The European Commission has updated its lists of dual-use items by adopting Regulation 2016/1969 of September 12, 2016, amending the EU Dual-Use Regulation. Dual-use items are items that can be used for both civil and military purposes; they are subject to controls for exports outside of the EU territory and, in rare circumstances, for intra-EU exports. The lists of dual-use items are regularly updated to take account of changes to control lists maintained by international non-proliferation regimes and export control arrangements.
Among the numerous changes made to the lists, the most notable are:
- New controls for:
- Electronic equipment performing high-speed, analog-to-digital conversions
- Software for the operation and maintenance of guidance sets
- Gel propellant rocket motors
- Certain chemicals
- Two viruses, the SARS-related coronavirus and the Reconstructed 1918 influenza virus
- Removal of certain controls, such as those on aerospace/missile seals, hydraulic fluids and underwater cameras
- Changes to the control of laser measuring systems
The European Commission has published a summary of the changes to the control lists, which entered into force last week.
Companies exporting dual-use items should verify whether their exports will be impacted by the changes to the lists. Non-compliance with EU export controls rules can have serious criminal, financial and reputational consequences for companies and their employees.
If you have any questions regarding this Sidley Update, please contact the Sidley lawyer with whom you usually work, or
| Arnoud R. Willems Partner awillems@sidley.com +32 2 504 6409 |
Sven De Knop Partner sdeknop@sidley.com +32 2 504 6468 |
Yohan Benizri Associate ybenizri@sidley.com +32 2 504 6406 |
Justine Fassion Associate justine.fassion@sidley.com +32 2 504 6487 |
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