On 19 March 2025, the European Commission (âECâ), in collaboration with the EUâs High Representative for Foreign Affairs and Security Policy, published the Joint White Paper on the Future of European Defence (the âWhite Paperâ), 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…
On September 5, 2024, the European Commission published a Delegated Regulation, updating the list of dual-use items contained in Annex I to Regulation (EU) 2021/821 (the “EU Dual Use List”) The EU Dual Use List is updated annually, to ensure it remains aligned with multilateral export control regimes, including the Wassenaar Arrangement, the Missile Technology Control Regime, the Nuclear Suppliers Group and the Australia Group. The Delegated Regulation will only take effect the day after…
Introduction During September 2023, the US, UK, and EU, and Japan, updated their Common High Priority Items Lists (“the List(s)”), with seven new Harmonized System (“HS”) codes. These coordinated Lists are composed of items identified as critical to Russia’s war effort, weapons systems and military development. The Lists highlight to businesses that there is a particularly high risk these sanctioned items may be the target of sanctions circumvention and possible diversion to Russia. Companies can…
Following the entry into force of the new EU Dual-Use Regulation 2021/821 last month (see also our recent post), the EU has introduced new document codes that need to be used on EU customs export declarations for exports and transits of dual-use items. Notably, specific codes now apply depending on the relevant (type of) authorisation/licence. The old code âX002â (which was previously valid for all dual-use authorisations) has been replaced and cannot be used anymore.…