Perkins Coie·SANCTIONS / EXPORT CONTROLS

EU Commission Adopts Updated Dual-Use Export Control List

A new Delegated Regulation adds controls on emerging technologies including advanced semiconductors, computing components, and aerospace materials.

The European Commission adopted a Delegated Regulation on September 14, 2026, that amends the EU’s list of controlled dual-use goods, software, and technology. The update formally aligns the EU’s export control regime with its commitments to international non-proliferation arrangements, including the Wassenaar Arrangement and the Australia Group. The new controls target emerging and strategically significant technologies, most notably in the semiconductor manufacturing, advanced computing, aerospace, and advanced materials sectors. Specific additions include certain types of atomic layer deposition equipment, advanced computing integrated circuits, and ceramic matrix composites. The amendments also modify technical parameters for existing controls, which may bring previously uncontrolled items within scope. Companies exporting from or within the EU, particularly in the tech and aerospace industries, must now review their products and technology against the updated list to determine if new export licenses are required. The regulation is subject to a two-month scrutiny period by the Council and Parliament and is expected to enter into force in November 2026.

export-controlsdual-useeuropean-uniontechnologysemiconductorsinternational-trade
Read the original firm alert → Wednesday, September 23, 2026

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