The EU Commission Recommends Member States' Data Sharing on Dual Use Export Controls

BY:

Gail Leeson
23 April 2025

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The EU Commission has released a recommendation proposed initially in the January 2024 White Paper on Export Controls, aimed at enhancing coordination and communication between the EU Member States of their national control lists of dual-use items.  

Dual-use controls can apply to goods and technology with high specifications that can be used in civil, military, or other controlled or sanctioned regimes.  The national control lists stem from internationally agreed conventions and arrangements. 


The Commission Recommendation is a set of voluntary standards, guidelines, and a coordination mechanism where pertinent dual-use control information can be shared on a voluntary basis between EU Member States.   


It also outlines key principles for aligning national dual-use control lists with EU and multilateral agreed standards.  


Export controls are subject to national security regulations and restrictions; therefore, the recommendation could only be for implementation voluntarily by each member state, and with possible national member state conditions. 


The EU has advised that implementation of the recommendations in the paper would promote a more integrated and unified EU approach towards global export control issues. 


Links to the Commission Recommendation can be found below: 

Commission Recommendation (EU) 2025/683 on coordination of national control lists 


The White Paper on which the recommendations are based can be found below: 

White Paper on export controls - 24 January 2024 


Details of the EU Trade Policy on the export of dual-use items can be found below: 

Exporting dual-use items 


The UK Strategic Export Control lists and links to the UK Export Control legislation can be found here: 

UK strategic export controls - GOV.UK 


If you are interested in exploring this topic further, you might find it worthwhile to consider the training courses and live clinics offered by Strong & Herd LLP:

Focus On: Dual Use Export Compliance - The Dual-Use Exporter

This full-day session focuses on dual-use regulations, a topic relevant to many industry sectors. With licences required for dual-use items moving between the UK and EU, the need to understand this topic has grown significantly. The controls are based on an item’s inherent capability, type of materials, or technical ability, affecting many industry sectors.

Beginners Guide to Export Licensing Controls

Whether at the start of your learning pathway or as a standalone training session, this course will equip you with the necessary knowledge to understand export licensing controls and how they work. Covering essential elements provides a solid foundation for understanding what goods, technology or software could be controlled and reviewing business-relevant areas in more detail.

The UK Export Licensing System

This course combines the key elements of the UK Export Licensing System into a practical session. By reviewing the UK strategic export control lists and the legislation surrounding financial sanctions, delegates will gain a comprehensive foundation of knowledge to support future learning and understand internal requirements.

Applying for and Using UK Export Licences

This practical session provides the necessary information for applying for individual licences and helps you determine when an open licence is suitable for specific movements or transfers of controlled items. The workshop is designed to instruct participants on using the UK export licensing system.


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