Adoption of Delegated Regulation On September 8, 2025, the European Commission adopted a delegated regulation amending the export control list of dual-use items set out in Annex I of Regulation (EU) 2021/821. 

Background The EU’s dual-use export control list is aligned with internationally recognized non-proliferation standards and requires export authorizations for listed items. As part of Annex I of the EU Dual-Use Regulation, this list is typically updated at least once a year through delegated acts to reflect global developments.

Reason for the Update In 2024, several international export control regimes—including the Australia Group (AG), the Missile Technology Control Regime (MTCR), the Nuclear Suppliers Group (NSG), and the Wassenaar Arrangement (WA)—introduced changes to their respective control lists. On May 23, 2025, EU Member States unanimously endorsed new control commitments under the Wassenaar Arrangement. To ensure consistent implementation of these international commitments across the EU, Annex I has now been revised through a delegated regulation.

Key Updates The revised control list introduces new categories of dual-use items and updates existing definitions. Notable additions include:

· Quantum technologies – e.g., quantum computers, cryogenic electronic components, parametric amplifiers, cryogenic cooling systems, wafer probers.

· Semiconductor manufacturing and testing equipment – including Atomic Layer Deposition equipment, epitaxial deposition equipment and materials, lithography systems, EUV pellicles, masks and reticles, Scanning Electron Microscopes, and etching tools.

· Advanced computing integrated circuits and assemblies – such as Field Programmable Logic Devices (FPLDs) and related systems.

· Coatings for high-temperature applications.

· Additive manufacturing technologies – including advanced 3D-printing machines and related materials such as powder inoculants.

· Peptide synthesisers.

· Technical revisions – modifications to control parameters, definitions, and descriptions.

Entry into Force The updated control list will become applicable following the standard two-month scrutiny period by the Council and the European Parliament.

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