Publication of the updated Annex I to Regulation 2021/821 for 2025

On 14 November 2025, the European Commission published the 2025 update of the EU Control List of Dual-Use Items.[1]

Adopted by the Commission on 8 September 2025 to reflect decisions taken within the Multilateral Export Control Regimes in 2024 and to address evolving technological and proliferation risks that could not be unanimously agreed in those fora but were endorsed by EU Member States, the Commission Delegated Regulation (EU) 2025/2003 was published in the Official Journal of the EU on 14 November, following the two-month period during which the European Parliament or the Council could raise objections.

By virtue of its article 2, the Commission Delegated Regulation enters into force on the day following that of its publication in the Official Journal of the EU (i.e., 15 November 2025).

The update includes the following additions and changes:[2]

• Quantum technology: Quantum computers, electronic components designed to work at cryogenic temperatures, parametric signal amplifiers, cryogenic cooling systems, cryogenic wafer probers.
• Semiconductor manufacturing and testing equipment and materials: Atomic Layer Deposition equipment, equipment and materials for epitaxial deposition, lithography equipment, Extreme Ultra-Violet pellicles, masks and reticles, Scanning Electron Microscope equipment, etching equipment.
• High-performance Integrated Circuits: Advanced computing integrated circuits such as field programmable logic devices (FPLD).
• High-Temperature Coatings: materials for extreme thermal environments.
• Additive manufacturing: 3D printing systems for metals and associated materials (e.g., high entropy alloy or refractory metal and alloy powders).
• Peptide synthesizers: equipment used in biotechnology for the synthesis of peptides.
• Modification of certain control parameters and update of certain technical definitions and descriptions.

[1] Commission Delegated Regulation (EU) 2025/2003 of 8 September 2025 amending Regulation (EU) 2021/821 of the European Parliament and of the Council as regards the list of dual-use items, C/2025/5947, OJ L, 2025/2003, 14.11.2025. Available here.

[2] European Commission, 2025 Update of the EU Control List of Dual-Use Items. Available here.