The recent European Commission updates to the EU dual-use export control list mark a historic change in the EU’s export control policy. Additions to the dual-use export control list are not rooted in any of the multilateral export control regimes and reflect the EU’s growing emphasis on economic security within its trade policy. On September 8, 2025, the Commission adopted a Delegated Regulation updating the EU dual-use export control list in Annex I of Regulation (EU) 2021/821 (the “EU Dual-use...
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