On September 14, 2026, the EU Commission adopted a Delegated Regulation updating Annex I to Regulation (EU) 2021/821 (“EU Dual-Use Regulation”). Although the changes have not yet entered into force, the Delegated Regulation sets out the expected amendments to the EU Dual-Use Regulation. Background Annex I to the EU Dual-Use Regulation lists dual-use items that require an export authorization pursuant to Article 3(1) of the EU Dual-Use Regulation. The EU Commission periodically, usually at least…