On 14 September 2026, the European Commission adopted a Delegated Regulation amending Annex I of Regulation (EU) 2021/821—the EU's dual-use export control list. The update introduces new controls on several emerging and strategically significant technologies, aligning the EU's controls with Member States' commitments within the Wassenaar Arrangement, the Australia Group, and the Nuclear Suppliers Group.
Summary of the Changes
The 2026 update adds a number of items to Annex I across several technology clusters. These include:
- Semiconductor manufacturing and testing equipment and materials, including atomic layer deposition equipment for molybdenum and ruthenium, equipment for the development and inspection of extreme ultraviolet masks and reticles, and single-wafer cleaning equipment;
- Advanced computing integrated circuits and electronic assemblies such as integrated circuits incorporating one or more 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; and
- Technology for the development of axial compressors of gas turbine engines.
Beyond these new control entries, the amendments also modify certain technical control parameters, definitions and descriptions. These changes can bring previously uncontrolled items within scope.
The Delegated Regulation has been adopted but is not yet in force. It is subject to the usual two-month scrutiny period during which the Council and the European Parliament may raise objections. The updated control list will enter into force upon publication in the EU's Official Journal, which is expected in November 2026.
Commentary
The sectors most directly affected by this update are semiconductor manufacturing, advanced computing, advanced materials, additive manufacturing, and aerospace and propulsion engineering. That said, all exporters should consider taking the following steps ahead of the entry into force of the updated list:
- Review whether goods, software or technology fall within the updated list and determine whether new or amended controls will require export licences, and engage early with national competent authorities. In particular, consider the impact on intangible technology transfers: development know-how, design files, and certain forms of remote technical assistance may also be controlled.
- As necessary, update internal export control compliance policies and procedures to account for the changes.
- Monitor the legislative timeline for publication of the Delegated Regulation in the Official Journal, as this will trigger the legal effective date.
Author: Andris Ivanovs, Partner.
