To amend the export control list of dual-use commodities listed in Annex I of rule (EU) 2021/821, the European Commission enacted a delegated rule on September 8, 2025.
Context
· Based on globally accepted control standards, the EU dual-use items export control list mandates that the items on the list have an export permission mechanism.
· This list, which is Annex I of the EU Dual-Use Items Regulation, is usually updated by delegated acts at least once a year.
The rationale behind the update
· International non-proliferation regimes, including the Wassenaar Arrangement (WA), the Australia Group (AG), the Missile Technology Control Regime (MTCR), and the Nuclear Suppliers Group (NSG), modified their control lists in 2024.
· EU members unanimously approved the revised control commitments under the Wassenaar Arrangement on May 23, 2025.
· Annex I must be updated through a delegated regulation to guarantee the uniform and coordinated application of these additional control mechanisms throughout the EU.
Details of the Update
In particular, the following new dual-use products are added to the EU control list because of this update:
· Quantum technology controls (such as electronic parts made to function at cryogenic temperatures, quantum computers, parametric signal amplifiers, cryogenic cooling systems, and cryogenic wafer probes)
· Equipment and materials used in the production and testing of semiconductors (such as lithography equipment, Extreme Ultra-Violet pellicles, masks and reticules, equipment for Atomic Layer Deposition, equipment and materials for Epitaxial Deposition, Scanning Electron Microscope equipment, and etching equipment)
· Electronic assembly and integrated circuits for advanced computing, including Field Programmable Logic Devices and Systems
· High temperature coatings; peptide synthesisers; additive manufacturing equipment and associated supplies (such as powder inoculants)
· Some technical definitions and descriptions have been updated, and some control parameters have been modified.
Following the customary two-month review process for the Council and the European Parliament, the revised EU control list goes into effect.
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