On 25 September 2025, “Royal Decree-Law 10/2025 of 23 September came into force, adopting urgent measures against genocide in Gaza and in support of the Palestinian population”. Among other extraordinary measures, Spain has banned the exchange of defence and dual-use materials with Israel.
In customs matters, the aforementioned Royal Decree-Law prohibits, on the one hand, the import, export and transfer of anything considered to be defence material and dual-use technology as provided for in the relevant regulations (Law 53/2007, of 28 December, and Royal Decree 679/2014, of 1 August, both derived from Regulation (EC) No 428/2009, as last amended by Regulation (EU) 2021/821 of the European Parliament and of the Council of 20 May 2021 establishing a Union regime for the control of exports, brokering, technical assistance, transit and transfer of dual-use items) and, on the other hand, imports into Spain of products originating in Israeli settlements in the Occupied Palestinian Territory (West Bank, East Jerusalem and the Gaza Strip).
On this point, it is important to remember that, in accordance with the aforementioned regulations, goods designed for military purposes will be considered defence material, while dual-use technology refers to technological products that can be used for both civilian and military or nuclear purposes.
As for authorisations and other licences in this area, granted prior to the publication of this Royal Decree-Law, or those pending on the date of its entry into force, they will be revoked or denied, respectively, when the origin and/or destination is Israel.
How can we assist you?
We recommend that operators whose economic activity is the international trade of defence material and/or dual-use technology to carry out a detailed analysis of the supply chain of the products concerned, as well as their origins and destinations, in order to avoid possible contingencies at Spanish customs.
Salinas & Partners, with more than 30 years of experience in international trade and indirect taxation, is at your disposal for any questions or comments that may arise.
