2025 Update of the EU Dual-Use Control List: Strategic Implications for European Technology and Security
On 8 September 2025, the European Commission adopted a Delegated Regulation updating the EU dual-use export control list under Annex I of Regulation (EU) 2021/821. This update follows decisions made in 2024 by the multilateral export control regimes—the Wassenaar Arrangement, the Missile Technology Control Regime, the Australia Group, and the Nuclear Suppliers Group. The new list incorporates both multilateral commitments and additional items agreed by EU Member States for uniform control. The changes reflect a broader EU strategy, set out in the 2024 White Paper on Export Controls, to strengthen oversight of sensitive technologies at the Union level. With quantum computing, advanced semiconductor equipment, additive manufacturing and peptide synthesis now included, the EU is consolidating its role as a proactive regulator in the governance of emerging dual-use technologies. These changes are not simply technical adjustments but part of a broader framework connecting trade, security, and strategic autonomy.