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 November 8, 2024. 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 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.

Updates – what the 2025 EU dual-use control list looks like

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. 

There are no changes in category 4 and some categories only reflect new notes and editorial changes. No new export control numbers have been added, however, changes to sub-entries have taken place. 

New and deleted sub-entries are listed below for each category. 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 informational purposes)

Category O

  • 0B004.a.3: New entry for "Combined Electrolysis and Catalytic Exchange (CECE) plants"
  • 0B004.a.4: New entry for "Combined Industrial Reforming and Catalytic Exchange (CIRCE) plants"
  • 0B004.a.5: New entry for "Bithermal Hydrogen-Water exchange (BHW) plants"
  • 0B004.b.6: Entry deleted and replaced by "not used"
  • 0B004.b.10: New Entry for "Complete columns or towers specially designed or prepared for hydrogen isotope exchange"

Category 1

  • 1C011.e: New entry for "Iodine pentafluoride"
  • 1C350.90: New Entry for "Dipropylamine"
  • 1C351.d.24: New Entry for "Neosaxitoxin"

Category 3

  • 3A001.b.7.c.3: Entry deleted and replaced by "not used"
  • 3A002.e.2: Entry deleted and replaced by "not used"

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.

Note: On November 8, 2024, 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.

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