The EU has comprehensively revised Annex I of the Dual-Use Regulation (EU) 2021/821. With the publication of Delegated Regulation (EU) 2025/2003 in the Official Journal on 14 November 2025, the amendments came into force on 15 November 2025. As they do every year, the EU Member States are thus responding to international export control requirements.
Reasons for the current adjustment
Annex I is revised regularly to align EU legal requirements with international export control regimes such as the Wassenaar Arrangement, the Australia Group, the Nuclear Suppliers Group and the MTCR. The current need for adjustment arose from new international commitments and technological advances in areas such as microelectronics, hyperspectral sensor technology, microwave and laser technology, and post-quantum cryptography.
For companies, this means that classifications, technical documentation and internal control processes must be reviewed immediately, as the changes are already in effect.
An Overview
The changes concern both the addition of new goods to the list and the adjustment of existing parameters. This includes, among other things, a more precise description of technical characteristics, the inclusion of new technologies and the removal of items that are no longer relevant. Delegated Regulation 2025/2003 replaces only Annex I of the Dual-Use Regulation. Annex IV remains officially unchanged, but new or more precise definitions may have an indirect impact on the classification process.
Newly added items – Annex I:
- 1A907 – Composite structures for high loads
- h.4 – Additional mycotoxins
- g.8 – New genetic elements/organisms
- f – Equipment for handling microorganisms
- f.5 – High-performance microwave components
- f – Advanced optoelectronic modulators
- c.3 – High-resolution phased array receiver modules
- p – Electronic components with dual-use relevance
- j – Advanced cryptographic hardware
- h – Software for quantum-resistant cryptography
- d.3 – Sensors for hyperspectral imaging
- l – Optical space components
- b.5 – High-temperature engine technology
- c.2 – Test benches for high-temperature turbine components
Amended parameters – Annex I:
- 0B001, 1A004, 1C240, 1E001 (adjustment of technical limits and definitions)
- 2A001 – 2D001 (precision engineering & software control)
- 3A001 – 3A003, 3A991 (electronics & RF technologies)
- 5A002 – 5E002 (cryptography)
- 6A002 – 6A003, 6A008 (sensor technology & optics)
- 9A001 – 9B001 (aeronautical technology & test benches)
Significance for companies
For exporters, the update means that they must review their internal compliance processes and adjust them if necessary. New technologies such as quantum computers, additive manufacturing and modern semiconductor processes are becoming the focus of export controls. Companies are therefore well advised to regularly review their goods classification and keep up to date with the latest regulations.
As the changes have been in force since 15 November 2025, rapid and structured implementation in classification, compliance and supply chain management is essential to ensure legal certainty and efficiency in the export process.
Link to Delegated Regulation (EU) 2025/2003 (amendment to the EU Dual-Use Regulation): click here
