On 8 September 2025, the EU Commission adopted a delegated regulation updating Annex I to Regulation (EU) 2021/821 (the Dual-Use Regulation). This update is intended to bring the list more closely into line with new technologies and international commitments (for example, the Wassenaar Arrangement, the MTCR, the Australia Group, and the NSG). It is expected to enter into force in November 2025, following the usual scrutiny procedure by the Council and Parliament.
Significance and recommended action for companies
Internal compliance programmes and export control processes need to be reviewed to ensure that the changes are correctly implemented. Individual areas have been newly added to the Dual-Use Regulation. Companies that manufacture or trade in goods in areas such as quantum technology, semiconductor manufacturing, high-temperature materials, or additive manufacturing should check whether their products now fall, for the first time, under an authorisation requirement. The technical specifications or parameters of a product have been captured in greater detail. This can now be decisive: even where a product was not covered under previous versions of the list, a new variant of it could now be caught.
Overview of the newly covered and amended areas:
| Technology / Area | Newly Regulated / More Strictly Controlled | Notes / Examples |
|---|---|---|
| Quantum technology | New control content | e.g. quantum computers, electronic components for cryogenic applications, parametric signal amplifiers, cryogenic cooling systems, cryogenic wafer probers |
| Semiconductors / manufacturing technology | Extension of control | e.g. Atomic Layer Deposition (ALD) equipment, epitaxial deposition equipment, lithography equipment, EUV pellicles, masks and reticles, etch equipment, manufacturing materials |
| Advanced circuits / electronics | New entries and adjustments | e.g. field-programmable logic devices/systems, electronic assemblies, specific definitions of chips, etc. |
| High-temperature coatings / materials | New rules | High-temperature coatings are now explicitly covered |
| Additive manufacturing / 3D printing | Additional controls | e.g. machines, materials, and special additives or alloying agents (inoculants) for powder processes |
| Peptide synthesis / biotechnology | Addition of new items | Peptide synthesisers are now newly covered |
Conclusion
Should you operate in one of the sectors mentioned above, you should review your internal compliance and export control screening process and make room for a goods list check from November onwards.
