The updated Annex I of the EU Dual-Use Regulation (EU) 2021/821 entered into force on November 15, 2025. 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.
Note: Items listed in Annex I are always subject to license requirements when exported from the EU.
Following the publication of the Commission Delegated Regulation (EU) 2025/2003 in the Official Journal of the EU on November 14, 2025, the amendments to Annex I of the EU Dual-Use Regulation entered into force on the following day.
As already announced by the EU Commission in the press release of September 8, the following goods were added to Annex I of the EU Dual-Use Goods List:
If you wish to see all changes in detail – including new or changed notes, added specifications, clarifications, parameter and editorial changes – please refer to the Summary of Amendments to Regulation (EU) 2021-821 for 2025.
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. Companies should check the latest updates carefully and implement any required changes in their material master accordingly.
If you are checking your export transactions with AEB's software solutions for Trade Compliance Management, changes are taken into account once they come into force.
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.
