On 14 September 2026, the European Commission adopted the update to Annex I of the EU Dual-Use Regulation. This revision brings the European control list for dual-use items into line with new technological developments. Companies that export goods, software or technologies should review the changes at an early stage, as numerous new items have been added and existing control parameters have been revised.
The amendments are based on the decisions of international export control regimes from 2025 and are intended to ensure that European export controls keep pace with rapid technological progress. The new regulations are expected to come into force from November 2026.
What does the EU Dual-Use Regulation cover?
The EU Dual-Use Regulation forms the basis of European export controls for dual-use items. These include goods, software and technologies which, although developed for civilian purposes, can also be used for military purposes or in connection with the development of sensitive technologies.
At the heart of the Regulation is the Common European List of Goods set out in Annex I to Regulation (EU) 2021/821. Goods listed there are, in principle, subject to specific control and authorisation requirements when exported. As technologies are constantly evolving, the list is regularly updated and aligned with international standards.
Why is the dual-use list regularly updated?
New products and technical processes are constantly emerging, particularly in fields such as semiconductor technology, high-performance computing, materials science and modern manufacturing processes. To ensure that export controls can continue to fulfil their protective function, the lists of goods must be regularly reviewed and updated.
The 2026 revision is based on the discussions and decisions of the ‘Wassenaar Arrangement’, the ‘Australia Group’ and the ‘Nuclear Suppliers Group’ from 2025. The aim is to ensure the uniform application of export controls within the European Union and the effective control of new and sensitive technologies.
At the same time, transparent and Europe-wide uniform guidelines are intended to create a level playing field for businesses and strengthen security in international trade.
Focus of the amendments: Modern high technologies
This year’s update focuses primarily on technologies used in strategically important industrial sectors. The areas most affected are semiconductor manufacturing, microelectronics, materials science, sensor technology and selected manufacturing processes.
Extended controls for the semiconductor industry
One of the main areas of change is the semiconductor sector. The EU is extending controls to cover various manufacturing, testing and cleaning technologies used in the production of modern high-performance chips.
Newly covered items include, amongst others, certain equipment for the atomic layer deposition of molybdenum and ruthenium, technologies relating to EUV masks and EUV reticles, and specialised equipment for cleaning individual wafers.
Technical definitions and descriptions relating to EUV technology have also been updated to reflect current technological developments.
New regulations for advanced computing chips
High-performance integrated circuits and electronic assemblies are also coming under greater scrutiny in the context of export controls. The revised list of goods takes account of modern electronic components that may contain one or more digital processing units.
In addition, various technical definitions have been updated, including terms such as ‘power density’ and ‘data centre’, which are becoming increasingly important for the assessment of modern high-performance electronics.
New materials and production technologies
As well as the electronics industry, the update also affects various high-performance materials.
New additions include, amongst others, certain ceramic matrix composites reinforced with mullite fibres, which can be used in high-temperature applications. Furthermore, further adjustments have been made to ceramic materials and related definitions.
Technologies and equipment for the manufacture of silicon carbide fibres have also been newly included. These materials play an important role in demanding technical applications and will be subject to enhanced controls in future.
Additive manufacturing is coming increasingly into focus
With this update, certain equipment for the additive manufacturing of energy-related materials is, for the first time, explicitly covered by export controls.
This applies to equipment designed or adapted for the manufacture of products based on explosives, pyrotechnic substances or propellants. In this way, the EU is taking account of the growing importance of modern manufacturing technologies in sensitive sectors.
New controls for sensor technology and power electronics
The control list has also been expanded to include further technology-related goods.
These include, in particular, inductive rotary encoders as well as certain power semiconductors, power diodes and associated power modules. At the same time, the technical descriptions and control parameters for individual items have been clarified and brought into line with the current state of the art.
Changes in the field of gas turbine technology
Changes have also been made in the field of aerospace and engine technology. A new control item has been added for technologies used in the development of axial compressors for gas turbine engines.
This expansion underlines the EU’s approach of incorporating advanced development technologies more closely into export controls.
Which companies should pay particular attention to these changes?
The update primarily affects companies that work with technologically sophisticated products, materials or development services. A review of their own product portfolios and classifications is particularly recommended for companies in the following sectors:
- Semiconductor and microelectronics industry
- Mechanical and plant engineering
- Aerospace
- Materials and ceramics technology
- Chemical industry
- High-tech and research sector
Particularly in the case of technologically complex products, even a minor adjustment to technical parameters can result in goods being subject to authorisation in future.
An overview of the key changes:
- Update to Annex I of Regulation (EU) 2021/821 by the European Commission.
- Inclusion of new goods and technologies in the European Dual-Use List.
- Extended controls on semiconductor manufacturing equipment and technologies.
- New control entries for advanced integrated circuits and electronic assemblies.
- Introduction of additional controls in the field of EUV technology.
- Extension of controls on high-performance ceramic materials and silicon carbide fibres.
- New regulations for equipment used in the additive manufacturing of energy-related materials.
- Inclusion of goods in the field of sensor technology and power electronics.
- Introduction of new controls for technologies used in the development of axial compressors for gas turbine engines.
- Revision of technical definitions, parameters and descriptions in line with the current state of the art.
- The amendments are expected to come into force from November 2026.
Sources: Federal Office for Economic Affairs and Export Control (in German), European Commission
