Dual-use & export control check

EU export controls do not only catch exporters. Returns, repairs, samples, equipment to your own subsidiary abroad, software by e-mail -- all of it is export, and the dual-use list reaches deep into civilian product ranges: machine tools, chips, sensors, lasers, drones. Describe what you ship and see which of the ten Annex I categories it could touch, and whether the catch-all or a sanctions destination changes the picture. Runs in your browser; nothing is sent anywhere.

This is a keyword triage against the common category names, written and maintained here; it does not read parameters (performance, precision, end-use), and it cannot classify an item. The legal text is Annex I of Regulation (EU) 2021/821; the binding answer on a specific item comes from the national licensing authority. Checked 2 October 2026.

The ten categories, one line each

0 -- nuclear and weapons-related items.

1 -- special materials: high-performance metals, alloys, composites, ceramics.

2 -- materials processing: machine tools and production equipment.

3 -- electronics: chips, compound semiconductors, test equipment.

4 -- computers: very high performance machines.

5 -- telecommunications and information security: cryptography, secure hardware, cyber-surveillance.

6 -- sensors and lasers: thermal cameras, motion sensors, lasers.

7 -- navigation and avionics: inertial navigation, GNSS receivers, aircraft electronics.

8 -- marine: underwater systems, sonar, propulsors.

9 -- aerospace and propulsion: aircraft parts, engines, propellants, unmanned aircraft.

The full text of each category, with the parameters that decide control, is Annex I of Regulation (EU) 2021/821 in EUR-Lex. The list is amended regularly -- read the consolidated version, not a copy.

The catch-all: controlled even when unlisted

Article 4 of the regulation keeps a second filter behind the list. You may not export an item -- listed or not -- when your authority informs you it is or may be intended for weapons of mass destruction, or for military end-use in an arms-embargoed destination; and when circumstances give you grounds for suspicion, you must inform the authority yourself and wait. In practice: a strange end-user story, a freight forwarder as consignee, an unusual routing, or a buyer who cannot explain what the item is for -- that is the moment to stop and ask, not to ship and hope.

Screen the counterparty before that question arises: the sanctions screening on this site covers the lists that bind an EU trader, and the counterparty check pairs it with VAT and registry verification.

Questions importers actually ask

I only import into the EU. Why would export controls concern me?

Because 'export' is wider than selling abroad. Sending a defective batch back, shipping a sample to a trade fair, returning repaired equipment, moving a test rig to your own subsidiary outside the EU, e-mailing software or drawings abroad -- all of it is export, including intangible transfers by electronic means. The scope sits in Article 2 of Regulation (EU) 2021/821.

What is the difference between dual-use and military items?

Dual-use goods are civilian goods with a plausible military or proliferation use -- machine tools, chips, lasers, drones. They are listed in Annex I of the dual-use regulation and licensed by your national authority. Military goods are weapons and dedicated military equipment; they follow the military export controls and the Common Military List instead. One product can be neither, either or -- in assembled systems -- both.

What is the catch-all, in plain words?

Article 4: even an item that is on no list may not be exported when you are informed by your authority that it is or may be intended for weapons of mass destruction or (in sanctioned contexts) military end-use -- and when there are grounds for suspicion, you must inform the authority and may not export without its go-ahead. The list is the first filter; the end-use question is the second.

My product is just software. Does that count?

Yes: technology and software are controlled exactly like hardware when they are 'specially designed' for controlled items, and transferring them by e-mail or cloud access is an export -- the intangible transfer. Many everyday cryptography products have been decontrolled in recent amendment rounds, but cyber-surveillance and end-use concerns are not part of that relief.

Who grants the licence, and where do I read the actual list?

Licences come from the national licensing authority of the member state where you are established -- the European Commission keeps the list of authorities. The legal text of the categories is Annex I of Regulation (EU) 2021/821 in EUR-Lex; this page's keyword check is a reading aid to it, not a replacement.

How do sanctions interact with this?

Sanctions can ban exports that the dual-use regulation would allow, and they add their own lists -- the trade annexes of the Russia regulation, for instance, ban a range of components outright. And whoever the end user is: screen the name. The sanctions screening on this site covers the lists that matter to an EU trader.