Germany Eases Defense Exports To Ukraine and Gulf Allies

Ongoing conflicts in Ukraine and in West Asia have sharply increased demand for air and maritime defense systems. Governments are facing the challenge of enabling fast delivery of critical military equipment while maintaining effective export control safeguards. Against this backdrop, the German government introduced a new, time-limited mechanism to accelerate defense exports.

In a press release, marking the publication of the new General Export Authorization 48 (GEA 48), the Federal Minister for Economic Affairs Katherina Reiche stated:

“Iran's indiscriminate attacks on the Gulf states have created an urgent need for military equipment there, particularly for air defense. At the same time, Ukraine's need for military support, especially for air defense, remains as urgent as ever. With the new, temporary GEA 48, we are adapting our arms export control procedures for the export of urgently needed military equipment to these countries to meet the new requirements. In doing so, we are ensuring swift and unbureaucratic exports to strengthen their defense systems and are thus sending a signal of solidarity.”

GEA 48 has been in force since March 20, 2026, and is valid for six months until 15 September 2026.

What is a General Export Authorization (GEA)?

General Export Authorizations are a type of export license that have the same legal effect as individual licenses but do not require a prior application to the Federal Office for Economic Affairs and Export Control (BAFA). Instead, they are issued by BAFA, publicly announced and henceforth apply to all exports and transfers that meet the conditions specified in the respective GEA.

As a result, exporters can carry out transactions covered by a GEA immediately, ensuring both speed and planning certainty for the duration of the authorization.

Scope of the GEA 48

GEA 48 defines its scope of application with reference to the types of goods it covers, their intended use, and the authorized recipients and destinations.

Authorized Goods

GEA 48 applies to the export and transfer with subsequent export of goods listed in Part I Section A of the Export List, provided that such goods are supplied by a domestic exporter and are intended for use in air and maritime defense. 

Further, the authorization only applies where the goods are supplied to recipients who (i) belong to the armed forces of an authorized destination country or (ii) act as a contracting authority in the defense sector and make the purchase exclusively for use by those armed forces. In individual cases, deliveries to other recipients may also be carried out under GEA 48.

Certain categories of sensitive military goods and technologies are excluded from the scope of GEA 48. This also includes goods classified as war weapons, unless the exporter or shipper has obtained a license under the War Weapons Control Act for the specific export or transfer.

Permitted Destinations

GEA 48 applies to exports to Bahrain, Qatar, Kuwait, Oman, Saudi Arabia, the United Arab Emirates, and Ukraine, as well as to transfers within the European Union, provided that the transferor is aware that the goods will subsequently be exported to one of the aforementioned destinations for defense purposes covered by GEA 48.

Key Compliance Requirements

GEA 48 is subject to a number of detailed ancillary provisions set out by BAFA. These include, in particular, the following obligations: 

• Registration: Exporters intending to rely on GEA 48 must register as users with BAFA via the ELAN-K2 portal prior to the first export or transfer, or within 30 days thereafter.
• Reporting Obligations: Exports and transfers carried out under the authorization must be reported to BAFA on a monthly basis via the ELAN-K2 portal. 
• Record-Keeping requirements: Exporters and transferors must retain all documentation relating to the use of the GEA 48 for at least three years following the end of the calendar year in which the export or transfer took place. 

Key Grounds for Exclusion 

GEA 48 sets forth a number of grounds for exclusion, under which the authorization cannot be relied upon. These include, among others, exports followed by re-export to unauthorized destinations, cases where the goods are intended to support Russia’s war of aggression, as well as circumstances where BAFA requires individual licensing.

Practical Implications and Navigating Requirements with HEUKING

GEA 48 provides significant procedural relief by enabling faster exports in situations where defense equipment is urgently required. In particular, it facilitates deliveries to Ukraine and selected Gulf states without the delays associated with individual licensing procedures, thereby offering greater flexibility and planning certainty for exporters operating in this space.

At the same time, the strict licensing conditions and detailed compliance requirements applicable to the GEA 48 should not be underestimated. Companies should assess, at an early stage, whether their goods actually fall within the scope of GEA 48 and ensure that its requirements are properly implemented. In the event of a violation, the GEA 48 may be revoked, and regulatory and criminal penalties may apply. To prevent this, thorough assessment and robust internal compliance processes are essential.

We regularly advise clients on the application of export control laws and on the implementation of internal processes to ensure compliance with German and European export control requirements. In addition, we assist you with registration and reporting obligations and provide support in situations where compliance issues have arisen. Furthermore, we advise on transaction-specific risks associated with the export of goods, enabling you to make optimal use of the GEAs published by BAFA within the framework of your export process.