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 once a year, updates Annex I by Delegated Regulation pursuant to Articles 17 and 18 of the EU Dual-Use Regulation. The amendments primarily reflect decisions and commitments made by Member States taken within the framework of the multilateral export control regimes and export control arrangements Wassenaar Arrangement (WA), Australia Group (AG) and Nuclear Suppliers Group (NSG).
As we previously reported, the Commission followed the same procedure for the 2025 update, which was published in the Official Journal on November 14, 2025 as Delegated Regulation (EU) 2025/2003 and entered into force the following day (see our previous blog post here).
Unless the European Parliament or the Council objects during the two-month scrutiny period, the Delegated Regulation will be published in the Official Journal of the European Union and enter into force upon publication.
Expected Changes
The Delegated Regulation introduces new dual-use controls, expands certain existing entries and updates several technical parameters, definitions, and descriptions. The most significant changes concern advanced semiconductor manufacturing equipment and advanced computing integrated circuits, as well as certain technology in the context of gas-turbines.
New control entries include:
- Semiconductor manufacturing equipment: Certain Atomic Layer Deposition equipment for molybdenum and ruthenium, EUV photoresist-processing, mask-inspection and pattern-shaping equipment, certain single-wafer cleaning equipment, and equipment for depositing multilayer reflectors for EUV masks. Related software controls are also extended to certain newly listed equipment
- Power semiconductors: Certain high-voltage solid-state power-semiconductor switches, diodes and modules using wide-bandgap semiconductor materials, including silicon carbide, gallium nitride and gallium oxide.
- Advanced composite materials: Certain ceramic-ceramic composite materials with a glass or oxide matrix reinforced with continuous mullite fibers.
- Rotary encoders: Rotary-input absolute-position inductive encoders meeting specified output, size and resolution criteria.
- Additive manufacturing: Equipment designed or modified to produce explosive, pyrotechnic or propellant devices or shapes from energetic materials using ultrasonic extruders or nozzles.
- Silicon carbide fibers: Equipment specially designed or modified to produce multiple parallel silicon carbide fibers by laser-driven Chemical Vapor Deposition.
- Gas-turbine technology: Technology required for the development of gas-turbine-engine axial compressors. This entry concerns development technology rather than axial compressors as physical goods. Hence, it can already be triggered by sharing design data, process parameters or technical assistance with non-EU affiliates, suppliers or engineers, including by remote access or electronic transfer.
Expanded or modified existing controls include:
- Advanced computing integrated circuits: The revised entry introduces additional performance-based criteria and extends the scope of the control to certain integrated circuits that were not previously captured, including certain high-performance integrated circuits meeting specified performance-density thresholds, while introducing a decontrol for certain items not designed for use in data centers.
- Software: Existing software controls are extended to certain newly listed semiconductor equipment, including specified EUV-processing, mask-inspection and single-wafer cleaning equipment.
- Technical parameters: The update modifies control thresholds and decontrol provisions for certain secondary cells, lasers, turboexpanders and nucleic-acid synthesizers. – Definitions and descriptions: The amendments introduce a new global definition of “Extreme Ultraviolet” and make several technical, editorial and cross-reference changes throughout Annex I.
Consequences for manufacturers and exporters
Companies should consider whether their existing classifications, licenses and intra-EU transfer arrangements are affected before the updated Annex I applies. In addition, certain of the outlined changes are expected to flow through to Annex IV of the EU Dual-Use Regulation, which governs intra-Union transfers. This is because Article 17(1)(b) of the EU Dual-Use Regulation provides that where an amendment of Annex I concerns items also listed in Annex II or Annex IV, those Annexes are amended accordingly.
We will continue to monitor developments and keep you updated on all matters relating to export controls.
