New Zealand opens consultations on export control reform – responses by 16 Jan 2026

28 November 2025

New Zealand has opened a consultation on proposals to strengthen its export control regime. Feedback can be submitted until 17.00 (NZ time) 16 January 2026. The Ministry of Foreign Affairs and Trade (MFAT) will be holding consultation events throughout December 2025 to inform interested parties of proposed reforms. The deadline to register for a consultation event is 5 December 2025.

Under New Zealand’s current export control framework, MFAT may approve export licences for military and dual-use goods, and goods subject to ‘catch-all’ provisions under the Customs and Excise Act 2018. The list of controlled items is set out in the New Zealand Strategic Goods List. Our New Zealand pages have been recently updated with the help of Bell Gully to provide more information on sanctions and export controls in New Zealand.

The New Zealand government intends to reform parts of its export control regime because it is considered unable to address proliferation challenges – challenges by state and non-state actors that attempt to develop, acquire, manufacture, possess, transport or transfer military or dual-use goods and technology. New Zealand is therefore proposing to introduce controls on:

• Transfers of technology within New Zealand (‘deemed exports’), including the placing (publishing) of that technology in the public domain within New Zealand;

• Intangible Technology Transfers (ITT) (such as teaching, on-the-job training, joint research, services) carried out by someone in New Zealand to an overseas recipient(s);

• ITT carried out by New Zealanders and permanent residents when overseas (for example, to control disclosure of sensitive technical ‘know-how’ while travelling offshore); and

• The subsequent ‘re-export’ or ‘re-transfer’ of certain goods and technology previously supplied under an export control permit, from New Zealand.

MFAT is also seeking views on:

• Extending exemptions for primary systems through-life support from catch-all primary systems to also include NZSGL primary systems, and to include upgrades;

• Introducing a range of warnings and penalties for ‘lower-level’, less serious offences; and

• A provisional decision-making process, to address the absence of a formal appeal mechanism.

A complete overview of the proposed changes, which would require legislation, is set out in MFAT’s consultation document.