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EU Export Controls

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Spain’s Export Controls Regime: Recent Developments and What Comes Next

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Spain’s Secretaría General de Comercio (General Secretariat for Trade) recently held an informational briefing outlining significant developments in the country’s export control framework. The session addressed both recently implemented measures and upcoming regulatory changes that are expected to reshape the way companies engage with the Spanish licensing system. The briefing also addressed a number of practical issues of relevance to operators, including the treatment of technology transfers in cloud environments and the handling of re-export obligations,…

Hungary: Export Control of Dual-Use Products

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What’s new in 2026? Important amendments to Hungarian Government Decree no. 13/2011 (“Decree”) on the authorization of trade in dual-use items have entered into force. Together with Regulation (EU) 2021/821, which establishes the Union regime for controlling the export, brokering, technical assistance, transit and transfer of dual-use items, the Decree forms the foundation of the national legal framework governing dual-use product export controls. Main changes On 25 December 2025 and 1 January 2026, the following…

EU and UK update their respective dual-use export control lists: key changes and implications for exporters

By , , , and 5 Mins Read

The EU and UK have recently updated their respective lists of items subject to dual-use export controls, introducing important changes covering emerging technologies. In this blog post, we summarise the key updates under both the EU and UK regimes, and we highlight key steps that exporters can take in response to the changes. EU updates to the EU Dual-Use Regulation On 14 November 2025, the EU published Delegated Regulation (EU) 2025/2003, amending Annex I of…

EU Commission Adopts Delegated Regulation Updating Annex I of the EU Dual-Use Regulation

By , , , and 3 Mins Read

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…

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