Notice to Exporters 2025/29 – The Export Control (Amendment) (No.2) Regulations 2025

BY:

Steve Berry
11 November 2025

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Notice to Exporters 2025/29, published on November 7th, 2025, communicates advance notice of the Export Control (Amendment) (No.2) Regulations 2025, which will encompass the following updates. 

Dual-Use updates to Council Regulation (EC) No 428/2009, following the European Union's adoption of a Delegated Regulation that updated Annexe I of Regulation 2021/821 on September 8th, 2025.   


Relevant to the controls of specific emerging technologies, the amendment will strengthen export controls for national security purposes. To ensure alignment with EU regulations, avoiding duplication of control in Northern Ireland, where corresponding EU regulations apply directly, the amendment will move controls from Schedule 3 of The Export Control 2008 (S.I. 2008/3231(the ‘2008 Order’) to Annexe I of Council Regulation (EC) No 428/2009.     


There will be an update to Schedule 4 of the Export Control Order 2008 to reflect the removal of the UK Arms Embargo on Armenia and Azerbaijan, which was confirmed on October 29th via Notice to Exporters 2025/08.


Finally, an amendment to Annexes II and III of the assimilated Torture Goods Regulation, to bring controlled items in alignment with the corresponding EU Regulation 2019/125 of the European Parliament and the Council of January 16th, 2019. Annexes II and III already feature within the Human Rights List, located here in “The consolidated list of strategic military and dual-use items that require export authorisation from the United Kingdom”     



The notice states that the intention is to lay out the regulations in November, with them coming into force in December. Regulation will be published on legislation.gov.uk in due course.

Focus on: Controlling Technology & Intangible Transfers

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