corresponding general license. General licenses are issued by the Ministry of Defence of Georgia on the recommendation of the standing commission on military-technical questions; the seeker must submit, together with the documentation defined by the same law, registry data and a list of persons — with name, surname, date of birth, profession, workplace, identity-card number, residence and data on criminal record or deprivation of rights. The license for brokering services in military products is likewise issued by the Ministry of Defence — the whole licensing contour of this market is thus concentrated on one agency and one expert commission.
Frequently Asked Questions
Below we answer frequently asked questions on this topic.
Who issues the general license for military products?
The Ministry of Defence of Georgia — on the recommendation of the standing military-technical commission.
What must the seeker submit?
Registry data and a list of persons with birth, profession, workplace, identity and criminal-record data.
Who issues the brokering license?
Also the Ministry of Defence.
How We Help on Legal.ge
The export of dual-use and military products is subject to strict licensing control. The lawyers of Legal.ge will assess the licensing needs of your operation and prepare the licensing file. Write to us on Legal.ge.