The updated Annex I of the EU Dual-Use Regulation (EU) 2021/821 is scheduled to take effect in November 2026. Are the dual-use items that you trade with affected?
Annex I of the EU Dual-Use Regulation defines a uniform list of dual-use items for all member states of the European Union. Specifically, it summarizes the internationally agreed controls for dual-use items from the following export control regimes: The Australia Group (AG), the Missile Technology Control Regime (MTCR), the Nuclear Suppliers Group (NSG) and the Wassenaar Arrangement (WA).
Decisions taken in these regimes are incorporated by the member states into their respective export control lists. In the EU, changes are reflected in the EU Dual-Use Control List in Annex I of the EU Dual-Use Regulation. For this reason, an annual update usually takes place. Each new addition triggers a licensing requirement. Changes to parameters therefore also have an impact on the application for or use of licenses.
Note: Exporting items listed in Annex I from the EU is always subject to license requirements.
On September 14, the European Commission announced the update to Annex I of Regulation (EU) 2021/821 with the preliminary draft of the Delegated Regulation. This will be published shortly in the Official Journal of the EU and is expected to enter into force in November 2026.
In addition to amending certain control parameters and updating certain technical definitions and descriptions, new items and sub-items have also been added. The European Commission summarizes these in its press release dated September 14, 2026:
Export Controls from AEB automatically checks all your relevant transactions for license requirements and embargo restrictions worldwide. Ad hoc, fully automated, or company-specific. In the cloud or integrated in your ERP.
The EU list of dual-use items is divided into ten categories. To check your goods, follow the structure to find the correct export control number. Latest changes may result in certain goods being removed from the scope of control or added to it. Companies should therefore check the recent updates carefully and implement any required changes in their material master accordingly.
The following resources are available to support you in the process:
Note: The EU Commission is making a dual-use correlation table available, which can be downloaded in Excel format. This tool, however, only provides legally non-binding information to help you determine the correct export control number. Once available, the latest version will be published in the official EU TARIC ad Quota data information library.
