The European Union has published the update to the dual-use goods control list, Annex I of Regulation (EU) 2021/821. This update, released on September 14, 2026, aligns with decisions from multilateral export control regimes such as the Wassenaar Arrangement and the Australia Group.
The new list includes items such as semiconductor manufacturing and testing equipment (ALD, EUV), advanced computing integrated circuits, ceramic matrix composites (CMC), inductive rotary encoders, additive manufacturing equipment for energetic materials, CVD equipment for silicon carbide (SiC) fibers, and technology for axial compressors in gas turbine engines. Control parameters and technical descriptions have also been modified.
According to the analysis by the trade service of the Chamber of Commerce of Manresa, the update focuses on the semiconductor and advanced materials value chain. Exporting SMEs must review their product classifications, as exporting a listed good without a license constitutes an infringement.
Practical consequences include reviewing product catalogs, considering components and sub-assemblies, and technology and software transfers. The two-month scrutiny period before entry into force is crucial for conducting this review.
Sectors in the Manresa region potentially affected include metallurgy and precision machining, advanced materials and technical ceramics, electronics and instrumentation, industrial equipment and additive manufacturing, and engineering and technical services.
The competent authority for export licenses in Spain is the Secretariat of State for Trade. The Chamber of Commerce of Manresa can provide guidance on the procedure, but the binding classification rests with the competent authority.
