EU, Export Control, Update of the Dual-Use Control List
With Commission Delegated Regulation No. 2025/2003 of 8 September 2025, published in the Official Journal of the European Union on 14 November 2025, the list of dual-use items and technologies (EU Dual-Use Control List) falling within the scope of the Union regime for the control of exports, brokering, technical assistance, transit, and transfer of dual-use items, established by Regulation (EU) No. 2021/821 of the European Parliament and of the Council of 20 May 2021 (the so-called Dual-Use Regulation), was updated annually.
The European Commission has updated the list of dual-use goods as delegated by Article 11 of Regulation (EU) No. 2021/821 of the European Parliament and of the Council of 20 May 2021. 17 of the Dual-Use Regulation, to align it with the decisions taken in 2024 under the main multilateral control regimes (Wassenaar Arrangement; Missile Technology Control Regime, MTCR; Australia Group; Nuclear Supplier Group, NSG). In particular, the new Delegated Regulation – in force from 15 November 2025, the day after its publication – provides for the complete replacement of the text of Annex I of the Dual-Use Regulation and incorporates, in particular, the new provisions contained in the following documents:
MTCR, Equipment, Software, and Technology Annex, dated March 14, 2024;
NSG – Guidelines for Transfer of Nuclear-Related Dual-Use Equipment, Materials, Software, and Related Technology, published in July 2024;
WA – List of Dual-Use Goods and Technologies and Munitions List, dated December 5, 2024.
The objectives of regularly updating the common list of dual-use items—subject to control in the Union when exported from the European Union, when in transit, or when supplied to a third country through brokering services or technical assistance provided by operators resident or established in the EU—can be summarized as strengthening security in the trade of sensitive technologies, ensuring effective and transparent controls, and facilitating consultation and verification by both competent authorities and businesses, while maintaining competitiveness and a level playing field for economic operators.
The update covers all categories of Annex I – except Category 0 (Nuclear materials, facilities, and equipment) – and introduces controls on certain emerging technologies, through the integration of products from the following sectors:
quantum technology (e.g., quantum computers, parametric signal amplifiers, electronic components designed to operate at cryogenic temperatures, cryogenic cooling systems, cryogenic wafer probes);
semiconductors, equipment, and materials for the production and testing of semiconductors (e.g., atomic layer deposition equipment, epitaxial deposition equipment and materials, lithography equipment, films, masks, and gratings for extreme ultraviolet radiation, scanning electron microscope equipment, etching equipment);
Advanced computer integrated circuits and advanced electronic assemblies, such as field-programmable logic devices (FIS) and systems;
Furthermore, the Regulation expands the list with products such as:
Coatings for high-temperature applications;
Additive manufacturing machines and related materials (e.g., powder inoculants);
Tools or devices used for the automated and controlled production of chemical compounds (e.g., peptide synthesizers).
Finally, the Delegated Regulation introduces changes to the control parameters, regarding technical specifications, quantitative thresholds, minimum performance (e.g., speed, accuracy, operating temperature), structural characteristics (such as materials, dimensions, and configurations), functional capabilities (computing, sensing, and transmission), sensitivity thresholds (frequencies, power, resolutions), as well as certain definitions and technical descriptions.
As usual, the Commission has published a summary of the main amendments made (Summary of 2025 amendments to Annex I to Regulation (EU) 2021/821), available on the EU CIRCAB (Communication and Information Resource Centre for Administrations, Businesses and Citizens) platform.
It should be noted that the list had previously been amended by Commission Delegated Regulation (EU) No. 2024/2547 of September 5, 2024.
The amendments were quantitatively limited due to difficulties in reaching agreement in multilateral fora (particularly in the Wassenaar context), difficulties caused primarily by Russia’s conduct, which effectively exercised veto power over the amendment initiatives.
This stalemate also led to the adoption of several national control lists for non-listed goods.
November 14, 2025
Source: Assonime
regolamento delegato ue 2025:2003 del 14.11.2025
