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EU Export Controls

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On 8 September 2025, the EU Commission adopted a Delegated Regulation updating Annex I of the Regulation (EU) 2021/821 (“EU Dual-Use Regulation”). Although the changes have not yet entered into force, they outline the likely amendments to the EU Dual-Use Regulation. Background Annex I of the EU Dual-Use Regulation lists dual-use items that require export authorization pursuant to Article 3 paragraph 1 EU Dual-Use Regulation. Annex I is periodically amended, usually at least once a year, based on decisions…

On August 21, 2025, the European Union and United States unveiled their Framework on an Agreement on Reciprocal, Fair, and Balanced Trade (“Framework”). The Framework follows, and provides further detail to, the July announcement that the European Union and United States had agreed on broad terms of a trade deal. The Framework outlines the key terms of the trade deal that will be negotiated between the parties, and is a first step in a process…

The Council has adopted a new decision on arms-related export controls, emphasizing the importance of responsible arms trade policies, cooperation and convergence among Member States, and the prevention of diversion to unauthorized users. On 14 April, the Council concluded its review of the EU framework for arms export control by adopting a decision (15 April 2025)[1] amending the Council’s Common Position 2008/944/CFSP, defining common rules governing the control of exports of military technology and equipment,…

On 19 March 2025, the European Commission (“EC”), in collaboration with the EU’s High Representative for Foreign Affairs and Security Policy, published the Joint White Paper on the Future of European Defence (the “White Paper”), available here. As outlined in the White Paper, the EU is embarking on an ambitious journey: bolstering its defence capabilities through the “REARM Europe” initiative (as announced by the President of the European Commission here. The REARM Europe initiative is…