Updates to the EU Dual-Use Export Control List

On 8 September 2025 the European Commission announced updates to the EU Dual-Use List (as set out in Annex I of Regulation 2021/821).

While some of these updates reflect international decisions taken in 2024 by multilateral export control regimes (including the Wassenaar Arrangement (WA), Missile Technology Control Regime (MTCR), Australia Group (AG) and Nuclear Suppliers Group (NSG)) and are part of the European Commission’s annual review process, others – such as those in relation to semiconductor equipment – are unilateral and impose brand new controls on emerging technologies.

Key Changes

The 2025 amendments include a number of new entries to the EU Dual-Use List, including:

• Quantum technology (control entries 4A506, 3A501.b.13, 3A504, 3B504). This includes quantum computers, cryogenic components, parametric signal amplifiers, cryogenic cooling systems and cryogenic wafer probes.
• Semiconductor equipment, including manufacturing, testing equipment and materials.
  • Importantly, there are new control entries for semiconductor manufacturing equipment, including Atomic Layer Deposition (ALD) equipment (control entry 3B501.n) which is not currently covered by the UK Dual-Use List. This control entry includes the following:
    • Equipment designed for the deposition of tungsten to fill an entire interconnect or in a channel less than 40 nm wide;
    • Equipment designed for 'area selective deposition' of a metal or metal nitride sidewall barrier using an organometallic compound precursor;
    • Equipment designed for the deposition of a 'work function metal' composed of titanium aluminium carbide (TiAlC) and having a work function greater than 4,0 eV;
    • Equipment designed for cobalt electroplating or cobalt electroless-plating deposition processes;
    • Equipment designed for Chemical Vapour Deposition (CVD) of cobalt fill metal;
    • Equipment designed for 'selective bottom-up' Chemical Vapour Deposition (CVD) of tungsten fill metal;
    • Equipment designed for void-free plasma enhanced deposition of a layer with a dielectric constant less than 3,3, in 'gaps' having an 'aspect ratio' equal to or greater than 1:1 and a width less than 25 nm;
    • Equipment designed for the deposition of a ruthenium layer using an organometallic compound precursor, while maintaining the wafer substrate at a temperature greater than 293,15 K (20°C) and less than 773,15 K (500°C);
    • Equipment designed for multistep processing in multiple chambers and maintaining high vacuum or inert environment during transfer between process steps; and
    • Equipment designed to fabricate a metal contact by multistep processing within a single chamber.
  • The EU Dual-Use List will now also include pellicles specially designed for Extreme Ultraviolet (EUV) lithography, as well as equipment designed for epitaxial growth of silicon (Si) or silicon germanium (SiGe). These entries are also not currently included on the UK Dual-Use List.
• Advanced computing components. The new control entries include integrated circuits and electronic assemblies (such as Complementary Metal Oxide Semiconductor (CMOS) integrated circuits, Scanning Electron Microscope (SEM) equipment and software designed to extract GDSII or equivalent standard layout data Gate-All Around Field-Effect Transistor (GAAFET) structures).
  • While some of the new control entries are identical to those included on the UK Dual-Use list updated in May 2025 (please see our previous briefing here), some of the newly controlled equipment (such as electronic assemblies, modules or equipment, containing user configurable Field Programmable Logic Devices (FPLDs) under EU Dual-Use entry 3A502.i) is not currently covered by the UK export controls.
• High-temperature application coatings.
  • The new control entries include nickel alloys for aero, aero-derivative, industrial or marine gas turbine engines.
  • EU export controls will now also extend to technology for the development or production of certain high-temperature coating systems (control entry 2E503.g).
  • While most of these new control entries are identical to those included on the UK Dual-Use list updated in May 2025, some of the newly controlled alloys (such as high-entropy alloys or refractory metal and alloy powders) are not currently subject to UK export controls.
• Peptide synthesisers that are automated and capable of generating peptides at a system synthesis scale of 1mmol or greater.

Some technical amendments providing updates to definitions and control parameters were also made to improve clarity and consistency such as updating the carbon content of maraging steels specified from “very low” to “less than or equal to 0.03% by weight”. This includes editorial changes to technical notes and refined terminology.

Implementation Timeline

The new controls will enter into force following the usual two-month scrutiny period for the European Council and European Parliament, allowing stakeholders to assess the impact and prepare for compliance.

Impact on Business

Exporters across the EU should review the updated list to determine whether their products now fall under the revised controls. This is particularly relevant for companies operating in quantum computing, semiconductor manufacturing and biotechnology fields.

It is important to emphasize that some of the new control entries represent unilateral controls by the EU on items, including certain semiconductor manufacturing equipment, which are not currently subject to UK export controls. This misalignment may reflect a broader shift away from streamlining controls across jurisdictions to unilateral and protectionist measures impacting emerging technologies. For businesses trading globally and impacted by these new entries, it will be important to identify the differences between the relevant control lists and to obtain appropriate licences to continue cross-border trade.