The EU has adopted new export controls on a range of emerging technologies (including quantum technologies, semiconductor manufacturing equipment, advanced computing, advanced materials and coatings for high temperature applications, additive manufacturing and certain life sciences tools), under the new “500-series” of EU-only controls.
The update to the EU’s Dual-Use Export Control List, which incorporates the new 500-series items along with other amendments to definitions and control parameters, entered into force on November 15, 2025, via Commission Delegated Regulation (EU) 2025/2003, which amends Annex I to Regulation (EU) 2021/821 (the EU Dual‑Use Regulation).
The UK will also be adopting similar 500-series control list entries in the UK’s assimilated Dual-Use Regulation via the Export Control (Amendment) (No. 2) Regulations 2025 (noting the UK has already adopted certain related controls previously), which will come into force on December 16, 2025, and broadly ensure alignment between the UK and EU regimes.
Background and International Context
- Progress at the Wassenaar Arrangement on Export Controls for Conventional Arms and Dual-Use Goods and Technologies has been effectively stalled due to Russia’s veto of new Wassenaar dual-use listings since 2022. As a result, controls on technologies widely viewed by the EU, U.S. and UK as strategically sensitive (in particular quantum, advanced semiconductor tools and additive manufacturing) could not be agreed upon on at the multilateral level.
- In response, several EU Member States (including the Netherlands, Germany, Italy, France and Finland, amongst others) introduced national controls on emerging technologies, which generated regulatory divergence within the EU. To eliminate internal fragmentation and maintain pace with international partners (including the UK and U.S.), the Commission advanced EU-level action in September to adopt EU-wide controls for items that could not be agreed at Wassenaar but enjoy broad EU and international-partner support, which were formally adopted at the EU level in November.
- The update to the EU’s Dual-Use Export Control List also reflects a deliberate move to align with parallel U.S. and UK tightening on exports of emerging technologies. The U.S. has already expanded controls on quantum computing items, advanced semiconductor manufacturing equipment and related high-performance technologies previously, while the UK in 2024 introduced, and is now replacing, its own national emerging technology entries (control entries PL9013-9015) with its version of the 500-series to mirror the updated EU list. For companies operating across the EU, U.S. and UK, the regulatory direction is converging, but the substantive scopes are not identical, requiring coordinated multi-jurisdictional classification and licensing analysis.
Compliance Impact
For most emerging technology items, the new EU controls largely replace the national controls previously adopted by Member States, though some limited national measures may remain in place.
The updated EU controls require companies to reassess product classifications across the in-scope emerging technologies. Given the parallel expansion of U.S. and UK controls, exporters should map their portfolios against all three regimes to identify divergences in scope and thresholds.
Companies operating in multiple EU Member States should also confirm whether previously applicable national controls continue to apply and whether the move to EU-level controls allows for the use of EU General Export Authorisations (GEAs), which can simplify licensing for transfers to certain destinations (including, for example, EU001, which permits exports of most Annex I dual-use items including the newly added emerging-technology entries to the U.S., UK, Canada, Japan, Australia, New Zealand, Norway and Switzerland).
The update to the EU’s Dual-Use Export Control List represents a substantive recalibration of export controls on emerging technologies and will require companies across sectors to reassess their compliance posture.