The EU is updating the dual-use list, the bloc's common list of items that are subject to export controls in all EU member states. The updated list reaches beyond the usual calibration of individual technical parameters and expands into fields such as quantum computing, semiconductors, advanced materials and biotechnology. The update is expected to enter into force before the end of 2025 and calls on EU operators to update their compliance programms.
Quantum technologies
Guided by its European Economic Security Strategy, the EU considers quantum technology to be a critical technology, alongside semiconductors and artificial intelligence and is preparing coordinated risk assessments and new guardrails to manage security concerns. The revised dual-use list is set to cover:
- Quantum computers;
- Electronic components designed to work at cryogenic temperatures;
- Parametric signal amplifiers;
- Cryogenic cooling systems; and
- Cryogenic wafer probers.
The importance of quantum technology – and the need to control its export – is also highlighted in the EU’s Quantum Europe Strategy and EU initiatives like European Quantum Communication Infrastructure (EuroQCI). The Commission has also urged more coordinated use of the Dual-Use Regulation as part of its economic-security follow-up.
Semiconductors and advanced computing
The upcoming update is also set to capture a broad set of semiconductor manufacturing and testing equipment, including:
- Atomic Layer Deposition (ALD) equipment;
- Epitaxial deposition tools and materials;
- Lithography systems (including EUV pellicles, masks, and reticles);
- Scanning Electron Microscopes (SEM) for wafer inspection; and
- Etching equipment.
On the design side, advanced computing integrated circuits and assemblies (e.g. Field Programmable Logic Devices or FPGAs) are explicitly included.
This approach is consistent with the EU’s Economic Security Strategy, which elevates semiconductors to the status of critical technologies requiring coordinated risk assessment and protective measures. It also resonates with global developments, including US efforts under the CHIPS Act and Science Act and recent Bureau of Industry and Security rules tightening controls on advanced logic chips, though the EU framework remains distinct and tailored to its own regulatory context.
Other changes
The new list broadens controls in areas less headline grabbing but equally significant, and companies active in these areas should carefully evaluate the need to adapt their export control compliance:
- 3D-printing: Additive manufacturing equipment and materials;
- Aerospace and energy systems: High-temperature coatings;
- Biotechnology: Peptide synthesisers.
In the aerospace sector, the new, broader definition of spacecraft effectively widens the scope of the dual-use list whereas the definitions for specific space vehicles provides additional guidance.
The update also introduces changes concerning the terminology, technical definitions and parameters. While these changes might appear minor, companies are well advised to carefully assess their impact on the business. As always with export controls, the devil is in the details and seemingly small changes can have far-reaching compliance consequences and impact supply chains.
Conclusion
The 2025 update to the EU dual-use list as proposed in the Commission's Delegated Regulation of 8 September 2025 is more than a technical revision of individual parameters and specifications. It is a step in the EU’s effort to expand export controls into a broader economic security toolkit, which treats quantum technologies, semiconductors, advanced materials and biotechnology as strategic domains rather than neutral industrial sectors. Companies active in these sectors should adapt their export control compliance processes before the changes enter into force before the end of 2025.
With significant investments flowing into R&D in these areas, it is important to note that intangible technology transfers, research collaborations and emerging applications in these strategic sectors may also trigger authorisation requirements.
The EU Parliament and the Council of the EU can now raise objections to the new dual-use list within two months. Objections, however, are rare and the changes are expected to be implemented. EU operators are advised to begin assessing how the revised controls may affect their activities and to start updating their internal compliance programmes.
For more information on how to make your company compliant, contact your CMS client partner or the authors.
