Update of EU dual-use products and technologies list

The EU’s export control list of dual-use products—items, software and technology that can be used for both civil and military purposes—is based on a common list of dual-use products that must be controlled in all Member States. This list—Annex I of the EU's dual-use Regulation—is typically amended at least once a year via a delegated act.

The European Commission (EC) has recently updated Annex I, incorporating changes agreed at an international level in the framework of the main export control regimes, such as the Wassenaar Agreement, Australia Group, Missile Technology Control Regime and Nuclear Supplier Group. These changes reflect technological progress and new concerns on global security.

The new list will apply to all EU Member States and will enter into force after the usual two-month scrutiny period for the Council and the European Parliament.

Companies and operators that export dual-use products must carefully review the updated list to ensure they meet the new legal obligations and avoid sanctions.

Main technical developments

The EC has published a summary of the main changes introduced in Annex I of Regulation (EU) 2021/821, including:

• Quantum technology: quantum computers, circuits and electronic components designed to work at cryogenic temperatures; parametric signal amplifiers, cryogenic cooling systems, and cryogenic wafer probers.
• Semiconductors: manufacturing and testing equipment and related materials (atomic layer deposition, epitaxial deposition, lithography, extreme ultra-violet mask pellicles, scanning electron microscope equipment, and etching equipment).
• Advanced circuits and electronic assemblies: new high performance computer integrated controls, field programmable logic devices and systems that incorporate them.
• Coatings for high temperature applications and high entropy alloy materials.
• Additive manufacturing: 3D metal printers and specific inoculants/powders.
• Peptide synthesis: including single-use and large-scale peptide synthesizers.
• Review of technical parameters and definitions e.g., changes included replacing "satellite" with "spacecraft", updating definitions of "laser", and reworking the text to account for Permanent Magnetic Alternating Current (PMAC) motors.

Recommendations for companies

In this context, companies must adopt a proactive approach to guarantee regulatory compliance, minimizing legal and operational risks.

Therefore, they should proactively reclassify products and technologies, and carefully review new entries included on the list, e.g., categories 3A501, 3B501 and 4A506. Internal compliance programs (ICP) involving export controls must also be adapted to ensure that internal procedures reflect the new regulatory requirements.

Another essential aspect for correct implementation is training relevant departments and areas—e.g., engineering, sales and logistics—on the key changes introduced in the regulation. Likewise, companies are recommended to evaluate possible synergies with export controls from the USA and the UK, to minimize trade friction and facilitate global compliance.

In conclusion, this update strengthens the EU’s export control policy consistency with international standards and significantly expands the regulated scope in cutting-edge sectors. A preventive approach—accurate classification, adjustments to the ICP and early dialog with competent authorities—is essential for operators to maintain business agility and avoid sanctions or delays in their supply chains.

For more information, please contact our Knowledge and Innovation Area specialists.