EU Updates Dual Use Control List

The European Commission adopted Delegated Regulation C(2025)5947 on 8 August 2025, introducing critical updates to the EU control list of dual-use items under Regulation (EU) 2021/821. These updates align the EU’s controls with international standards, ensuring better oversight of sensitive exports that could be misused for military purposes or human rights abuses.

What Are Dual-Use Items?

Dual-use items are goods, software, and technologies that can serve both civilian and military purposes. These include:

• Nuclear materials and related equipment
• Semiconductors and advanced electronics
• Aerospace and satellite navigation systems
• Cyber surveillance and intrusion tools
• Telecommunications and encryption technologies

Export of such items from the EU is regulated to prevent their diversion to proliferation-sensitive end users, such as rogue states, terrorist groups, or human rights violators.

Key Details of the Regulation

Regulation Amended: Regulation (EU) 2021/821 (Dual-Use Regulation)
Document Reference: C(2025)5947
Adoption Date: 8 August 2025
Status: Awaiting publication in the Official Journal
Regulatory Body: Directorate-General for Trade (DG TRADE)
Legal Instrument: Delegated Regulation (binding update)

Main Changes in Delegated Regulation C(2025)5947

🔄 Updated Control List

Annexes of Regulation (EU) 2021/821 have been revised to incorporate the most recent changes from four major multilateral export control regimes:

• Wassenaar Arrangement (conventional arms and dual-use goods)
• Nuclear Suppliers Group (NSG)
• Australia Group (chemical and biological controls)
• Missile Technology Control Regime (MTCR)

🔧 Technical Adjustments

• Reclassification of several technologies due to technical advancements
• Clarification of licensing thresholds, scope, and item specifications
• Harmonisation with international nomenclature and standards

These changes ensure consistency with global export controls and help EU exporters stay compliant across jurisdictions.

Impact on Exporters

All EU-based exporters involved in sensitive sectors—such as electronics, aerospace, quantum computing, or cybersecurity—must:

• Review the revised control list once published.
• Update internal compliance programs to align with the new technical criteria.
• Conduct internal audits to reassess product classifications.
• Train staff on the updated licensing obligations and procedures.

Exporters may also need to engage with national export control authorities to ensure accurate classification and obtain necessary licenses.

Why It Matters

🔐 Security: Enhances control over exports that could aid in military proliferation or authoritarian surveillance.
📘 Trade Compliance: Ensures the EU meets international commitments and supports global non-proliferation efforts.
✅ Legal Clarity: Reduces ambiguity in export licensing by refining item descriptions and thresholds.

Next Steps

• The regulation will enter into force after publication in the Official Journal of the EU.
• National export authorities will issue detailed implementation guidance.
• Exporters should immediately begin preparations to ensure uninterrupted compliance once the regulation becomes law.

Reference: Register of Commission Documents – C(2025)5947