EU Trade Policy Developments Since 1 January 2026
- Dual‑Use and Defence Export Controls — Updated EU Dual‑Use List – Emerging Technologies Focus
A major update to Annex I of the EU Dual‑Use Regulation (Regulation (EU) 2021/821) took effect via an implementing regulation on 15 November 2025, but its operational impact is being felt throughout 2026, particularly for high‑tech exporters.
The update:
– Incorporates the latest decisions from the Wassenaar Arrangement, MTCR, Australia Group and NSG.
– Expands controls on critical and emerging technologies, including: Advanced materials – e.g. high‑entropy alloy powders (entry 1C513) and updated nickel alloy controls for gas turbines; Additive manufacturing – new controls on metal alloy additive manufacturing equipment (entry 2B510) and related technologies; Biotech – e.g. expanded controls on peptide synthesizers (2B352.j); Semiconductor manufacturing – extensive new entries for EUV lithography equipment and tools, epitaxial growth equipment, etching and deposition equipment, specialised SEMs and cryogenic wafer probing tools (various 3B5xx and 3C5xx entries); Advanced computing / quantum – new controls on quantum computers (4A506) and quantum‑related electronics (e.g. quantum‑limited amplifiers, cryogenic CMOS).
2026 is the first full year in which exporters must fully operate under this updated list, requiring:
Re‑classification exercises;
Licence reviews for items newly‑captured; and
Updated internal compliance programs, especially in semiconductors, quantum, advanced materials, biotech and aerospace.
EU Defence Export Control List – New Directive (2026)
On 18 February 2026, the EU published a directive updating the list of military goods subject to export controls in the Official Journal.
Member States must:
“Adopt and publish” implementing laws and regulations by 31 May; and
Apply those provisions from 5 June.
This effectively updates national military‑list controls across the EU in mid‑2026; exporters of defence items must review national transposition measures and licence needs.
