Check your material master: Changes to the EU dual-use control list
Dual-use items

Check your material master: Changes to the EU dual-use control list

The updated Annex I of the EU Dual-Use Regulation (EU) 2021/821 entered into force on December 16, 2023. Are the dual-use items that you trade with affected?

Changes with impact on license requirements

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 export control regimes. Specifically, these are the Australia Group (AG), the Missile Technology Control Regime (MTCR), the Nuclear Suppliers Group (NSG) and the Wassenaar Arrangement (WA).

The decisions taken in these regimes will be incorporated by the member states into their respective export control lists. In the case of the EU, this is the dual-use 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.

Legal certainty for shipping critical goods

Not only military goods are subject to export controls. AEB's Export Controls software also automatically checks your dual-use items against current national and international product lists and makes legally compliant shipping easy.

Updates – what the 2024 EU dual-use control list looks like

In 2023, in addition to the annual revision that is expected at the end of each year, there were also changes in the course of the year. 

With the Delegated Regulation (EU) 2023/996 of February 23, 2023, the European Commission revised Annex I of Regulation (EU) 2021/821. Four new entries for marine toxins in category 1 were added. The Delegated Regulation then entered into force on May 26, 2023.

A few months later, the EU Commission presented the annual amendments in Delegated Regulation (EU) 2023/2616 of September 15, 2023. The Delegated Regulation entered into force on December 16, 2023.

Note: On December 29, 2023, the EU Commission released its dual-use correlation table, 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.

Latest changes mainly refer to the control parameters of production systems as well as high-performance computers and lasers. Propulsion engines for submersible vehicles and technologies for the development of gas turbine engines for aircraft have been added. Other changes relate to technical definitions, notes, and descriptions as well as editorial changes.

Companies should check these updates carefully and implement any required changes in their material master accordingly. 

If you are working with the Export Controls software from AEB, the solution always checks your export transactions automatically against the latest EU dual-use control lists once they take effect.