On 8 September 2025, the European Commission adopted a delegated regulation updating the EU control list of dual-use items (Annex I to Regulation (EU) 2021/821). This annual revision aims to align EU law with recent decisions of multilateral export-control regimes and to ensure harmonised application across all Member States.
Legal Framework
Regulation (EU) 2021/821 establishes a common EU regime for the export, transfer, brokering, transit, and technical assistance of dual-use items—i.e., goods, software and technologies that can have both civil and military applications. Annex I (commonly called the EU Control List) is regularly updated via delegated acts so as to reflect decisions adopted within the following international export-control frameworks:
- the Wassenaar Arrangement (WA)
- the Missile Technology Control Regime (MTCR)
- the Australia Group (AG)
- the Nuclear Suppliers Group (NSG)
The 2025 update transposes decisions made in 2024 by these regimes, and also incorporates additional commitments made by Member States under the Wassenaar Arrangement.
Key Changes
The 2025 revision introduces new controls and amends several technical definitions. Notable updates include:
- quantum technologies: quantum computers, electronic components designed for cryogenic temperatures, cooling systems and parametric signal amplifiers
- semiconductor-manufacturing and testing equipment and materials: atomic layer deposition tools, epitaxial-deposition equipment, lithography machines, EUV pellicles/masks, scanning-electron microscopes, etching equipment
- advanced integrated circuits and electronic assemblies (e.g., field-programmable logic devices)
- high-temperature coatings
- additive-manufacturing machines and related materials (e.g., powder inoculants)
- peptide synthesisers
- modifications to certain control parameters and updated technical definitions
These changes reflect the growing strategic importance of dual-use technologies in fast-evolving areas, and ensure that the EU’s export-control regime keeps pace with technological, economic and security-related developments.
Entry into Effect & Practical Implications
The delegated regulation will enter into effect at the end of 2025, following the standard two-month scrutiny period by the European Parliament and the Council.
Economic operators affected—including exporters, manufacturers of advanced components, technical-service providers and brokers—are advised to:
- review the updated Annex I to identify newly listed or amended categories of items;
- assess the potential impact of these changes on their export operations and licensing obligations;
- and, where applicable, update their internal export-control compliance procedures.
Our law firm assists clients in interpreting Regulation (EU) 2021/821, analysing the revised control list and adapting their export operations to ensure full compliance with EU law.
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