The European Union adopted Regulation (EU) 2025/2003, which issued an updated Annex I to Regulation (EU) 2021/821 on dual-use export controls. The updated Annex I entered into force on 15 November 2025 and brings extensive technical and substantive adjustments to the list of controlled items.
Dual use goods are products, software and technologies that have legitimate civilian uses, but can also be used for military purposes, in particular in the development or production of weapons of mass destruction. Such dual-use items are subject to export authorisation and control when exported from the Union, when transiting within the EU or when the items are supplied to a third country on the basis of brokering services provided by an intermediary established or established in the Union.
The update of Annex I is a regular review of the lists that the EU carries out in light of technological developments and Member States’ commitments under international control regimes – in particular the Wassenaar Arrangement, the Missile Technology Control Regime, the Australia Group and the Nuclear Suppliers Group. In its summary of amendments, the European Commission states that new definitions, modifications to technical parameters and additions to the items identified by these control regimes have been reflected in Annex I.
The amendments apply to most categories of dual-use goods, especially electronics, semiconductor technologies, production and laboratory equipment, laser systems and space technologies.
The reason for the update is the need to ensure that the regulation corresponds to current technical developments and newly identified security risks. The revision also strengthens alignment with international export control standards, which are updated annually and the content of which is subsequently transposed into EU law.
The changes may have a real impact on a number of exporters, including companies that have not yet been subject to licensing obligations. It is therefore appropriate to pay attention to this update and, if necessary, to obtain an export authorisation.
How can we help you?
If you are interested in more detailed information or need assistance in the field of dual-use trading, we will be happy to help you.
We also prepare workshops for our clients, where we will comprehensively explain the issue of export controls, which include, among other things, dual-use goods.
Seminars, webcasts, business breakfasts and other events organized by Deloitte.
