#52026XC02595EU overview of national controls on dual-use exports and cyber-surveillance items
AI-generated summary for informational purposes only. Not legal advice. See the original source for the authoritative text.
This notice maps how EU Member States apply extra national controls under the EU dual-use export control regime. It shows which countries require licences for exports, brokering, transit, technical assistance or transfers involving non-listed dual-use items, including cyber-surveillance tools, when there is a suspected link to weapons, military end-use, internal repression, or serious human rights abuses. Exporters, brokers, logistics providers, technology suppliers and compliance teams should not rely only on the EU Annex I control list. They need to check national rules in each Member State involved in a transaction, especially where goods or technology could have sensitive end-uses even if they are not listed EU-controlled items.
AI-generated summary. May contain errors. Refer to official sources for legal decisions.
Key Changes
- Publishes a consolidated EU overview of Member State measures under Regulation (EU) 2021/821.
- Identifies which Member States require authorisation for non-listed dual-use exports and cyber-surveillance items where sensitive end-use is suspected.
- Covers national extensions for brokering, transit, technical assistance, and transfers, so compliance checks must include Member State rules as well as EU rules.
Obligations
What this law requires
Before exporting non-listed dual-use items from an EU Member State that has adopted Article 4(3) controls, obtain an export authorisation where the exporter has grounds to suspect the items are or may be intended, wholly or partly, for the end-uses referred to in Article 4(1) of Regulation (EU) 2021/821.
Exporters operating from Belgium's Flemish or Walloon Regions must obtain an export authorisation for non-listed dual-use items when they have grounds to suspect the items may be intended for Article 4(1) end-uses.
Exporters in Member States identified as applying Article 5(3) controls must obtain an export authorisation for non-listed cyber-surveillance items where they have grounds to suspect the items may be intended for internal repression or serious human rights or international humanitarian law violations.
Exporters in Bulgaria must obtain an export authorisation for dual-use items not listed in Annex I where the conditions of Articles 4, 5, 9 or 10 of Regulation (EU) 2021/821 are met for relevant destinations.
Exporters in Denmark, Ireland, Croatia, Italy, Romania, Hungary, Slovenia or Sweden must obtain an export authorisation for non-listed cyber-surveillance items if they have grounds to suspect the items are or may be intended for Article 5(1) uses.