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

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 Regulation (EU) 2021/821 (the “EU Dual-Use Regulation”), in the Official Journal of the European Union. This update reflects the EU’s commitment to aligning its export control regime with recent changes adopted by international non-proliferation and export control regimes. Annex I of the EU Dual-Use Regulation is therefore typically amended at least once each year.

The updates were initially set out in a Delegated Regulation in September 2025, as covered in our earlier blog post here. The updates entered into force on 15 November 2025. The changes are directly applicable in all EU Member States, without the need for national implementation measures.

Key changes to Annex I

The revised Annex I incorporates updates from 2024 made by the following multilateral export control regimes:

• Australia Group (AG)
• Missile Technology Control Regime (MTCR)
• Nuclear Suppliers Group (NSG)
• Wassenaar Arrangement (WA)

These updates include new and modified entries across most of the ten dual-use categories, which introduces, among other things, the following new dual-use items:

• Controls related to quantum technology (e.g. quantum computers, electronic components designed to work at cryogenic temperatures, parametric signal amplifiers, cryogenic cooling systems, cryogenic wafer probers)
• Semiconductor manufacturing and testing equipment and materials (e.g. Atomic Layer Deposition equipment, equipment and materials for epitaxial deposition, lithography equipment, Extreme Ultra-Violet pellicles, masks and reticles, Scanning Electron Microscope equipment, etching equipment)
• Advanced computing integrated circuits and electronic assemblies such as Field Programmable Logic Devices and Systems
• Coatings for high temperature applications
• Additive manufacturing machines and related materials (e.g. inoculants for powders)
• Peptide synthesisers

The updates also include modification of certain control parameters and updates of certain technical definitions and descriptions. The full list of changes is detailed in the updated Annex I, which replaces the previous version in its entirety. The legislation is available here, and a summary of the amendments is available here.

UK updates to the Retained Dual-Use Regulation

The UK has also recently updated its export controls framework, including through making changes to the list of controlled dual-use items in Council Regulation (EC) No 428/2009 (the “Retained Dual-Use Regulation”).

These changes are introduced through the Export Control (Amendment) (No. 2) Regulations 2025 (available here), which will come into force on 16 December 2025. This legislation also implements certain updates to the Export Control Order 2008, and Regulation (EU) 2019/125 concerning trade in certain goods which could be used for capital punishment, torture or other cruel, inhuman or degrading treatment or punishment.

As summarised in the Explanatory Memorandum for the amending legislation (available here), these changes are intended to “ensure the UK’s export control regime remains up to date and aligned with international commitments and recent updates to EU regulations” and “avoid regulatory divergence between Great Britain and Northern Ireland, and ensure that UK controls reflect the latest international standards”.

Key changes include the following:

• The UK has deleted the national controls on sensitive emerging technologies (control entries PL9013, 9014 and 9015 – the introduction of these controls was covered in our previous blog post here), and has replaced them with new “500 series” control list entries in the Retained Dual-Use Regulation. These changes are intended to ensure alignment between Great Britain and Northern Ireland.
• The UK has introduced new controls relating to electronics and semiconductor manufacturing equipment and special materials, to ensure alignment with recent changes to the EU Dual-Use Regulation (as discussed above).
• The legislation also revises the status of Armenia and Azerbaijan in UK export controls legislation, on account of recent changes in the UK’s export control policy towards these countries, given the lifting of the UK arms embargo on both countries.

The UK Export Control Joint Unit has published further guidance on these changes here.

Practical consequences for exporters

The updated control lists have important implications for EU and UK exporters of dual-use items. We would recommend that exporters take the following steps:

1. Check product classifications are up to date: Exporters should consider reviewing their product portfolios to determine whether any items are now within scope of the revised controls. This may require engagement with suppliers and customers.
2. Understand licensing requirements: Items newly added to the control lists may now require export authorisations. Companies should assess whether existing export licences need to be updated.
3. Assess Internal Compliance Programs (ICPs): Businesses should update their export control ICPs to reflect the new controls, ensuring that staff are trained and internal systems are aligned with the latest regulatory requirements.
4. Document steps taken: Exporters should ensure that they document any steps taken or assessment carried out in relation to these measures, given the likelihood that compliance with these measures will be closely scrutinised by EU and UK authorities.