- The European Commission has published the first Summary of national control lists, which allows EU Member States to impose authorization requirements for the export of dual-use items not listed in Annex I to the EU Dual-use Regulation but included in other Member States’ national lists.
- National control lists contain descriptions of controlled products that may require authorization for export.
- The publication of the Summary means the possibility of extending export controls to dual-use products not listed on the basic EU Checklist.
- The published List currently includes national control lists published in 2023 by the Netherlands and Spain, including selected devices used to produce semiconductors or quantum computers and related electronic assemblies.
- This will likely increase compliance burdens for exporters and additional risks that will have to be taken into account at the stage of export-compliance analysis of individual export transactions.
Source Deloitte
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