EU dual-use list 2026: what changes for exporters

What has changed

The list of dual-use items is Annex I of Regulation (EU) 2021/821. A dual-use item is one that can serve civil purposes as well as military or proliferation ones. Exporting an item on that list outside the EU requires authorisation from the competent authority of the exporter's Member State.

On 14 September 2026 the Commission adopted a Delegated Regulation updating that annex. The update transposes decisions taken in 2025 in the Wassenaar Arrangement, the Australia Group and the Nuclear Suppliers Group, and includes commitments that Member States have accepted in Wassenaar.

The Commission reviews the list at least once a year through a delegated act. That is why it should be treated as a recurring check and not a one-off formality.

New in the 2026 list

• Equipment and materials to make and test semiconductorsFor example, atomic layer deposition equipment for molybdenum and ruthenium, equipment to inspect extreme ultraviolet masks, and single-wafer cleaning equipment.
• Advanced computing integrated circuitsIncludes circuits incorporating one or more digital processing units and the electronic assemblies that carry them.
• Ceramic matrix composites reinforced with mulliteDesigned for high-temperature applications.
• Rotary encoders based on inductive sensingA common component in machinery and automation.
• Additive manufacturing equipment for energetic materialsAnd chemical vapour deposition equipment to produce silicon carbide fibres.
• Gas turbine technologySpecifically, technology for the development of axial compressors of gas turbine engines.

Who is affected and when

The update enters into force on publication in the Official Journal of the European Union, after the usual two-month scrutiny period of the Council and the European Parliament. Counted from 14 September, that period ends in mid-November 2026. The exact date is set by publication in the Official Journal.

It mainly affects companies that make or resell machinery, laboratory equipment, electronic components and related technology, and that sell outside the EU. The list is common to all Member States: the control is the same from any country in the Union. For a company exporting from Spain, authorisation is requested from the competent Spanish authority.

Why it matters for a small business

Controls are defined by technical parameters, not by the commercial name of the product. An apparently ordinary component or machine can fall within the list if it exceeds a technical threshold.

An export without the necessary authorisation can hold up the shipment at customs and block an order the customer has already accepted. Checking the classification before quoting avoids that risk.

What to do before it applies

1. 01

   Gather the technical data sheets

   Find the technical specifications of each product you export: controls are defined by technical parameters.

2. 02

   Compare with the change note

   Review the summary of changes the Commission publishes, which goes through the ten categories of Annex I, and mark the products that may be affected.

3. 03

   Ask your manufacturer or supplier

   Find out whether the item or its components are listed in Annex I and ask for the classification in writing.

4. 04

   Apply for authorisation if needed

   If the product is on the list, request authorisation before accepting the order, not when preparing the shipment.

5. 05

   Record it in your documentation

   Add the classification to the product sheet and to the documents of each shipment, so the check is repeated on every transaction.

How Exporta helps

With Exporta you organise the paperwork of each shipment, such as the proforma invoice and the packing list, and keep your product sheets in one place. The market reports by country and product show you tariffs, demand and competition at the destination, and Xport, the assistant, helps you keep every operation documented.

Classifying a product as a dual-use item remains the responsibility of the company and the competent authority.

Frequently asked questions