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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
- 3C507and3C509: 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 2025before 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.
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.
