EU export control update: New licensing requirements for critical technology

In this blog, the Corporate Crime & Business Integrity team of NautaDutilh provides a clear overview of the new additions to the EU dual-use list, covering goods and technologies with both civilian and military purposes, and examines the geopolitical context behind this development.

What has changed?

The delegated act adopted on 8 September 2025, introduces several new technologies to the list of dual use goods, including:

Quantum computers and cryogenic cooling systems

Semiconductor manufacturing machines and integrated circuits

Coating for high-temperature applications

3D printers

Peptide synthesisers

Membranes for chip production (pellicles for EUV lithography)

From November 2025, companies exporting goods related to these technologies must obtain an export license before shipping relevant goods outside the EU .

From multilateral consensus to EU autonomy

The EU regularly amends its dual-use items list (Annex I of Regulation (EU) 2021/821), traditionally following consensus within multilateral export control regimes such as Wassenaar Arrangement, the Missile Technology Control Regime, the Australia Group, and the Nuclear Supplier Group. However, geopolitical tensions have recently hindered this process, with some states – especially Russia – blocking EU-backed updates.

Confronted by this gridlock, the European Commission sought an alternative approach. In its 2024 White Paper on Export Controls, the Commission expressed the need for a swift and effective solution to bolster EU security. Although a legislative proposal under the ordinary procedure was considered, it was ultimately deemed too time-consuming, given the urgency of expanding the dual-use items list. Individual member states would have needed to implement their own interim controls, risking inconsistency across the EU single market and exposing member states to geopolitical pressure, as evidenced by the Netherlands’ experience with advanced semiconductor export controls.

To avoid these pitfalls, the Commission opted for the delegated act, which allows for prompt updates based on commitments made by EU member states. This process enables the EU to react rapidly and independently to evolving geopolitical circumstances, without being hampered by the need for unanimous international agreement.

What does this mean for businesses?

If your company exports any of the newly controlled technologies, immediate action is essential to ensure compliance before the November 2025 deadline. We recommend the following steps:

Review your product portfolio: Conduct a thorough audit to determine whether your products, software, or technology now fall under the updated list.

Assess licensing requirements: Determine if new export licences are required for your existing or planned shipments.

Monitor further developments: The EU’s shift towards autonomous updates means export controls may change more frequently. Establish procedures to track regulatory changes and adapt your compliance programmes accordingly.

“Companies should review their internal compliance procedures promptly and secure the necessary export licences before November 2025 to avoid disruptions or penalties.” Simone Honig, partner Corporate Crime & Business integrity

Companies exporting the newly listed technologies should review their internal compliance procedures promptly and secure the necessary export licences before November 2025 to avoid disruptions or penalties.