For trade compliance professionals, inhouse counsel & supply chain managers of companies that export or are involved in the supply chain for goods, software or technology in sectors including semiconductor manufacturing, advanced computing, advanced materials, additive manufacturing and aerospace/propulsion engineering, this blog provides a practical overview of the new EU dual‑use controls adopted on 14 September 2026 and sets out the key compliance steps to take before the update enters into force.
On 14 September 2026, the European Commission adopted a delegated regulation updating the EU dual-use export control list (Annex I to Regulation (EU) 2021/821, the “Dual-Use Regulation”).
The Commission explains that the 2026 update (i) aligns Annex I with decisions taken in 2025 within multilateral export control regimes (notably the Wassenaar Arrangement, the Australia Group and the Nuclear Suppliers Group) and (ii) reflects additional Wassenaar-related commitments that EU Member States have accepted to control certain items uniformly across the EU.
The updated list will apply once the delegated regulation is published in the Official Journal of the EU and enters into force the day after publication. Publication is expected in November 2026, following the usual two-month scrutiny period.
What has changed?
The Commission highlights that the 2026 update adds or refines controls covering several technology clusters, including:
- Semiconductor manufacturing and testing equipment and materials, such as:
- Atomic Layer Deposition (ALD) equipment for molybdenum and ruthenium;
- equipment for the development and inspection of extreme ultraviolet (EUV) masks and reticles;
- single-wafer cleaning equipment.
- Advanced computing integrated circuits (ICs) and certain electronic assemblies, including ICs incorporating digital processing units (DPUs).
- Advanced materials, including:
- ceramic matrix composites (CMCs) reinforced with mullite for high-temperature applications;
- chemical vapour deposition (CVD) equipment to produce silicon carbide (SiC) fibres.
- Rotary encoders based on inductive sensing technology.
- Additive manufacturing equipment for energetic materials.
- Technology for the development of axial compressors of gas turbine engines.
Beyond these list updates, the Commission is also adjusting certain technical control parameters and definitions, the type of change that can unexpectedly bring items into scope.
From multilateral consensus to faster EU implementation
As with last year’s major Annex I expansion (widely seen as a step change in EU export control policy), the 2026 update reflects a broader “economic security” direction in which the EU is seeking to keep controls aligned and operational across the single market, even when decision-making in international regimes is difficult. The Commission explicitly links the limited number of 2025 regime changes to difficulties in regime decision-making, noting the context of Russia’s war of aggression against Ukraine. At the same time, EU Member States have adopted additional voluntary commitments under the Wassenaar Arrangement to control further items, an approach already anticipated in the Commission’s white paper on export controls of 24 January 2024 (COM (2024) 25).
What does this mean for businesses?
If your company exports (or supports the export of) items in the semiconductor supply chain, advanced computing hardware, advanced materials, additive manufacturing or aerospace and propulsion engineering, now is the time to run a focused “delta assessment”, even before the updated Annex I takes legal effect.
We recommend the following steps:
- Review your product portfolio (and not just hardware): audit whether your products, software or technology now fall within the updated list. Dual-use scope often turns on technical parameters and definitions, and the 2026 update expressly includes changes to both.
- Re-check “technology” and support deliverables: development know-how, design files, process parameters, troubleshooting and certain forms of remote assistance may be as relevant as physical shipments, particularly in aerospace and propulsion “development technology” areas.
- Assess licensing needs and timelines: once in force, affected exports outside the EU may require a licence depending on the item, destination, end-use and end-user. The legal trigger is publication in the Official Journal.
- Monitor further developments: the Commission’s framing makes clear that Annex I updates are part of an ongoing effort to keep EU controls effective for emerging technologies.
How we can help
If you have questions about how these export controls affect your business, or need guidance on export licensing, customs compliance or sanctions, please contact us or any member of our Corporate Crime & Business Integrity team.
