News

EU updates dual-use control list: New controls on emerging technologies and shift in export control policy

24 November 2025

Key takeaways

The update of the EU’s Dual-Use Control List introduces new controls and amends existing ones.

Businesses should assess whether these changes impact their operations and update their compliance programmes as necessary.

If affected, businesses are advised to conduct export control assessments and ensure compliance with both EU and national requirements where applicable.

If in doubt about any aspect, seek guidance from national competent authorities or legal counsel.

On 14 November 2025, the EU published a Delegated Regulation updating the EU's Dual-Use Control List in the Official Journal. The Delegated Regulation entered into force the following day, on 15 November 2025. This alert discusses the objectives behind the changes, highlights the key amendments, and provides compliance recommendations for businesses.

On 14 November 2025, the EU published a Delegated Regulation updating the EU's Dual-Use Control List in the Official Journal. The Delegated Regulation entered into force the following day, on 15 November 2025.

Purpose of amendments

The EU's Dual-Use Control List is updated annually to align with multilateral export control regimes. The 2025 update incorporates changes agreed in 2024 under the Australia Group, the Missile Technology Control Regime, the Nuclear Suppliers Group, the Wassenaar Arrangement and the Chemical Weapons Convention. For the first time, the update also includes items related to emerging technologies that were not agreed upon within these multilateral regimes. These items are designated as the "500" series on the EU's Dual-Use Control List.

Key amendments

The amended Dual-Use Control List introduces new controls and amends existing ones, including:

Controls related to quantum technology (e.g., quantum computers, parametric signal amplifiers, cryogenic cooling systems, cryogenic wafer probers).
Semiconductor manufacturing and testing equipment and materials (e.g. Atomic Layer Deposition equipment, lithography equipment, etching equipment).
Advanced computing integrated circuits and electronic assemblies (e.g., Field Programmable Logic Devices).
Coatings for high-temperature applications.
Additive manufacturing machines and related materials (e.g., inoculants for powders).
Peptide synthesisers.
Modification of certain control parameters and update of certain technical definitions and descriptions.

Shift due to geopolitical challenges

As highlighted by EU Trade Commissioner Maroš Šefčovič during the Export Control Forum 2025, these amendments mark a significant shift away from the EU's traditional reliance on international consensus, particularly under the Wassenaar Arrangement. The underlying reason is that, since Russia's invasion of Ukraine in 2022, Russia has used its veto power to block updates to the Wassenaar Arrangement control list, causing fragmentation among participating countries (see also: Commission's 2024 White Paper on Export Controls). Several EU Member States – including France, the Netherlands, Spain, Italy, Germany, Finland, and Sweden – have adopted national control lists introducing dual-use controls on certain emerging technologies. These national lists may differ in language, legal form, and substantive coverage.

As a result, in the 2025 update to the EU's Dual-Use Control List, the Commission included items blocked at the multilateral level but supported by EU Member States. These entries are classified under the new "500" series, such as 4A506, which covers quantum computers.

Suggested actions

Given the scope and significance of these amendments, we recommend the following actions:

Review product portfolios: assess whether your products, technologies, or services are affected by the new or amended controls.
Update internal compliance programs: ensure that your internal compliance procedures and screening tools are updated to reflect the latest changes to the EU's Dual-Use Control List.
Conduct export control assessments: re-evaluate current and planned transactions, contracts, and supply chains for potential new export restrictions.
Monitor national control lists: EU Member States are expected to amend or repeal national controls that overlap with the EU's Dual-Use Control List. The Netherlands for instance already published relevant changes to its national control measures on 24 November 2025, which will apply with retroactive effect as from 15 November 2025 (when the EU Delegated Regulation entered into force). Companies should monitor national developments, and in any event ensure compliance with both EU and national requirements where applicable.
Engage with authorities: if in doubt, seek guidance from national competent authorities or legal counsel to clarify the impact of the new controls on your operations.