Key legal question
Whether exporting non-listed goods without notifying SECO under Art. 4 GKV constitutes export without the required permit under Art. 14(1)(a) GKG.
Extracted holding
No. Art. 14(1)(a) GKG refers to a real permit requirement; the GKV reporting duty and SECO assent under Art. 4 GKV are not a licence within the meaning of that provision.
Extracted reasoning
The law distinguishes permits from reporting duties. Goods not covered by Art. 3 GKV are not permit-bound, and missing a catch-all notification only breaches Art. 4 GKV. SECO assent after notification is not a permit, and failure to notify does not transform the conduct into unlicensed export.