REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the implementation of Regulation (EU) 2021/821 setting up a Union regime for the control of exports, brokering, technical assistance, transit and transfer of dual-use items
Date: 2025-01-30
Institutions: Directorate-General for Trade and Economic Security, European Commission
Subjects: customs regulations, dual-use good, export (EU), export monitoring, intra-EU trade, technical cooperation, trade restriction, transit

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 30.1.2025  COM(2025) 19 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the implementation of Regulation (EU) 2021/821 setting up a Union regime for the control of exports, brokering, technical assistance, transit and transfer of dual-use items {SWD(2025) 8 final}  
 
 
REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND 
THE COUNCIL 

on the implementation of Regulation (EU) 2021/821 setting up a Union regime for the 
control of exports, brokering, technical assistance, transit and transfer of dual-use items 

1. 

INTRODUCTION 

This  report  provides  information  on  the  implementation  of  EU  export  controls  and  the 
modernised Regulation (EU) No 2021/821 of 19 May 2021 (‘the Dual-Use Regulation’ or ‘the 
Regulation’)1  for  dual-use  items  covering  the  period  of  2022-2023,  as  well  as  certain  key 
developments in 2024, together with the EU aggregated and Member States’ export control data 
for 2022.  

This is the first annual report prepared under the terms of the Regulation, which entered into 
force on 9 September 2021. It marks an important milestone in the development of EU export 
control policy through more information sharing on Member States’ licensing decisions in the 
area of export controls with the objective of increased transparency in this area.  

As required under the Regulation and in order to enable the enhanced data collection process, 
on 17 January 2024, the Commission published Guidelines agreed with the Member States on 
data gathering and processing on export controls (transparency guidelines)2. These guidelines 
have allowed Member States to gather statistics in view of the preparation of the EU’s annual 
report  on  dual-use  export  controls.  In  this  context,  the  Commission  launched  a  stakeholder 
consultation on how data is collected around export controls from 27 January until 28 February 
2023. Against this background, this report was prepared by the Commission with input gathered 
from Member States3 in the Dual-Use Coordination Group (DUCG). Due to their volume, the 
data for year 2022 provided by Member States are presented in a consolidated format in the 
Staff Working Document that accompanies this annual report. This report will be supplemented 
by the publication of the data for year 2023 separately as a Staff Working Document in the first 
quarter of 2025.   

The  period  covered  by  this  report  has  witnessed  a  great  shift  in  the  geopolitical  landscape. 
Russia’s war of aggression against Ukraine as well as the widening conflict in the Middle East 
have only  served to  highlight the importance of effective  controls  on the export of dual-use 
items and such controls have been an increasingly important part of  the Commission’s response 
to geopolitical developments, notably through sanctions. At the same time the period has also 
seen the increasing unilateral use of export controls outside the scope of international regimes, 

1 Regulation (EU) 2021/821 of the European Parliament and of the Council of 20 May 2021 setting up a Union 
regime for the control of exports, brokering, technical assistance, transit and transfer of dual-use items (recast) – 
(OJ L 206, 11.6.2021, p. 1) - https://eur-lex.europa.eu/eli/reg/2021/821/oj. 
2 Commission Recommendation (EU) 2024/214 of 10 January 2024 on guidelines setting out the methodology for 
data gathering and processing for the preparation of the annual report on the control of exports, brokering, technical 
assistance, transit and transfer of dual-use items pursuant to Regulation (EU) 2021/821 of the European Parliament 
and of the Council - https://eur-lex.europa.eu/eli/reco/2024/214/oj  
3 Some Member States’ competent authorities also publicly report on trade in dual-use items. 

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for example, in relation to semi-conductors and semi-conductor manufacturing equipment or 
raw materials critical for the production of sensitive enabling technologies.  

2. 

EVOLUTION OF THE POLICY & REGULATORY FRAMEWORK 

2.1. 

Export control policy  

2.1.1.  Modernisation of EU export controls under the Dual-Use Regulation 

Further to the adoption of the enhanced Dual-Use Regulation, the Commission and the Member 
States  have  initiated  its  effective  implementation  in  a  number  of  new  areas,  such  as 
transparency, enforcement and capacity-building. The DUCG played a key role, as described 
in Section 3 below, and expanded the EU export control “institutional infrastructure” through 
the activities of a number of expert groups to develop new policies, guidelines, procedures, etc. 

This  included  (i)  setting  up  an  “Emerging  Technology  Expert  Group”  (ETEG)  to  exchange 
information with Member States on risk assessments for emerging technologies; (ii) setting up 
an  Enforcement  Coordination  Mechanism  to  support  the  work  of  national  law  enforcement 
agencies  throughout  the  EU;  (iii)  developing  the  Dual-Use  electronic  System  (DUeS)  to 
enhance information exchange between relevant services in the Commission and the Member 
States; and (iv) enhancing industry outreach and compliance as part of a “partnership with the 
private sector”. 

The Commission and the Member States developed Guidelines to ensure transparency about 
national licencing decisions as part of Member States’ annual reports.4 These Guidelines were 
prepared by the Technical Expert Group on Data Collection and Transparency, composed by 
representatives  of  Member  States’  export  control  authorities  and  chaired  by  the  European 
Commission. 

The enhanced Regulation also places additional emphasis on the export of cyber-surveillance 
items.  It  addresses  the  potential  risk  of  such  items  being  exported  from  the  Union  for  their 
misuse in connection with serious violations of human rights or international humanitarian law. 
It is in this context that the Commission, on 16 October 2024, published guidelines on the export 
of cyber-surveillance items5  under Article 5 of Regulation  (EU) 2021/821  to  provide clarity 
primarily  for  exporters  on  how  to  conduct  due  diligence  and  internal  compliance  prior  to 
exporting cyber-surveillance items.  

2.1.2  Consultations and outreach 

The Commission and the Czech Presidency of the Council organised, with the support of the 
DUCG, the "2022 Export Control Forum" on 6 December 2022. This provided an opportunity 
to exchange views on the implementation of EU export controls and the modernised EU export 
controls  regime  with  nearly  1000  industry  and  civil  society  stakeholders6.  The  Commission 

4 Commission Recommendation (EU) 2024/214 of 10 January 2024 on guidelines setting out the methodology for 
data gathering and processing for the preparation of the annual report on the control of exports, brokering, technical 
assistance, transit and transfer of dual-use items pursuant to Regulation (EU) 2021/821 of the European Parliament 
and of the Council - https://eur-lex.europa.eu/eli/reco/2024/214/oj 
5 https://policy.trade.ec.europa.eu/news/commission-publishes-guidelines-cyber-surveillance-exporters-2024-10-
16_en 
6 https://policy.trade.ec.europa.eu/news/2022-export-control-forum-outcome-2022-12-13_en 

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cooperated with and appeared in front of the European Parliament’s Committee of Inquiry to 
investigate the use of Pegasus7 and equivalent spyware (PEGA Committee8). 

2.1.3  Cooperation with third countries in 2022 

The second meeting of the EU–US Trade and Technology Council (TTC)9 took place in Paris-
Saclay on 16 May 2022, hosted by the French Presidency of the Council of the European Union. 
At that meeting, the TTC expressed a shared desire to use export control tools in defence of 
security.  In  particular,  the  EU  and  the  US  committed  to  enhance  cooperation  and  support 
information exchange on dual-use technologies and export controls. The work of the TTC was 
considered foundational in developing common approaches between the United States and the 
European  Union  in  response  to  Russia’s  war  of  aggression  against  Ukraine,  including  by 
facilitating  cooperation  on  export  controls.  That  cooperation  supported  further  common 
approaches, including the update of the controlled goods list taking into account decisions of 
multilateral export control regimes, the cooperation with partners, and regular consultations on 
new actions that could affect the EU or US. 

Following the second ministerial meeting of the TTC, the EU and the US invited stakeholders 
to participate in a second outreach event on export controls. The event took place on 19 July 
2022 and showcased the progress achieved in TTC Working Group 7 on Export Controls since 
October 2021. It also provided an opportunity for industry, academia and civil society to submit 
their feedback and ideas for future initiatives, and to discuss the priorities for export control 
cooperation with EU and US authorities. 

The US  hosted the 3rd  ministerial  meeting  outside  Washington,  D.C., on  5 December 2022. 
Regarding cooperation on export controls, the TTC looked at how to simplify transatlantic trade 
with  regard  to  exports  and  re-exports  of  dual-use  items  and  technologies,  through  pilot 
exchanges of information. The TTC also aimed at facilitating trade between the two partners 
by  a  more  coordinated  adoption  and  publication  of  multilateral  control  list  revisions,  by 
pursuing consultations on new regulatory actions and by coordinating export control outreach 
with  other  partners.  The  parties  committed  to  enhance  enforcement  collaboration,  including 
through  a  consistent  application  of  sanction-related  export  restrictions  targeting  Russia  and 
Belarus. Lastly, the EU and the US announced their intention to cooperate on export controls 
of  sensitive  and  emerging  technologies,  while  ensuring  appropriate  protection  against  the 
misuse of such items. 

In addition, the Commission and Member States actively contributed to the global coalition on 
Russia  sanctions (the “GECC”10), that has  39 members that have  implemented substantially 
similar  export  controls  in  response  to  Russia’s  invasion  of  Ukraine  in  February  2022.  The 

7 Pegasus is a spyware developed by the Israeli cyber-arms company NSO Group that is designed to be covertly 
and remotely installed on mobile phones running iOS and Android. 
8 https://www.europarl.europa.eu/committees/en/archives/9/pega/home/welcome-words 
9 In June 2021, the EU and the U.S. established the Trade and Technology Council, which met for the first time in 
Pittsburgh on 29 September 2021 and agreed on an ambitious Joint Statement, including cooperation on export 
control. One of the ten Working Groups is dedicated to export controls, sharing information and working on themes 
like  legislative  and  regulatory  developments,  risk  assessments  and  licensing  good  practices,  as  well  as  on 
approaches  to  industry  compliance  and  enforcement.  Furthermore,  this  working  group  aims  at  promoting 
convergent control approaches on sensitive dual-use technologies, and perform joint industry outreach on dual-
use export controls. 
10 The GECC members are Australia, Canada, the 27 EU Member States, Iceland, Japan, Liechtenstein, New 
Zealand, Norway, South Korea, Switzerland, United Kingdom, United States and Taiwan. 

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GECC’s  aims  at  cutting  Russia  and  Belarus  off  from  the  commodities,  technologies,  and 
software necessary to sustain their aggression in Ukraine, depriving their defence, aerospace, 
and maritime sectors of key materials. 

Finally, the EU and Norway held EU-Norway Dialogues on Arms and Dual-Use Export Control 
on 13 June and 17 November 2022, respectively. The parties discussed the new EU Dual-Use 
Regulation, Norway’s legislative developments and exchanged views on recent export control 
developments, upcoming meetings of export control regimes and information on denials. The 
EU and Norway also discussed export restrictions on dual-use items and advanced technologies.  

2.2. 

Updates to the EU control list 

The EU Control List in Annex I to the Regulation essentially provides a list of dual-use items, 
including software and technology, which are subject to controls given their potential use for 
both civil and military purposes. The list is updated on a regular basis to reflect changes in the 
Multilateral Export Control Regimes, such as the Wassenaar Arrangement, the Australia Group, 
the Nuclear Suppliers Group and the Missile Technology Control Regime (MTCR). 

On  21  October  2022,  the  Commission  adopted  Commission  Delegated  Regulation  (EU) 
2023/6611 to update the EU control list, bringing the EU’s Dual-Use Regulation in line with 
decisions taken in international regimes up until December 2021. The updated list includes new 
entries  in  the  field  of  electronics,  semiconductors  and  computers,  chemical  and  biological 
sectors,  and  the  category  of  aerospace  and  propulsion.  The  Commission  also  adopted 
Commission Delegated Regulation (EU) 2022/699 on 3 May 202212, which removed Russia 
from  the  scope  of  the  Union  general  export  authorisations  laid  out  under  the  Dual-Use 
Regulation  as  a  consequence  of  Russia’s  military  invasion  of  Ukraine  and  the  consequent 
adoption  of  EU  restrictive  measures  aimed  at  limiting  the  export  of  dual-use  goods  and 
technology to Russia.   

2.3. 

National implemention and enforcement measures 

2.3.1. Implementation measures  

The Dual-Use Regulation is binding in its entirety and directly applicable in all Member States. 
However, it provides that Member States may take certain measures for the implementation of 
specific provisions, and requires such information on national measures to be published in the 
Official  Journal  of  the  European  Union.  Accordingly,  the  Commission  published  an 
Information Note on 8 February 202213, which provides an updated overview of measures taken 
by  Member  States  including,  inter  alia,  the  extension  of  brokering  and  transit  controls,  the 
extension  of  controls  to  non-listed  items  for  reasons  of  public  security  and  human  rights 
considerations, the introduction of national general export authorisations, and the application 
of  intra-EU  transfer  controls  for  non-listed  items.  Such  Information  Notes  ensure  the 
transparency  of  applicable  rules  and  reflect  the  EU's  efforts  to  support  the  consistent  and 
effective implementation of controls by exporters throughout the EU. 

11 http://data.europa.eu/eli/reg_del/2023/66/oj 
12 http://data.europa.eu/eli/reg_del/2022/699/oj 
13 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52022XC0208(02) 

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2.3.2. Enforcement measures  

The Commission was not informed of any changes to the list of national enforcement measures 
published together with the 2019 annual export control report14. 

2.4 

Exports from Northern Ireland 

Exports  of  dual-use  items  from  the  EU  to  the  UK  became  subject  to  control  under  the 
Regulation with the UK’s departure from the Union on 1 January 202115. 

Specific arrangements are set forth in the Northern Ireland (NI) Protocol16, which provides that 
the Regulation applies to the United Kingdom in respect of Northern Ireland17, with the UK 
acting as a competent authority under the Regulation for exports from Northern Ireland to third 
countries outside of the EU. The Commission has developed a dedicated secure electronic tool 
to support the exchange of information with the UK competent authority in charge of applying 
the Regulation in and from Northern Ireland, which was used throughout 2022. This enables 
UK authorities to access information on denials for essentially identical transactions issued by 
EU Member States, and have bilateral consultation with the issuing Member State, as foreseen 
by the Regulation. 

3. 

ACTIVITIES OF THE DUAL-USE COORDINATION GROUP 

The DUCG brings together experts from the Commission and Member States to examine any 
issue concerning the application of export controls18. In 2022, the DUCG held seven meetings: 
on 20 January, 15 March, 24 May, 14 July, 11 October and 8 December, and in the form of an 
Export Control Forum with stakeholders on 6 December 2022. A special session to review the 
draft 2021 Delegated Regulation updating Annex I to Regulation took place on 14 July 2022. 
The DUCG was also consulted in 2022 on an exceptional update to Annex I to include items 
controlled by the Australia Group. 

3.1. 

Consultations on implementation issues - general information exchange 

The  Commission  and  Member  States’  representatives  in  the  DUCG  conducted  general 
information exchanges on export control issues. In particular, the DUCG exchanged views on 
implementation  aspects,  such  as  the  distinction    between  “national  measures”  and  “national 
control lists” under Article 9 of the Regulation, large project authorisations and the control of 
intangible exports/transfers. 

3.2 

Guidelines and Guidance Notes 

The  DUCG  started  a  survey  among  competent  authorities  on  the  implementation  of  the 
Guidelines  for  Dual-Use  Research  of  23  September  202119,  endorsed  an  Implementation 
Monitoring  Plan  for  the  Industry  Compliance  Guidance,  exchanged  information  regarding 

14 https://ec.europa.eu/transparency/documents-register/detail?ref=COM(2019)562&lang=en   
15 The UK has been added to EU General Export Authorisation EU001 in the meantime. 
16 OJ L 29, 31.1.2020, p. 7 (“Withdrawal Agreement”).   
17 Article 5(4) of the NI Protocol and section 47 of Annex 2 to that Protocol. 
18 This report is also the annual report required by the Regulation on the activities, examinations and consultations 
of the DUCG. 
19 https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=uriserv:OJ.L_.2021.338.01.0001.01.ENG 

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national implementing measures to update the official information notice on national measures, 
and  started  discussions  about  the  preparation  of  guidelines  on  the  Intangible  Transfer  of 
Technology. 

3.3 

Technical exchange of information – Technical Expert Groups 

Member States’ competent authorities in the DUCG provided technical expertise supporting 
the  updates  to  the  EU  control  list,  and  engaged  in  discussions  on  a  number  of  specific 
implementation issues, as mentioned above. 

Under  the  Commission’s  coordination,  the  DUCG  also  took  initiatives  to  address  certain 
technical  implementation  issues  and  set  up  dedicated  expert  groups  to  implement  the 
requirements  of  the  new  Regulation.  The  specific  role  of  technical  expert  groups  is  now 
recognised in Article 24(3) of the new Regulation. 

The following expert groups were active in 2022: 

a)  The  Surveillance  Technology  Expert  Group  (STEG)  allows  experts  from  Member 
States to contribute to the development of EU controls on exports of cyber-surveillance 
items.  The  STEG  mandate  involves  technical  discussions  on  risks  associated  with 
exports of cyber-surveillance items – in particular the risk of such items being used in 
connection  with  internal  repression  or  serious  violations  of  human  rights  and/or 
international humanitarian law. Since 2021, the STEG has worked on the preparation of 
guidelines on the export of cyber-surveillance items under Article 5 of Regulation (EU) 
2021/82120.  In  2022,  such  work  focused  on  the  scope  of  the  definition  of  cyber-
surveillance items; 

b)  The Technical Expert Group on Emerging Technologies (ETEG) continued to exchange 
information  on  risks  associated  with  exports  of  emerging  technologies  and  the 
challenges associated with their control. The ETEG members identified as main priority 
the creation and use of an operational tool for risk assessment. ETEG also organised 
discussions  on  quantum  technology,  including  presentations  by  private  sector 
representatives;  

c)  The Enforcement Coordination Mechanism (ECM) was launched in accordance  with 
Article  25  of  the  Regulation  to  support  the  exchange  of  information  and  direct 
cooperation between competent authorities and enforcement agencies of the Member 
States; 

d)  The  Technical  Expert  Group  on  Data  Collection  and  Transparency  (DCT-TEG)  was 
particularly active and met seven times in 2022, to prepare the transparency Guidelines. 
Experts discussed several drafts and had extensive discussions on a new methodology 
to collect and report licensing data, in view of a public consultation21 with stakeholders 
in early 2023; and 

e)  The Technical Expert Group on Capacity-Building (CB-TEG) was launched with a view 
to  supporting  regular  training  and  sharing  of  expertise  within  the  EU  dual-use 

20 The subsequent Guidelines were published by the Commission on 16 October 2024. 
21 
dual-use-export-controls-under_en#respond-to-the-consultation 

https://policy.trade.ec.europa.eu/consultations/guidelines-data-collection-and-preparation-eu-annual-report-

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community, including through developing common training programmes for Member 
States’ officials. The CB-TEG collected input from Member States on training needs 
and advanced in the preparation of a feasibility report. 

3.4 

Technical  support  to  the  preparation  of  updates  to  the  EU  control  list  and 
national implementing measures 

In accordance with Article 17 of the Regulation, the DUCG held technical information sessions 
to support the preparation of the proposal for a Commission Delegated Regulation updating the 
EU  Control  List.  National  experts  and  observers  from  the  European  Parliament  attended  a 
special session of the DUCG  on  14 July  2022, with  presentations  from  the German  Federal 
Office for Economic Affairs and Export Control (BAFA) on the key changes introduced to the 
EU Control List. The Commission adopted the Delegated Act in October 2022. 

The DUCG exchanged information  regarding  national implementing measures and prepared 
the update of the Information Note on national measures, which was published on 8 February 
2022. 

3.5 

Licensing and implementation data exchange  

The DUCG completed the 2020 licensing data collection exercise based on the agreed Data 
Exchange Questionnaire (DEQ), with a view to providing an overview of the implementation 
of export controls throughout the EU, and to allow for the publication of aggregated data in the 
EU Export Control Annual Report for 201922. The DUCG also initiated the collection of 2021 
licensing data.  

3.6 

IT  Tools  for  the  Exchange  of  Information  among  Member  States  and  for 
Electronic Licensing  

The  Commission,  supported  by  the  DUCG,  continued  to  develop  the  Dual-Use  e-System 
(DUeS) as the IT backbone of the EU export control network. This platform has a key role in  
the effective application of the Regulation.  

New functionalities were developed to support the exchange of information on denials for intra-
EU transfers and to support the regular review and update of denials. In particular, the DUCG 
completed the review of denials in 2013 and advanced in the review of 2014 data. 

Other DUeS functionalities were improved, as follows: 

a)  A new functionality to review denials was implemented in January 2022; 

b)  A  new  module  was  created  in  March  2022  to  support  information  sharing  related  to 
notifications/authorisations and denials, according to the Russian and Belarus sanctions 
regulations.  Subsequent  updates  were  introduced  to  implement  changes  needed 
following the update of sanctions packages; and 

22 Report from the Commission to the European Parliament and the Council on the implementation of Regulation 
(EU) 2021/821 setting up a Union regime for the control of exports, brokering, technical assistance, transit and 
transfer of dual-use items (COM(2022) 434 final). 

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c)  A  new  functionality  allowed  the  exchange  of  information  on  the  implementation  of 

Russia sanctions with the Member States. 

2022 was also the second year of operation of the dual-use eLicensing system, which allows 
competent  authorities  and  exporters  to  administer  controls  on-line  and  to  reduce  the 
administrative burden associated with those controls. It is aimed at replacing off-line systems 
or outdated national  electronic systems, to  allow for more  agile exchanges of information  – 
including  reporting  of  licensing  data  to  the  Commission  in  the  context  of  Article  26  of  the 
Regulation. In 2021, the eLicensing system went live in Latvia and Romania. In 2022, it was 
further improved and customised to support the Italian licensing authority (as of July 2022) and 
preparations for the Slovenian and Wallonian authorities to become users of the system in 2023 
were  ongoing.  Likewise,  Hungary  and  Belgium  (Brussels  Region)  expressed  an  interest  in 
joining the project.  

Beyond  the  EU,  and  as  part  of  its  dialogues  with  partner  countries,  the  Commission  is 
examining  options  for  providing  the  eLicensing  tool  to  partners.  Moldova,  Bosnia  and 
Herzegovina, and Serbia expressed an interest in using the tool. 

The eLicensing project is also developing in new directions to make controls more effective, 
for  example  by  connecting  the  eLicensing  system  with  national  customs  systems  via  the 
Customs’ Single Window environment. This makes the sharing of information across borders 
and  with  customs  authorities  much  easier,  reducing  the  regulatory  burden  for  operators  and 
allowing  automatic  licensing  management.  This  is  done  through  the  Certification  Exchange 
“CERTEX” platform, managed by DG TAXUD. The interconnection between eLicensing and 
the national customs has been operational since December 2022. 

At the request of Member States that already operate eLicensing systems,  in April 2022 the 
Commission initiated a new "eLicensing bridge" project to allow to connect national licensing 
systems to customs systems through eLicensing. Finland is part of the pilot project. Belgium 
(Flanders) expressed an interest in joining the project. 

3.7 

Transparency and outreach 

The  DUCG  contributed  to  the  preparation  of  the  2022  Annual  Export  Control  Report  –
published along with the second Foreign Direct Investments (‘FDI’) Screening Annual Report23 
- which informs stakeholders on the implementation of dual-use export controls in the European 
Union, including on the activities of the Dual-Use Coordination Group.  

3.8 

Support to international cooperation 

In the context of the Trade and Technology Council’s Export Control Working Group with the 
United States, the DUCG supported relevant discussions on the simplification of re-export, in 
particular (i) to explore national practices in the application of EU General Export Authorisation 
EU001; and (ii) through dedicated expert discussions on US license exceptions that authorise 
the re-export of US-origin dual-use items from the EU. 

3.9 

Dual-use research and control over intangible exports 

23 https://ec.europa.eu/transparency/documents-register/detail?ref=COM(2022)433&lang=en 

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The DUCG hosted dedicated discussions on the interlinks between export control and research 
involving  dual-use  technology.  Such  discussions  took  place  in  the  framework  of  the 
Commission’s strategy on international R&I cooperation (Horizon Europe) and counted on the 
support of Commission’s experts from DG Research and Innovation and of external experts. 

3.10   Overview of developments relating to dual-use items in 2023 and 2024 

1.  Updates to Annex I to the Regulation: 

•  On 11 January 2023, the Commission published Delegated Regulation (EU) 2023/66 amending 
Annex I to the Dual-Use Regulation in the Official Journal (OJ) of the EU. This annual update 
brings  the  list  in  line  with  decisions  taken  in  the  multilateral  export  control  regimesand  is 
independent from the EU’s export restrictions against Russia or Belarus.  

•  On 23 February 2023, the Commission published Delegated Regulation (EU) 2023/996 in the 
OJEU  to  exceptionally  update  Annex  I to the  Regulation  to  include items  subject to control 
under the Australia Group. 

•  On  15  September  2023,  the  Commission  published  Delegated  Regulation  2023/2616  as  the 
regular annual update of Annex I to the Regulation. This Regulation has been applied since 16 
September 2023. 

•  On 5 September 2024, the Commission adopted the annual update to Annex I, which is expected 

to enter into force two months later. 

2.  Member States’ national control lists 

•  The  Commission  published  the  first  EU  compilation  of  national  control  lists  on  20  October 
2023,  which  includes  the national  controls  adopted by  Spain  and  the  Netherlands  on certain 
emerging  technologies.  It  was  revised  on  27  September  2024  to  include  national  controls 
adopted by France. This compilation reflects controls of items at national level that have not 
been  adopted  in  the  multilateral  regimes  on  certain  emerging  technologies.  This  is  the  first 
compilation of national control lists under the Regulation. It enables Member States to impose 
authorisation requirements by referring to other Member States’ national control lists published 
in the compilation without necessarily having to adopt their own national controls.  

3.  Export controls under the Economic Security Strategy 

•  Following the adoption of the Economic Security Strategy on 20 June 202324, the Commission 
published on 24 January 2024 a White Paper on Export Controls25 outlining how to make EU 
export controls more effective in the context of growing geopolitical tensions, with a view to 
better upholding international security and safeguarding the EU's security interests. The White 
Paper proposes short and medium-term actions to improve the coordination of export controls 
on dual-use items in the EU. These actions include: uniform EU controls for items that have not 
been adopted at multilateral level due to blockages or delays in export control regimes; a senior-
level forum for political coordination on export controls; a mechanism to better coordinate new 
national control lists; and the evaluation of the EU Dual-Use Regulation in 2025. The White 
Paper was subject to a public consultation which ran from 2 February until 30 April 2024, to 
which 23 replies were received, feeding into the Commission’s internal deliberations. 

24 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52023JC0020&qid=1687525961309 
25 https://circabc.europa.eu/ui/group/aac710a0-4eb3-493e-a12a-e988b442a72a/library/a44df99c-18d2-49df-
950d-4d48f08ea76f/details?download=true 

9 

 
 
 
4.  Export restrictions against Russia 

•  Throughout  2023  and  2024,  the  Commission  actively  continued  to  tighten  dual-use  export 
restrictions in the context of sanctions against Russia, including through the adoption of a 14th 
package  of  sanctions  in  June  202426.  The  Commission  also  published  guidance  to  support 
implementation and enforcement and to counter the circumvention of sanctions. In particular, 
the Commission developed, in cooperation with partners - Japan, the United Kingdom and the 
United  States  -  a list  of  so-called  Common  High  Priority  Items  (as last  updated  in  February 
2024)27, including dual-use goods and advanced technologies used in Russian weapons systems 
found on the battlefield in Ukraine or critical to the development, production or use of those 
Russian military systems. 

5.  International outreach 

•  The  Commission  discussed  export  control  related  matters  with  partners  such  as  the  US 
throughout 2023. Notably, on 10 May 2023 the fourth meeting of the US-EU TTC discussed 
areas  such  as  trade  facilitation  and  offered  a  strong  basis  for  cooperation  on  Russia-related 
sanctions. The last stakeholder meeting in the TTC took place on 19 July 2023, focusing on re-
exports of dual-use items. Finally, the Commission had a virtual  first export control dialogue 
with China on 26 October 2023 and the second one on 24 October 2024. 

4. 

EU EXPORT CONTROLS – KEY DATA  

This Section presents EU aggregated export control data for the reference year 2022. Due to 
their  volume,  the  underlying  data  provided  by  Member  States  are  presented  in  consolidated 
form in the Staff Working Document that accompanies the report. The data have been made 
available in accordance with new reporting Guidelines28, that are hereby applied for the first 
time. 

With  the  adoption  of  Regulation  (EU)  2021/821,  the  EU  demonstrated  its  commitment  to 
strengthening public reporting and transparency. Article 26 of the Regulation provides that the 
publication of an EU annual  report on the implementation  of controls  shall include relevant 
information  on  authorisations,  denials  and  prohibitions,  as  well  as  information  on  the 
administration, and enforcement of controls. 

Since  2013,  the  DUCG  has  developed,  on  a  voluntary  basis,  a  licensing  data  collection 
mechanism and supported the preparation of an annual report to the European Parliament and 
the  Council,  that  included  EU  aggregated  licensing  data  and  other  export  control-related 
information. The data collection took place on an annual basis and the format was progressively 
expanded in an effort to capture data relating to various types of authorisations and concerning 
the administration, implementation and enforcement of controls.  

Under  the  recently  adopted  transparency  guidelines,  the  data  collection  methodology  is 
designed  to  remain  sustainable  over  time,  allowing  for  Member  States  to  provide  relevant 

26 https://finance.ec.europa.eu/eu-and-world/sanctions-restrictive-measures/overview-sanctions-and-related-
resources_en 

27 https://policy.trade.ec.europa.eu/news/eu-and-partners-expand-list-common-high-priority-items-further-
weaken-russias-war-effort-2024-02-23_en 
28 Commission Recommendation (EU) 2024/214 of 10 January 2024 setting out the methodology for data gathering 
and processing for the preparation of the annual report on the control of exports, brokering, technical assistance, 
transit and transfer of dual-use items pursuant to Regulation (EU) 2021/821 (“the Guidelines”). 

10 

 
 
 
 
 
information to the Commission in an efficient and cost-effective manner, which is statistically 
sound  and  with  due  consideration  to  the  protection  of  personal  information,  commercially 
sensitive information or protected defence, foreign policy or national security information. 

4.1. 

Types of items  

The Regulation primarily applies to the export of over 1800 dual-use items listed in the EU 
Control List, classified in 10 Categories (Figure 1). That is the underlying rationale that led the 
EU experts to group the entries in Annex I in “types of items” for the purpose of the EU annual 
report29.  

Figure 1: Number of dual-use items listed in the 10 Categories of Annex I to the Regulation  

In  order  to  allow  for  the  required  level  of  transparency  of  public  reporting  while  ensuring 
efficient  and  sustainable  data  collection  over  time,  it  was  decided  that  the  baseline  for  the 
determination of the types of items would build on the classification of dual-use items at 5-digit 
level30  while  ensuring  that  the  determination  of  “types  of  items”  supports  the  provision  of 
meaningful  information  from  a  security,  policy  and  trade  perspective.  Annex  A  to  the 
Guidelines describes the list of 52 “types of items” used for the collection of licensing data and 
the preparation of this annual report. Authorisations are broken down by type of item and by 
relevant  destinations  in  line  with  the  requirements  of  the  Regulation,  whilst  considering  the 
nature, purpose and characteristics of the different types of authorisations, as well as the varying 
practices in Member States for granting authorisations and collecting data. Furthermore, it was 
necessary  to  adapt  the  relevant  data  collection  and  submission  by  the Member  States  to  the 
Commission according to the specificities of the different types of national authorisations and 
practices. For that reason, figures presented in this report provide a count of Member States that 
have  provided  the  data  underlying  each  authorisation  type.  The  methodology  also 
acknowledges that authorisations may refer to multiple items falling within multiple types of 
items. 

Concerning  cyber-surveillance  items,  the  definition  of  Article 2,  point  (20)  comprises  both 
items listed in Annex I as well as non-listed items. Annex B to the Guidelines identifies five 
items  in  Annex I  to  the  Regulation  which  fulfil  the  definition  of  Article 2,  point  (20).  The 

29 Cf. Article 26(2) paragraph 1 of the Regulation. 
30 E.g. ECCN 0A001: Nuclear reactors. 

11 

 
 
 
 
decision as to whether a specific non-listed item meets the requirements of the legal definition 
is taken on a case-by-case basis by the Member States and the Commission within the STEG. 
Applications and authorisations for non-listed cyber surveillance items also need to be included 
in the annual report in accordance with Article 26(2) of the Regulation, based on data provided 
by the Member States. Applications and authorisations for other listed items can be included in 
the report, based on the decision of the relevant competent authority. 

4.2 

Overview of authorisations by type of license31 

In  2022,  the  total  value  of  authorised  dual-use  trade32  amounted  to  EUR  57.3  billion, 
representing 2% of extra-EU exports of goods (Figure 2). In terms of numbers, that corresponds 
to 138,764 authorisations and notifications33. With respect to the types of authorisations, the 
majority of transactions fall under EU General export authorisations (93,311), National general 
export  authorisations  (26,953)  and  individual  licences  (17,072).  In  terms  of  value,  the  most 
important types of licenses  were global export authorisations  (EUR  27.3 billion), individual 
export  authorisations  (EUR  17.1  billion)  and  EU  general  export  authorisations  (EUR  9.6 
billion). 

4.3 

Denials and prohibitions 

In 2022, 813 denials were reported for a value of EUR 0.98 billion. Those figures show that 
only a small portion of EU exports were denied (0.04% of value of total extra-EU27 exports of 
goods that year). 

31 Please note that in accordance with the third paragraph of Article 26 (2) of the Regulation, Sections 4.2 to 4.7 
of this report do not include data relating to cyber-surveillance items. Information on those items is provided in 
section 4.8 below. 
32 Please note that this includes voluntary data on uses of National General Export Authorisations and EU General 
Export Authorisations. 
33 Please note that this includes voluntary data on uses of National General Export Authorisations and EU General 
Export Authorisations. 

12 

 
 
 
Figure 2: Export authorisations by type of license 

4.4 

Individual authorisations 

Individual  authorisations  are  licences  granted  to  one  specific  exporter  for  one  end-user  or 
consignee in a third country and covering one or more dual-use items. For the purpose of this 
report,  individual  export  authorisations,  brokering  authorisations,  technical  assistance 
authorisations,  transit authorisations,  intra-EU transfer  authorisations,  authorisations under a 
national control measure and authorisations for non-listed items are all considered individual 
licences, as specified in the Guidelines. 

The overview of individual authorisations in 2022 by the 10 Categories of items in Annex I to 
the Regulation as well as non-listed items subject to controls (Figure 3) indicates that the highest 
number  of  authorisations  in  terms  of  market  value  was  granted  to  Category  0  on  Nuclear 
materials, facilities, and equipment (EUR 8,1 billion, 41% of total), followed by Category 2 on 
Materials processing (EUR 2,5 billion, 13% of total), and Category 5 on Telecommunications 
and 'information security' (EUR 2,3 billion, 12% of total). Concerning the volume of individual 
authorisations,  the  largest  figure  was  for  Category  2  on  Materials  processing  (5,592 
representing 29% of total), followed by Category 1 on Special materials and related equipment 
(4,501  representing  23%  of  total),  and  Category  5  on  Telecommunications  and  'information 
security' (3,205 representing 17% of total). 

13 

 
 
 
Figure 3: Individual export authorisations by category of items in Annex I to Regulation (EU) 
2021/821 

Breaking-down the value of individual authorisations by types of items (Figures 4.1 and 4.2) 
shows that the top 5 items are 0EC1 Nuclear materials, facilities, plants and equipment (EUR 
6,4  billion,  33%  of  total),  2EC1  Machines  tools  and  systems  and  components  for  industrial 
equipment (EUR 1,8 billion, 9% of total), 5EC2 Information security and crypto-analysis items 
and  equipment  (EUR  1,3  billion,  7%  of  total),  9EC1  Aerospace  engines  and  gas  turbines 
(except UAV) (EUR 1,1 billion, 6% of total), and XEC1 Other/non-listed (EUR 1,1 billion, 6% 
of total). 

14 

 
 
 
 
Figure 4.1: Individual export authorisations by type of items (Part 1) 

15 

 
 
 
Figure 4.2: Individual export authorisations by type of items (Part 2) 

16 

 
 
 
Concerning destinations covered by individual authorisations (Figures 5 and 6), China was the 
largest destination by value (EUR 5,6 billion, 28% of total), followed by South Korea (EUR 
1,7 billion, 9% of total), the United States (EUR 1,3 billion, 7% of total), Japan (EUR 1,04 
billion, 5% of total) and Singapore (EUR 994 million, 5% of total). Overall, the top-25 extra-
EU destinations account for 90% of individual authorisations by value34. With respect to intra-
EU  transfers,  the  main  destinations  were  France  (EUR  301  million),  Belgium  (EUR  251 
million),  Sweden  (EUR  188  million),  Hungary  (EUR  141  million)  and  Spain  (EUR  113 
million). Compared to extra-EU destinations, intra-EU transfers appear to be limited because 
most intra-EU dual-use exports do not require to be authorised according to the Regulation. 

Figure 5: Individual export authorisations by destination 

34 Please note that export authorisations with a destination to the Russian Federation correspond to exemptions and 
derogations  in  accordance  with  Council  Regulation  (EU)  No  833/2014  of  31  July  2014  concerning  restrictive 
measures in view of Russia's actions destabilising the situation in Ukraine. 

17 

 
 
 
 
Figure  6:  Individual  export  autorisations  by  top  extra-EU  destinations  and  by  intra-EU 
destinations 

4.5  Global Export Authorisations 

Mindful of the nature, purpose and characteristics of each type of authorisation, the Guidelines 
acknowledge  that  global  export  authorisations  most  often  contain  estimated  or  open-ended 
export values and are granted either for one or multiple items and a single destination or for one 
or  multiple  items  for  multiple  destinations.  As  such,  global  authorisations  lessen  the 
administrative  burden  of  competent  authorities  and  exporters  for  similar and/or  frequent 

18 

 
 
 
transactions. In order to safeguard non-proliferation objectives, exporters are required to draft 
and submit an internal compliance programme in order to qualify for a global license. Because 
the Regulation leaves the concrete configuration of global authorisations to the Member States, 
different practices across Member States also apply. To the purpose of providing meaningful 
information to the public, while taking into account different national practices and the rationale 
of global export authorisations, the Guidelines adapt the relevant data collection and reporting. 
Member States provide licensing data to the Commission accordingly, with a focus on: (i) the 
total value of global export authorisation (EUR 27.3 billion, equivalent to 48% of authorised 
value in 2022) and (ii) a break-down of the total volume of global licenses by types of items 
(Figures 8.1 and 8.2) and destinations (Figures 9.1 and 9.2). 

By category of items in Annex I to the Regulation (Figure 7), the majority of authorisations  
were  granted  by  volume  to  Category  5  on  Telecommunication  and  ‘information  security’ 
(39%), Category 2 Special materials and related equipment (11%) and Category 6 Sensors and 
lasers (11%).  

Breaking-down the volume of global export authorisations by types of items (Figures 8.1 and 
8.2) shows that the top 5 items are 5EC2 Information security and crypto-analysis items and 
equipment  (18%),  5EC3  Software  for  telecommunications  and  information  security  (14%), 
6EC1 Optical and acoustic equipment, related components and materials; other sensors (10%), 
4EC1 Computers (8%), and 5EC4 Technology for telecommunications and information security 
(7%).  

Figure  7:  Global  export  authorisations  by  category  of  items  in  Annex  I  to  Regulation  (EU) 
2021/821 

19 

 
 
Figure 8.1: Global export authorisations by type of items (Part 1) 

20 

 
 
Figure 8.2: Global export authorisations by type of items (Part 2) 

Concerning  destinations  (Figures  9  and  10),  the  majority  of  authorisations  by  volume  were 
granted for exports with destination in China (3%), Taiwan (2%), India (2%), Hong Kong (1%) 

21 

 
 
 
and Singapore (1%). Overall, top 25 destinations account only for 31% of authorisations by 
volume of global export authorisations, as a global licence often covers multiple destinations35.  

Figure 9: Global export authorisations by destination 

35 Ibid. 

22 

 
 
 
Figure 10: Global export authorisations by top destinations 

23 

 
 
 
 
 
4.6 

National and Union General Authorisations 

National and EU General Export Authorisations are issued to facilitate trade of dual-use items 
while reducing administrative burden for exporters and export control authorities. 

Union  General  Export  Authorisations  (EU  GEAs)  are  granted  by  the  European  Union  to 
exporters who notify competent authorities while complying with the relevant pre-conditions 
established in the Regulation. The Regulation provides for eight types of EU GEAs36. 

The vast majority of uses of EU GEAs in 2022 corresponded to EU001 (86% in terms of value, 
95% of volume), with 10 destinations including several important trade partners for the EU. 

Figure 11: EU general export authorisations 

National  General  Export  Authorisations are granted by the Member States to  exporters who 
notify competent authorities while complying with the relevant pre-conditions established by 
applicable national laws. The list of National General Export Authorisations communicated by 
Member States for 2022 is provided in an Annex to this report, detailing destinations and types 
of items included in each National GEA. 

Figure 12 breaks down the value of EU and National GEAs by the Categories of Annex I to the 
Regulation.  The  highest  values  correspond  to  Category  5  on  Telecommunication  and 

36 EU001 - Exports to Australia, Canada, Iceland, Japan, New Zealand, Norway, Switzerland, Liechtenstein, 
the United Kingdom and the United States of America. 
EU002 – Export of certain dual-use items to certain destinations. 
EU003 – Export after repair/replacement. 
EU004 – Temporary export for exhibitions or fairs. 
EU005 – Telecommunications. 
EU006 – Chemicals. 
EU007 – Intra-group technology transfers. 
EU008 – Encryption. 

24 

 
 
 
 
 
‘information security’ (EUR 4,98 billion, 46% of total), Category 3 on Electronics (EUR 1,64 
billion), Category 2 on Material Processing (EUR 1,56 billion, 15% of total) and Category 9 
on Aerospace and Propulsion (EUR 1,30 billion, 15% of total).  

Figure 12: EU and national general export authorisations by category of items in Annex I to 
Regulation (EU) 2021/821 

Breaking-down the value of EU and National GEAs by types of items (Figures 13.1 and 13.2) 
indicates  that  the  top  5  items  are  5EC2  Information  security  and  crypto-analysis  items  and 
equipment (EUR 4,81 billion, 45% of total), 3EC4 Equipment for the manufacturing and testing 
of  semiconductor  devices  or  materials  (EUR  1,32  billion,  12%  of  total), 9EC3  Rockets  and 
spacecraft (EUR 961 million, 9% of total), 2EC1 Machines tools and systems and components 
for industrial equipment (EUR 860 million, 8% of total), and 2EC2 Chemical and biological 
manufacturing equipment (EUR 675 million, 6% of total). 

25 

 
 
 
Figure 13.1: EU and national general export authorisations by type of items (Part 1) 

26 

 
 
 
Figure 13.2: EU and national general export authorisations by type of items (Part 2) 

27 

 
 
 
Concerning destinations authorised under EU and National GEAs, the top 5 were the United 
States (EUR 6,60 billion, 51% of total), the United Kingdom (EUR 2,21 billion, 17% of total), 
Switzerland (EUR 1,16 billion, 9% of total), China (EUR 512 million, 4% of total) and Japan 
(EUR  432  million,  3%  of  total).  This  indicates  the  large  majority  of  the  dual-use  exports 
covered  by  GEAs  are  directed  towards  countries  listed  in  EU  GEA  EU001.  That  is  also 
explained by the fact that the value of exports authorised under EU GEAs is much higher than 
under National GEAs (EUR 9,65 billion versus EUR 846 million, respectively, as per Figure 
2).  

Figure 14: EU and national general export authorisations by destination 

28 

 
 
Figure 15: EU and national general export authorisations by top destinations 

29 

 
 
 
 
 
4.7 

Registered users of National and EU General Export Authorisations 

In order to provide information on exporters’ notifications in accordance with the Regulation37, 
the annual report includes data on the number of exporters that have notified or are registered 
with the competent authority to use Union or National General Export Authorisations. 

In 2022, there were in total 7,033 exporters using EU General Export Authorisations, including 
80.57%  of  them  using  EU001,  and  3,492  exporters  using  National  General  Export 
Authorisations. With respect to first use notifications or registrations in 2022, the figures were 
676 for EU GEAs (73% for EU001) and 218 for National GEAs, respectively. 

Figure  16:  Exporters  registered  or  notified  to  use  EU  and  national  general  export 
authorisations 

Data on dual-use items classified as cyber-surveillance items according to Article 

4.8 
2, point (20) of the Regulation 

In 2022, Member States received a total of 288 applications (Figure 17) for the export of cyber-
surveillance  items,  mostly  in  relation  to  Telecommunications  interception  systems  (216 
applications), followed by Communication monitoring software (28 applications), and Intrusion 
software (20 applications). Figures 18.1 and 18.2 show the destinations of applications for the 
export of cyber-surveillance items. In 2022, 224 authorisations were issued and 37 denied. This 
shows an increase in the number of licences for cyber-surveillance items (as compared to 115 

37 Conform the provisions for Union General Export Authorisations in Annex II of the Regulation: “The exporter 
who uses this authorisation shall notify the competent authority of the Member State where the exporter is resident 
or established of the first use of this authorisation within 30 days from the date when the first export took place 
or, alternatively, and in accordance with a requirement by the competent authority of the Member State where the 
exporter  is  resident  or  established,  prior  to  the  first  use  of  this  authorisation.  Member States  shall  notify  the 
Commission  of  the  notification  mechanism  chosen  for  this  authorisation.  The  Commission  shall  publish  the 
information notified to it in the C series of the Official Journal of the European Union”. 

30 

 
 
 
 
licenses issued in 2021), a trend confirmed since 2020. The number of denials for the export of 
cyber-surveillance items38 appear to be rather stable (35 denials in 2021). 

Figure 17: Applications for the exports of cyber-surveillance items39 

38 More information on cyber-surveillance items can be found in the Guidelines of 16 October 2024, as referred 
to in footnote 7. 
39 Please note that Article 11 of the Regulation also requires licenses issued by Member States in the case of 
intra-EU exports of specific cyber-surveillance items listed in Annex IV to the said Regulation. 

31 

 
 
 
 
Figure 18.1: Applications for the exports of cyber-surveillance items by destination 

Figure 18.2: Applications for the exports of cyber-surveillance items by destination 

4.9 

Information on administration and enforcement 

Member  States  communicated  the  following  information  on  the  administration  and 
enforcement of the Regulation in 2022: 

a)  Number of staff (full-time equivalent) directly involved in the administration of controls 

in the EU): 392. 

b)  Number of outreach events organised in the reference year: 129. 

c)  Number  of  compliance  audits  conducted  in  the  year,  including  those  conducted  by 

customs or other agencies: 1,062. 

d)  Number of infringements reported: 110. 

e)  Number  of  administative  and  criminal  penalties  or  fines  imposed  (by  any  relevant 
national enforcement agency) in case of infringement of export control regulations: 30. 

f)  Use of export control tools: 

−  Member States using an e-licensing system: 18. 

32 

 
 
 
−  Member States using classification tools: 24. 

−  Member States using other tools or software to support the application of controls: 

24. 

5. 

CONCLUSIONS 

The report has been prepared on the basis of a new methodology that ensures a better granularity 
and  reliability  of  the  information.  At  the  same  time,  the  change  of  methodology  makes  it 
difficult to build a time-series comparison with reports of previous years. However, it can be 
noted in broad terms that there was an upward trend for both authorised dual-use trade40 and 
denials41 in 2022. 

In 2022, the total value of authorised dual-use trade amounted to EUR 57.3 billion, representing 
2% of the extra-EU exports of goods. That corresponds to 138,764 authorisations by volume, 
with  the  majority  of  transactions  falling  under  uses  of  EU  General  export  authorisations 
(93,311),  uses  of  National  general  export  authorisations  (26,953)  and  individual  licences 
(17,072). During the same year, 813 denials were reported for a value of  EUR  0.98 billion. 
Those figures show that only a small portion of EU exports were denied (0.04% of value of 
total extra-EU27 exports of goods). 

The  report  includes  information  up  to  the  limit  of  available  data,  in  the  context  of  different 
practices and types of authorisations in each Member State. In this sense, the report does not 
provide the precise allocation of authorised trade by type of item or destination with respect to 
Global  export  authorisations  (representing  48%  of  authorised  value  in  2022),  since  those 
authorisations often include open-ended export values and are granted for multiple items and 
destinations.  Despite  this,  it  is  still  useful  to  consider  the  trends  for  the  other  types  of 
authorisation  (individual  and  General  Export  Authorisations),  which  represent  52%  of  the 
authorised value. 

In  2022,  the  highest  values  of  authorised  trade  other  than  global  authorisations  (Figure  19) 
corresponded to items 0EC1 Nuclear materials, facilities, plants and equipment (21%), 5EC2 
Information  security  and  crypto-analysis  items  and  equipment  (20%),  2EC1  Machines  tools 
and  systems  and  components  for  industrial  equipment  (9%),  3EC4  Equipment  for  the 
manufacturing and testing of semiconductor devices or materials (7%) and 9EC1 Aerospace 
engines and gas turbines (except UAV) (5%). Overall, the list of types of items in Figure 19 
accounts for 90% of the value of authorisations other than global licences. 

40 In 2021 the authorised dual-use trade was of EUR 38.5 billion, representing 1.8% of total extra-EU exports. 
41 In 2021, 568 denials were issued, representing about 0.01% of total extra-EU exports. 

33 

 
 
 
Figure 19: Top type of items for value of individual and General Export Authorisations 

Concerning  destinations  for  authorisations  other  than  global  authorisations  (Figure  20),  the 
United States was the largest destination by value (24% of total), followed by China (19%), the 
United Kingdom (7%), South Korea (5%) and Japan (5%). However, that ranking is heavily 
influenced by the weighting of EU GEAs, in particular EU001 (EUR 8.2 billion), and does not 
take account of major destinations of global export authorisations by volume, namely Taiwan, 
India, Hong Kong, Singapore and Türkiye. Overall, the list of destinations in Figure 20 accounts 
for 90% of the value of authorisations other than global licences. 

34 

 
 
 
 
Figure  20:  Top  extra-EU  destinations  for  value  of  individual  and  General  Export 
Authorisations 

Finally, the report pays particular attention to the licensing of cyber-surveillance items as part 
of EU’s commitment to effectively address the risk of cyber-surveillance items being used in 
connection with internal repression and/or the commission of serious violations of human rights 
and international humanitarian law. In 2022, Member States received a total of 288 applications 
for the export of those items. The highest figure was in relation to item Telecommunications 
interception systems (216 applications). In the same period, 224 authorisations and 37 denials 
were  issued.  Those  figures  also  show  an  increase  in  the  number  of  licences  with  respect  to 
202142,  whereas the number of denials appears rather stable43. 

Further  to  the  various  actions  initiated  in  2021,  the  Commission  and  the  Member  States 
continued  to  focus  on  meeting  the  requirements  and  mandates  under  the  modernised 
Regulation. This includes continuing the work in the various technical expert groups towards 
enhanced controls on cyber-surveillance items, the enforcement of export controls, emerging 

42 In 2021, 115 licenses were issued for cyber-surveillance items. 
43 In 2021, 35 denials were issued for cyber-surveillance items. 

35 

 
 
 
 
technologies  and  the  development  of  EU  capacity-building  and  training  programmes  for 
Member States’ licensing and enforcement authorities. 

These  actions  under  the  Dual-Use  Regulation  will  also  allow  the  EU  to  cooperate  more 
effectively with partners in order to promote the global convergence of controls, reduce trade 
frictions,  increase  predictability  for  business,  promote  EU  values  and  uphold  international 
peace and security. 

36