The European Commission has adopted an update to the common EU list of dual-use items subject to export control. The changes expand the scope of controlled items, and will also eventually affect Norwegian export control rules.
On 14 September 2026, the European Commission adopted a Delegated Regulation updating Annex I to the EU Dual-Use Regulation (Regulation (EU) 2021/821), which sets out the common EU list of dual-use items subject to export control in all Member States (the "EU control list"). The amended Annex I will enter into force on the day following that of its publication in the Official Journal, after it clears the standard two-month scrutiny period for the Council and the European Parliament. See the press release here.
What is new on the EU control list
The update aligns the EU control list with 2025 decisions taken within the multilateral export control regimes, namely the Wassenaar Arrangement, the Australia Group and the Nuclear Suppliers Group, as well as additional commitments accepted by EU Member States as participants in the Wassenaar Arrangement. The amended EU control list expands controls to new technology areas, including:
- Semiconductor manufacturing and testing equipment and materials
- Advanced computing integrated circuits (ICs) and electronic assemblies such as ICs incorporating one or multiple Digital Processing Units
- Ceramic Matrix Composites reinforced with mullite, for high-temperature applications
- Rotary encoders based on inductive sensing technology
- Additive manufacturing equipment for energetic materials
- Chemical Vapour Deposition equipment to produce silicon carbide fibres
- Technology for the development of axial compressors of gas turbine engines
In addition, the update adjusts several control parameters and revises technical definitions and descriptions. See the Comprehensive Change Note Summary here.
Relevance for Norway
Norway implements the EU control list as List II to the Norwegian export control regulation (Eksportkontrollforskriften). Once the updated EU control list enters into force, corresponding amendments to List II can be expected, extending export licensing obligations to the additional items and technologies listed above also in Norway.
What businesses should do now
Businesses already subject to export controls under the EU control list should review their existing classifications before the amended Annex I enters into force, as certain items may become subject to different control parameters. Other entities operating in the relevant technology areas covered by the update should assess whether their products, software or technology will become subject to export controls.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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