EU tightens controls on emerging technologies

Annex I is the common EU list of goods, technology and services that require an export licence because they can be used for both civilian and military purposes ("dual-use" items). It is organised into ten categories, from nuclear materials and electronics to sensors, navigation, marine and aerospace technology, with each category broken down into more specific entries (for example, 6A001 for certain acoustic systems).

The list is amended roughly once a year, based on decisions taken within multilateral export control regimes rather than by the EU alone.

The updated list will not take immediate effect: it must first clear the standard two-month scrutiny period for the Council and the European Parliament, and it enters into force on publication in the Official Journal. Publication is currently expected around November 2026.

What changed in the 2026 update

The update aligns the EU list with 2025 decisions taken in the Wassenaar Arrangement, the Australia Group and the Nuclear Suppliers Group, together with additional commitments EU Member States have accepted as Wassenaar Arrangement participants.

New or expanded controls now cover, among others:

• Semiconductor manufacturing and testing equipment and materials.
• Advanced computing integrated circuits and electronic assemblies incorporating digital processing units.
• Mullite-reinforced ceramic matrix composites for high-temperature use.
• Inductive-sensing rotary encoders.
• Additive manufacturing equipment for energetic materials.
• Chemical vapour deposition equipment for silicon carbide fibres.
• Technology for developing axial compressors used in gas turbine engines.

Beyond these new entries, the amendments also adjust technical control parameters, definitions and descriptions, which may bring items that were previously outside scope within it.

A summary of the amendments is available here.

Relevance for Norway

Norway is not an EU member state but participates in the same multilateral export control regimes and aligns its own control lists with the EU's to maintain a consistent approach across Europe.

In practice, the EU control list is implemented in Norway as List II to the Norwegian export control regulation (Eksportkontrollforskriften), so once the updated Annex I enters into force at EU level, a corresponding update to Norwegian List II can be expected – extending licensing obligations to the additional items above.

What to do now

Companies already subject to export controls should start reviewing their existing product and technology classifications now, since some items may end up with different control parameters once the update takes effect. If necessary, companies should also consider updating internal export control compliance policies and procedures to account for the changes.

Others working in the affected technology areas should assess whether their goods, software or technology will become newly controlled – including intangible transfers such as know-how, design files and certain remote technical assistance. If the abovementioned updates are within the scope of your business, it is recommended that you watch the Official Journal for the exact date the new rules take effect.

Schjødt is ready to assist

Schjødt's corporate compliance team is experienced in all aspects of sanctions and export control-related matters, including risk assessments and associated review of projects, business partners and M&A-activities that may entail an increased sanctions risk. We have an extensive global network consisting of leading compliance and white-collar crime specialists and can efficiently include relevant local knowledge in our assistance.

Please note that this newsletter is provided for general information purposes only and does not constitute legal advice. It does not provide an exhaustive description of the amendments to the EU control list or their implications for any specific business or transaction. Companies should seek tailored advice on how the changes affect their own products, technology and operations. Schjødt's team is ready to assist in this regard.