Update to EU control list of dual-use items enters into force

The updated list of dual-use items subject to export controls in the EU, adopted by the European Commission in September, entered into force on 15 November 2025.

The update brings the list in line with decisions taken in the multilateral export control regimes in 2024: Wassenaar Arrangement (WA), Missile Technology Control Regime (MTCR), Australia Group (AG) and Nuclear Supplier Group (NSG). It also includes commitments that Member States have accepted, as members of the Wassenaar Arrangement, to control additional items uniformly.

The update ensures effective EU-level controls of new technologies and thus contributes to security in the trade of dual-use items in line with the 2024 White Paper on Export Controls. Uniform EU-level controls guarantee effectiveness and transparency while maintaining the Union’s competitiveness and a level playing field for economic operators. Certain items now added to the EU control list have been subject to controls in Finland already since September 2024, as the items are listed in the Annex to the national Act on the Export Control of Dual-Use Items (500/2024).

New dual-use items added to the list

The update to Annex I to the EU Regulation specifically adds the following dual-use items to the control list:

• semiconductor manufacturing and testing equipment and materials (e.g. certain Atomic Layer Deposition equipment, certain equipment and materials designed for epitaxial growth, certain lithography equipment, pellicles specially designed for EUV (Extreme Ultraviolet) lithography)
• electronic assemblies containing programmable logic devices
• certain metal powders used in 3D printing, and
• peptide synthesisers.

The update also provides for modifications of the control parameters and definitions of certain control entries.

Following the update to the EU control list, the following items currently listed in the Annex to the national Act on the Export Control of Dual-Use Items (500/2024)  will be subjected to EU controls:

• items related to quantum technology (e.g. quantum computers, CMOS circuits designed to operate at low temperatures, parametric signal amplifiers, cooling systems, probing equipment designed to test integrated circuits at low temperatures)
• semiconductor manufacturing and testing equipment and materials (e.g. certain Scanning Electron Microscope equipment, dry etching equipment)
• certain 3D metal printing equipment
• coating technology for high-temperature applications
• masks and reticles designed for EUV lithography.

Both the updated Annex I to the EU Regulation and the Annex to the national act contain integrated circuits used specifically for computations related to artificial intelligence (EU: 3A501.a.16, FI: 3A901.c). The control entries in Annex I to the EU Regulation and in the Annex to the national act differ from one another. If an entry in Annex I to the EU Regulation applies to an item, that entry number must be used in export. If only an entry in the Annex to the national act applies, the entry number on the national list will continue to be used.

The appended table describes equivalence between control entries on the national list and the EU list as assessed by the Ministry for Foreign Affairs.