On September 14, 2026, the European Commission adopted a Delegated Regulation updating Annex I of Regulation (EU) 2021/821, the EU dual-use export control list, aligning it with 2025 decisions of the Wassenaar Arrangement, the Australia Group and the Nuclear Suppliers Group. The update adds semiconductor manufacturing and testing equipment, advanced computing integrated circuits, ceramic matrix composites and several other items to the list that exporters across all 27 Member States must control.
The adopted act amends Annex I, which sets out the items subject to export, brokering, transit and transfer controls in every Member State. Exporters of the newly listed goods must re-classify their products and, where a licence is required, apply through their national licensing authority before the list enters into force upon publication in the Official Journal after the usual two-month Council and Parliament scrutiny period.
What new items enter the Annex I control list?
The 2026 update adds new dual-use items across seven technical families and modifies certain control parameters and technical definitions. Semiconductor manufacturing and testing equipment leads the additions, 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 incorporating one or more Digital Processing Units are now listed, as are Ceramic Matrix Composites reinforced with mullite for high-temperature applications.
| Technical family | New Annex I items |
|---|---|
| Semiconductor manufacturing | Atomic Layer Deposition equipment for molybdenum and ruthenium; EUV mask and reticle development and inspection equipment; single-wafer cleaning equipment |
| Advanced computing | Integrated circuits and electronic assemblies incorporating Digital Processing Units |
| Advanced materials | Ceramic Matrix Composites reinforced with mullite for high-temperature use |
| Sensors | Rotary encoders based on inductive sensing technology |
| Energetic materials | Additive manufacturing equipment for energetic materials |
| Silicon carbide production | Chemical Vapour Deposition equipment to produce silicon carbide fibres |
| Aerospace | Technology for the development of axial compressors of gas turbine engines |
Who must re-classify products and apply for an export licence?
The change directly affects EU manufacturers and exporters of the listed goods, plus non-EU makers selling into the Union. On the semiconductor side, that includes equipment and chip makers such as ASML, Zeiss SMT, Trumpf, Infineon and ASMI, and advanced-computing chip exporters. On the aerospace and defence side, supply chains around Safran, Airbus, MTU Aero Engines, Leonardo and STMicroelectronics must review whether their products, technology and software now fall under a controlled entry.
Each Member State licenses dual-use exports through its national authority: BAFA in Germany via ELAN-K2, the SBDU in France via Egide, UAMA in Italy, and the equivalent bodies elsewhere. Exporters must classify each item against the updated Annex I, apply the catch-all and end-use controls of Regulation (EU) 2021/821 where relevant, and request an individual, global or general export authorisation before shipping. Non-compliance triggers national penalties, for example under the German AWG, the Italian D.Lgs. 64/2012, or the French penal code.
When does the updated list enter into force?
The list does not apply yet. As a delegated act under Article 290 TFEU, the Regulation is now subject to a two-month scrutiny period during which the Council and the European Parliament may object. If neither objects, it enters into force on the day it is published in the Official Journal of the European Union. Exporters should treat the adoption date as the trigger to begin classification work, because the two-month window can close quickly and licensing lead times for newly controlled items are unpredictable.
The Delegated Regulation in the documents register and the base act on EUR-Lex set out, respectively, the amending text and the catch-all, end-use and human-rights controls that frame how the new Annex I items are enforced.
How does this fit the wider export-control alignment?
The update implements commitments taken in the 2025 plenaries of the Wassenaar Arrangement, the Australia Group and the Nuclear Suppliers Group, the three multilateral regimes whose lists the EU mirrors each year through a delegated act. It also advances the 2024 EU White Paper on Export Controls, which presses for stronger EU-level controls on emerging technologies to keep a level playing field across Member States. For exporters, the EU list now tracks the global semiconductor and advanced-computing control push already visible in US BIS rules, Dutch ASML controls and Japanese METI measures. For compliance teams, the practical value of continuous, per-jurisdiction monitoring is catching such a list update the day the Commission adopts it, not the day it binds.
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Next steps: pull the Comprehensive Change Note Summary from the Commission release, map the new Annex I entries against your product and technology portfolio, confirm classifications with your national licensing authority, and brief engineering and sales teams on items that newly require a licence. Obsidian follows this dossier across the 27 Member States as the scrutiny period runs.
