On November 15, 2025, the implementing regulation updating the EU’s Dual-Use Regulation (Regulation (EU) 2021/821) came into force. The update incorporates editorial refinements for greater clarity and coherence, introduces new entries, and further clarifies some existing ones.

These updates reflect the EU’s efforts to harmonize its export controls with recent decisions and commitments under multilateral export control regimes, such as the Wassenaar Arrangement (WA), Missile Technology Control Regime (MTCR), Australia Group (AG) and Nuclear Suppliers Group (NSG). The update also further aligns the EU position with the United States, which has already implemented many of these developments.

The EU has amended and expanded export controls over critical and emerging technologies, in particular quantum computing, semiconductor manufacturing, biosecurity, and advanced materials.

Below is a non-exhaustive list of the changes and key industries affected:

Category 1: Special Materials and Related Equipment

  • 1C002.c.1.a: Nickel alloys for gas turbine engines
  • 1C002.c.2: Ultrasonic atomization
  • 1C513: High-entropy alloy or refractory metal powders 

Industries affected: Aerospace, maritime, advanced materials manufacturing.

Category 2: Materials Processing

  • 2B352.j: Peptide synthesizers
  • 2B510: Metal alloyadditive manufacturing equipment
  • 2E503: Corrosion-resistant coating systems technology

Industries affected: Pharma, biotech, defense, aerospace, automotive.

Category 3: Electronics

  • 3A501.a.15: Cryogenic Complementary Metal-Oxide-Semiconductor (CMOS)
  • 3A501.a.16: Integrated circuits
  • 3A501.b.13: Quantum-limited amplifiers (QLAs)
  • 3A502.i: User-configurable Field Programmable Logic Devices (FPLDs)
  • 3A504: Cryogenic cooling systems and components
  • 3B501.a: Epitaxial growth (silicon or silicon-germanium) and Atomic Layer Epitaxy (ALE) equipment
  • 3B501.f: Extreme Ultraviolet (EUV) lithography equipment
  • 3B501.k: Dry etching equipment
  • 3B501.l: EUV masks and reticles
  • 3B501.m: EUV lithography pellicles
  • 3B501.n: Deposition equipment
  • 3B503: Specialized Scanning Electron Microscopes (SEM)
  • 3B504: Cryogenic wafer probing tools
  • 3C507 and 3C509: Epitaxial materials and certain silicon and germanium materials

Industries affected: Semiconductor manufacturing, defense, consumer electronics, information security.

Category 4: Computers

  • 4A506: Quantum computers 

Industries affected: Telecommunications, information security, finance, defense, advanced computing R&D.

In parallel, the UK laid the Export Control (Amendment) (No.2) Regulations 2025 before Parliament on November 17, 2025 which are scheduled to come into force on December 16, 2025. The regulations will similarly update the UK’s export control framework to align with international commitments and recent EU regulatory changes. 

Crowell & Moring will continue to monitor developments related to EU, UK and U.S. export controls and potential impact to industry.

Tags: EU, Export Control
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Photo of Vassilis Akritidis Vassilis Akritidis

To maximize trade-related benefits, get customs advice, or ensure robust representation before the European Commission and EU courts in trade and EU matters, clients turn to Vassilis Akritidis and his team for clear advice and dedication to a positive result. Beyond disputes, proactive

…

To maximize trade-related benefits, get customs advice, or ensure robust representation before the European Commission and EU courts in trade and EU matters, clients turn to Vassilis Akritidis and his team for clear advice and dedication to a positive result. Beyond disputes, proactive compliance and proper corporate governance are essential for success. Vassilis organizes compliance training programs for executives to ensure smooth and cost-effective navigation through the complex web of EU and World Trade Organization regulations.

Vassilis has been practicing EU and international trade law in Brussels since 1991. He qualified in Athens as a maritime lawyer and then pursued graduate studies in European law at the Institute of European Studies in Brussels. An internship at the State Aid Directorate-General for Competition convinced Vassilis that EU and supranational law are hugely interesting. He started as an EU competition and public procurement lawyer and over the years focused increasingly on international trade and WTO law. Vassilis is regularly quoted by renowned legal directories as an expert in these fields.

Vassilis helps his clients win trade investigations, achieve and improve market access, maximize trade benefits, and be trade-compliant wherever they operate. He advises and represents private clients, professional associations, and governments in trade defense investigations (anti-dumping, anti-subsidy, safeguards), customs investigations and litigation, trade sanctions/export controls, and EU anti-fraud investigations led by the European Anti-Fraud Office and the European Public Prosecutor’s Office. Vassilis also advises on EU State aid and EU internal market and public procurement.

Vassilis has worked for clients active in the steel, chemicals, high-tech, transport, defense and aerospace, automotive, and agriculture/food sectors. He represents clients before the EC and other non-EU trade defense authorities.

Should things get contentious, Vassilis is an experienced litigator, representing parties before EU courts in Luxembourg as well as national customs and administrative tribunals.

Vassilis works with his colleagues at Crowell Global Advisors, our global government relations, public policy, and public affairs affiliate, in matters involving EU public policy and lobbying.

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Photo of Sophie Davis Sophie Davis

Sophie Davis is an associate in Crowell’s London office and advises clients on a range of sanctions, export controls, and trade compliance matters. Sophie has particular experience advising multinational corporations and financial institutions on how to comply with rapidly evolving trade and financial

…

Sophie Davis is an associate in Crowell’s London office and advises clients on a range of sanctions, export controls, and trade compliance matters. Sophie has particular experience advising multinational corporations and financial institutions on how to comply with rapidly evolving trade and financial sanctions across a range of EU and UK sanctions regimes, assisting corporate clients with complex sanctions issues arising from their continued operations in, or divestments from, Russia, and supporting clients with licensing applications and responding to investigations.

Sophie also assists companies on compliance with anti-bribery and anti-money laundering laws, foreign direct investment requirements, human rights, environmental and sustainability regulatory requirements. Prior to joining Crowell & Moring, Sophie worked in the international trade and regulatory team in another top international law firm, based in London, as well as for a leading New Zealand law firm.

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Photo of Chandler Leonard Chandler Leonard

Chandler S. Leonard is an associate in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade Group. Chandler’s practice focuses on export controls and economic sanctions issues, including voluntary disclosures and enforcement matters before the Departments of Commerce…

Chandler S. Leonard is an associate in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade Group. Chandler’s practice focuses on export controls and economic sanctions issues, including voluntary disclosures and enforcement matters before the Departments of Commerce, State, and Treasury. Chandler has experience analyzing and advising U.S. and non-U.S. companies with respect to proposed transfers of U.S. origin technology, software, hardware, and services. She has performed jurisdictional and classification analyses under the ITAR and EAR, including drafting Commodity Jurisdiction requests and CJ Reconsideration requests. She assists in developing and/or reviewing U.S. export and sanctions compliance programs, including risk assessments. Chandler also has experience training a wide variety of audiences, both U.S. and foreign, on compliance with U.S. export control and sanctions requirements.

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