EU: 2025 Update of the EU Control List of Dual-Use Items

 

On 8 September 2025, the European Commission adopted a Delegated Regulation updating the EU dual-use export control list contained in Annex I of Regulation (EU) 2021/821.

This update aligns the EU list with decisions adopted in 2024 within the framework of the multilateral export control regimes, namely the Wassenaar Arrangement (WA), the Missile Technology Control Regime (MTCR), the Australia Group (AG) and the Nuclear Suppliers Group (NSG). It also incorporates additional control commitments that EU Member States, as participants in the Wassenaar Arrangement, have agreed to apply uniformly.

The revision strengthens the effectiveness of EU-level controls on emerging technologies, thereby enhancing security in the trade of dual-use items in line with the objectives set out in the 2024 White Paper on Export Controls. Uniform EU-wide controls ensure consistency, transparency, and effectiveness while safeguarding the Union’s competitiveness and preserving a level playing field for economic operators.

In particular, this update of the EU control list introduces new dual-use items, including:

• Controls relating to quantum technologies (e.g. quantum computers, electronic components designed to operate at cryogenic temperatures, parametric signal amplifiers, cryogenic cooling systems, cryogenic wafer probers);
• Semiconductor manufacturing and testing equipment and materials (e.g. Atomic Layer Deposition equipment, equipment and materials for epitaxial deposition, lithography equipment, Extreme Ultra-Violet pellicles, masks and reticles, Scanning Electron Microscope equipment, etching equipment);
• Advanced computing integrated circuits and electronic assemblies such as Field Programmable Logic Devices and Systems;
• Coatings for high-temperature applications;
• Additive manufacturing machines and related materials (e.g. inoculants for powders);
• Peptide synthesisers; and
• Amendments to certain control parameters as well as updates to several technical definitions and descriptions.

The updated EU control list will enter into force following the standard two-month scrutiny period by the Council and the European Parliament.

 

Background and context

Export controls on dual-use items within the European Union are founded on a single, harmonised control list that must be implemented by all Member States. This list—set out in Annex I to the EU Dual-Use Regulation—is typically updated at least once per year by means of a Delegated Act. Each revision reflects the decisions and commitments made under the international non-proliferation regimes and export control arrangements.

In accordance with Regulation (EU) 2021/821 of the European Parliament and of the Council (the “Dual-Use Regulation”), dual-use items—meaning goods, software and technology that can be used for both civilian and military applications, or that may contribute to the proliferation of weapons of mass destruction—are subject to authorisation and export control. These obligations apply whenever such items are exported from or transit through the European Union, or are supplied to a third country through brokering services or technical assistance.

Annex I to the Dual-Use Regulation lays down the common list of dual-use items subject to control within the Union (the “EU control list”). The scope of this list is determined within the framework of the international non-proliferation regimes and export control arrangements, namely the Australia Group, the Missile Technology Control Regime, the Nuclear Suppliers Group, the Wassenaar Arrangement and the Chemical Weapons Convention.

Regular updating of Annex I is necessary to ensure continued alignment with international security obligations, to maintain transparency, to safeguard the Union’s competitiveness, and to provide a clear and practical reference point for both export control authorities and economic operators. Timely amendments to the EU control list are therefore essential to reflect evolving international commitments.

To this end, Article 17(1) of the Dual-Use Regulation confers on the Commission the power to adopt delegated acts “to amend the list of dual-use items set out in Annexes I and IV… in conformity with the relevant obligations and commitments, and any modifications thereof, that Member States and, where applicable, the Union have accepted as members of the international non-proliferation regimes and export control arrangements, or by ratification of relevant international treaties.”

The current version of the EU control list was last amended by Commission Delegated Regulation (EU) 2024/2547, which incorporated the control list updates adopted in 2023 by the Nuclear Suppliers Group, the Australia Group, the Missile Technology Control Regime and the Wassenaar Arrangement. In 2024, these international regimes adopted a limited number of additional modifications, as decision-making and consensus-building were hindered by the conduct of Russia in the context of its war of aggression against Ukraine. Furthermore, on 23 May 2025, Member States informed the Commission that they had all accepted, in their capacity as participants in the Wassenaar Arrangement, further commitments to uniformly control additional items. Consequently, Annex I to Regulation (EU) 2021/821 must be updated accordingly through the adoption of a Delegated Act.

The Commission’s White Paper on Export Controls of 24 January 2024 had already anticipated the need to introduce these controls into Annex I in order to ensure simultaneous, uniform, and publicly accessible controls across all 27 Member States.

This delegated act therefore introduces amendments to the EU control list relating to control parameters, technical definitions and descriptions, and the inclusion and removal of certain dual-use items.