Updates to the EU Dual-Use Export Control List
September 18, 2025
Updates to the EU Dual-Use Export Control ListSeptember 18, 2025 Key changes to export controls affecting emerging technologies and cross-border trade. On 8 September 2025 the European Commission announced updates to the EU Dual-Use List (as set out in Annex I of Regulation 2021/821). While some of these updates reflect international decisions taken in 2024 by multilateral export control regimes (including the Wassenaar Arrangement (WA), Missile Technology Control Regime (MTCR), Australia Group (AG) and Nuclear Suppliers Group (NSG)) and are part of the European Commission’s annual review process, others – such as those in relation to semiconductor equipment – are unilateral and impose brand new controls on emerging technologies. Key ChangesThe 2025 amendments include a number of new entries to the EU Dual-Use List, including:
Some technical amendments providing updates to definitions and control parameters were also made to improve clarity and consistency such as updating the carbon content of maraging steels specified from “very low” to “less than or equal to 0.03% by weight”. This includes editorial changes to technical notes and refined terminology. Implementation TimelineThe new controls will enter into force following the usual two-month scrutiny period for the European Council and European Parliament, allowing stakeholders to assess the impact and prepare for compliance. Impact on BusinessExporters across the EU should review the updated list to determine whether their products now fall under the revised controls. This is particularly relevant for companies operating in quantum computing, semiconductor manufacturing and biotechnology fields. It is important to emphasize that some of the new control entries represent unilateral controls by the EU on items, including certain semiconductor manufacturing equipment, which are not currently subject to UK export controls. This misalignment may reflect a broader shift away from streamlining controls across jurisdictions to unilateral and protectionist measures impacting emerging technologies. For businesses trading globally and impacted by these new entries, it will be important to identify the differences between the relevant control lists and to obtain appropriate licences to continue cross-border trade. Latest Insights
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