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: 2026-06-25
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, 25.6.2026  COM(2026) 296 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(2026) 162 final}  
 
 
1. 

INTRODUCTION AND EXECUTIVE SUMMARY 

1.1 Introduction 

This report provides information on the implementation of EU export controls and the revised 
Regulation (EU) 2021/821 of 20 May 2021 (‘the Dual-Use Regulation’ or ‘the Regulation’)1 
for  the  control  of  exports  of  dual-use  items  in  2024,  together  with  the  EU  aggregated  and 
Member States’ export control data for 2024. 

This annual report reflects the EU’s determination under the Regulation to improve information 
sharing on Member States’ licensing decisions in the area of export controls with the objective 
of increasing transparency. 

As required under the Regulation and to improve the data collection process, on 17 January 
2024,  the  Commission  published  guidelines  agreed  with  the  Member  States  setting  out  a 
methodology  for  collecting  and  processing  licensing  data  and  other  data  in  view  of  the 
preparation of the EU’s annual report on dual-use export controls2. Against this background, 
this report was prepared by the Commission with inputs from Member States3 in the Dual-Use 
Coordination  Group  (DUCG).  Due  to  their  volume,  the  data  for  2024  provided  by  Member 
States are presented in a consolidated format in the staff working document that accompanies 
this annual report. 

1.2 Executive summary 

In 2024, the total value of authorised dual-use trade amounted to EUR 77.6 billion, representing 
3% of total  extra-EU exports of goods4. The types of licences having  the highest weighting 
were global export authorisations (EUR 36.5 billion), individual export authorisations (EUR 24 
billion) and EU general export authorisations (EUR 9 billion). 

In  terms  of  volume,  the  2024  dual-use  trade  corresponds  to  133 470  authorisations  and 
notifications.  Most  transactions  fall  under  EU  general  export  authorisations  (89 388),  then 
national general export authorisations (23 406) and subsequently individual licences (18 549). 

In the same year, 487 denials were reported for a value of EUR 0.2 billion, indicating that only 
a small portion of EU exports were denied (0.01% of  the value of total extra-EU exports of 
goods that year). 

The  report  provides  information  synthesised  from  the  available  data.  Given  the  different 
practices  and  types  of  authorisations  in  each  Member  State,  it  does  not  provide  a  precise 
breakdown of authorised trade by type of item or destination for global export authorisations, 
which represent 47% of authorised value in 2024. Despite this, it is still useful to consider the 

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 (OJ L 2024/214, 17.1.2024): http://data.europa.eu/eli/reco/2024/214/oj. 
3 Some Member States’ competent authorities also publicly report on trade in dual-use items. 
4  This  includes  voluntary  data  on  the  uses  of  national  general  export  authorisations  and  EU  general  export 
authorisations. 

1 

 
 
 
trends for the other types of authorisations (individual and general export authorisations), which 
represent 44% of the authorised value. 

In  2024,  the  highest  values  of  individual  and  general  export  authorisations  (Figure  1) 
corresponded to the following items: Nuclear materials, facilities, plants and equipment (22%), 
Information  security  and  crypto-analysis  items  and  equipment  (21%),  Equipment  for  the 
manufacturing and testing of semiconductor devices or materials (9%), Aerospace engines and 
gas turbines (except UAV) (8%), Other/non-listed items (8%). Overall, the list of types of items 
in Figure 1 accounts for 90% of the value of these authorisations. 

Figure 1: Top types of items by value of individual and general export authorisations 

The  main  destinations  for  individual  and  general  export  authorisations  (Figure  2)  are  China 
(25%), the United States of America (21%), the United Kingdom (7%), South Korea (7%) and 
Ukraine (3%). This ranking is influenced by the weighting of EU GEAs, in particular EU001 
(EUR 8.6 billion), which account for a large share of the total value authorised under export 
authorisations.  As  a  result,  destinations  specified  in  general  export  authorisations,  and  in 
particular EU GEA  EU001, feature prominently  in  the ranking,  while the list  does not  fully 
reflect the importance of certain destinations that receive significant volumes of exports under 
global export authorisations, such as Taiwan, Brazil, Singapore and Israel. Overall, the list of 
destinations  in  Figure  2  accounts  for  90%  of  the  value  of  individual  and  general  export 
authorisations. 

2 

 
 
 
 
Figure 2: Top extra-EU destinations by value of individual and general export authorisations 

In addition, Member States reported a stable number of staff working on the administration and 
enforcement of the Regulation in 2024 as compared with 2023. It is also noteworthy that the 
number  of  reported  infringements  rose  from  192  in  2023  to  270  in  2024.  In  this  context, 
administrative and criminal penalties or fines imposed (by any relevant national enforcement 
agency) for the infringement of export control regulations increased from 122 in 2023 to 144 
in 2024. 

The report pays particular attention to the licensing of cyber-surveillance items as part of the 
EU’s commitment to effectively addressing 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 2024, Member States received a total of 320 applications 
for  the  export  of  those  items.  The  highest  figure  was  for  the  item  Telecommunications 
interception systems (233 applications). In the same period, 293 authorisations and 13 denials 
were issued. Those figures also show a rather stable number of licences for cyber-surveillance 
items compared to 20235, whereas the number of denials appeared to be decreasing6. 

5 In 2023, 330 licences were issued for cyber-surveillance items. 
6 In 2023, 20 denials were issued for cyber-surveillance items. 

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As  part  of  the  various  activities  initiated  in  2024,  the  Commission  and  the  Member  States 
continued to focus on meeting the requirements and mandates under the  revised Regulation. 
This  includes  continuing  the  work  in  the  various  technical  expert  groups  towards  enhanced 
controls  on cyber-surveillance items,  the  enforcement of export  controls,  work on emerging 
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. 

4 

 
 
 
 
 
2. 

EVOLUTION OF THE POLICY & REGULATORY FRAMEWORK 

2.1. 

Export control policy 

2.1.1  Effective implementation of EU export controls under the Dual-Use Regulation 

In  2024,  the  Commission  and  the  Member  States  continued  the  implementation  of  the 
Regulation 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 ‘institutional 
infrastructure’ for EU export controls through the activities of several expert groups working 
to develop new policies, guidelines, procedures, etc. 

The Regulation also places emphasis on the control of exports of cyber-surveillance items. It 
addresses the potential risk of such items being exported from the  European Union with the 
intention of being misused in connection with serious violations of human rights or international 
humanitarian  law.  It  is  in  this  context  that  on  16 October  2024  the  Commission  published 
guidelines on the export of cyber-surveillance items pursuant to Article 5 of the Regulation to 
provide clarity primarily for exporters on how to conduct due diligence and internal compliance 
checks prior to exporting cyber-surveillance items7. 

7  Commission  Recommendation  (EU)  2024/2659  of  11 October  2024  on  guidelines  on  the  export  of  cyber-
surveillance items under Article 5 of Regulation (EU) 2021/821 of the European Parliament and of the Council, 
C/2024/7035 (OJ L 2024/2659, 16.10.2024): http://data.europa.eu/eli/reco/2024/2659/oj. 

5 

 
 
 
 
 
 
2.1.2  Export controls under the Commission’s White Paper 

The Commission’s White Paper, published on 24 January 2024 proposed short and medium-
term  actions  to  improve  the  coordination  of  export  controls  on  dual-use  items  in  the  EU. 
Amongst the key measures proposed by the Commission were (1) inclusion in the EU control 
list (Annex I) of dual-use items that have not been subject to controls in the multilateral regimes 
due to delays in decision making; (2) a senior-level forum for political coordination on export 
controls;  (3)  a  mechanism  to  better  coordinate  new  national  control  lists;  and  (4)  an  early 
evaluation  of  the  EU’s  Dual-Use  Regulation.  The  White  Paper  was  subject  to  a  public 
consultation which ran from 2 February until 30 April 2024, to which 23 replies were received, 
informing the Commission’s internal deliberations. Since the publication of the White Paper, 
the Commission has been actively moving forward on each of those measures. The Council of 
the European Union responded to the White Paper in its Conclusions adopted in spring 20248. 

2.1.3  Export restrictions concerning products destined for Russia 

Throughout 2024, the European Union continued to actively tighten dual-use export restrictions 
in the context of sanctions against Russia, including through the adoption of three packages of 
sanctions, in particular expanding export restrictions on dual-use ‘advanced technology items’, 
in  light  of  information  from  the  battlefield,  and  targeting  entities  associated  with  Russia’s 
military-industrial facilities both in Russia and in non-EU countries9. In September 2024, the 
Commission published guidance for industry which had been developed and agreed by the G7 
members and the Commission, to assist industry in better identifying Russia’s sanctions evasion 
practices,  to  protect  G7  technology  from  misappropriation,  prevent  reputational  harm  and 
mitigate liability risk while supporting the effectiveness of export controls and sanctions10. 

In  addition,  the  Commission  and  the  Member  States  were  active  participants  in  the  global 
coalition on Russia sanctions (GECC)11, whose 39 members have implemented substantially 
similar export controls in response to Russia’s full-scale invasion of Ukraine in February 2022. 
The GECC aims to cut 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. 

2.1.4  Cooperation with non-EU countries in 2024 

The sixth ministerial meeting of the EU–US Trade and Technology Council (TTC) took place 
in Leuven on 4-5 April 202412. Both the EU and the US recognised the role of the EU-US TTC 

8 European Council, Conclusions of the European Council meeting (ST 9439 2024 COR 1). 
9  Council  of  the  EU,  Press  Release  ‘Russia’s  war  of  aggression  against  Ukraine:  EU  adopts  15th  package  of 
restrictive 
measures’:https://www.consilium.europa.eu/en/press/press-releases/2024/12/16/russia-s-war-of-
aggression-against-ukraine-eu-adopts-15th-package-of-restrictive-measures/. 
10  Preventing  Russian  Export  Control  and  Sanctions  Evasion:  Updated  Guidance 
https://finance.ec.europa.eu/news/sanctions-vis-vis-russia-commission-publishes-g7-industry-guidance-
preventing-sanctions-evasion-2024-09-24_en. 
11  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. 
12 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 its ten working groups is dedicated to export controls, sharing information and working on topics 
like  legislative  and  regulatory  developments,  risk  assessments  and  licensing  good  practices,  as  well  as  on 

Industry: 

for 

6 

 
 
 
 
in  coordinating  export  controls  imposed  in  response  to  Russia’s  invasion  of  Ukraine  and 
resolved to further align their respective priorities13. 

On  8-9 October  2024,  the  Commission  hosted  the  Fourth  Dialogue  on  Export  Control 
Governance in Brussels under the title ‘Catch-all Controls and Recommendations on Related 
Internal  Compliance  Programs  for  Companies’,  organised  under  the  EU’s  partner-to-partner 
(EUP2P)  export  control  programme  and  involving  partner  countries  and  organisations.  The 
Dialogue  served  to  strengthen  networking,  raise  awareness  and  build  capacity  among  the 
EUP2P partner countries and relevant stakeholders regarding the implementation and practical 
application of catch-all export controls and related compliance practices under the EU strategic 
trade control frameworks. 

Finally, the EU and Norway held an EU-Norway Export Control Dialogue on 6 February 2024. 
The parties discussed the regulatory developments in the field of export controls, shared their 
views on destinations of concern and discussed the sanctions against Russia. Norway informed 
the EU of its plans to establish a new department for export control and sanctions (DEKSA) 
which will be in charge of analysis, licensing and enforcement. 

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 due to 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 i.e. the Wassenaar Arrangement, the Australia Group, the 
Nuclear Suppliers Group and the Missile Technology Control Regime (MTCR). 

On 5 September 2024, the Commission adopted an annual update to Annex I, which entered 
into force on 8 November 2024, bringing the EU’s Dual-Use Regulation into line with decisions 
formally  taken  as  part  of  the  multilateral  regimes  in  202314.  The  updated  list  includes  new 
entries  in  the  field  of  nuclear  plants  and  equipment,  as  well  as  additional  toxins,  chemical 
precursors and noise reduction equipment. 

2.3.  National implementation and enforcement measures 

The Dual-Use Regulation is binding in its entirety and directly applicable in all Member States. 
It includes, in its Annex I, a common list of items derived from the multilateral export control 
regimes  that  must  be  subject  to  controls  in  all  Member  States.  However,  it  provides  that 
Member  States  may  take  certain  national  measures  to  implement  specific  provisions  of  the 
Regulation,  and  it  requires  information  on  such  national  measures  to  be  published  by  the 
Commission  in  the  Official  Journal  of  the  European  Union.  The  publication  ensures 

approaches to industry compliance and enforcement. Furthermore, this working group aims to promote convergent 
control approaches on sensitive dual-use technologies and to perform joint industry outreach activities on dual-use 
export controls. 
13 Press release: ‘EU and US continue strong trade and technology cooperation at a time of global challenges’, 
5 April 2024: https://ec.europa.eu/commission/presscorner/detail/en/ip_24_1827. 
14  COMMISSION  DELEGATED  REGULATION  (EU) …/…  amending  Regulation  (EU)  2021/821  of  the 
European 
items: 
the  Council 
https://policy.trade.ec.europa.eu/news/2025-update-eu-control-list-dual-use-items-2025-09-08_en. 

Parliament 

dual-use 

regards 

and 

list 

the 

of 

of 

as 

7 

 
 
 
transparency of the applicable rules and reflects the EU’s efforts to support the consistent and 
effective implementation of controls by exporters throughout the EU. 

The  Information  Note  published  on  2 October  202415  provided  information  from  Member 
States about how they make use of the possibilities provided for in the Regulation including 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. 

2.4 

Exports from Northern Ireland 

Exports of dual-use items from the EU to the United Kingdom became subject to control under 
the Regulation after the United Kingdom’s departure from the European Union on 1 January 
202116.  Specific  arrangements  are  set  forth  in  the  Northern  Ireland  (NI)  Protocol17,  which 
provides that the Regulation applies to the United Kingdom in respect of Northern Ireland18, 
with the UK acting as a competent authority under the Regulation for exports from Northern 
Ireland to non-EU countries. The Commission has developed a dedicated secure electronic tool 
to  support  the  exchange  of  information  with  the  United  Kingdom’s  competent  authority  in 
charge  of  applying  the  Regulation  in  respect  of  the  flow  of  goods  into  and  from  Northern 
Ireland,  which  was  used  throughout  2024.  This  enables  the  United  Kingdom  authorities  to 
access information on denials for essentially identical transactions issued by EU Member States 
and  to  hold  bilateral  consultations  with  the  issuing  Member  States,  as  provided  for  in  the 
Regulation. 

3. 

ACTIVITIES OF THE DUAL-USE COORDINATION GROUP 

The  Dual-Use  Coordination  Group  (DUCG),  chaired  by  the  Commission,  brings  together 
experts  from  the  Commission  and  Member  States  to  examine  any  issue  concerning  the 
application of export controls19. In 2024, the DUCG held eight meetings: on 16 January, 14 
March, 16 May, 3 July, 12 September, 4 October, 6 November and 11 December. 

3.1. 

Consultations on implementation issues - general information exchange 

The Commission and Member States’ representatives in the DUCG exchanged information on 
export control issues, regarding, in particular:  

- the implementation of intangible transfers of technology (ITT);  

- national general licences; 

- large project authorisations; 

- the definition of ‘exporter’; 

15 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:C_202405881. 
16 The UK has been added to EU General Export Authorisation EU001 in the meantime. 
17 OJ L 29, 31.1.2020, p. 7 (‘Withdrawal Agreement’). 
18 Article 5(4) of the NI Protocol and Section 47 of Annex 2 to that Protocol. 
19  This  report  is  also  the  annual  report  required  under  the  Regulation  on  the  activities,  examinations  and 
consultations of the DUCG. 

8 

 
 
 
- the interpretation of Article 16(1) of the Regulation; 

- the implementation of transit controls; 

- the implementation of technical assistance controls; 

- re-export of Union goods onwards from non-EU countries; and  

- treatment of goods temporarily brought into the Union. 

3.2 

Guidelines 

Following discussions within the DUCG, the Commission published guidelines for exporters 
of cyber-surveillance technologies and guidelines for gathering and processing data on export 
controls. 

First, the Commission published guidelines on data gathering and processing for export controls 
on 17 January 202420. Those guidelines establish detailed procedures for collecting licensing 
data from national authorities to enhance transparency and information sharing. This enables 
the EU’s annual export control report to include more detailed statistics on authorisations and 
denials. By improving public reporting, the guidelines aim to provide exporters, civil society 
and the public with a clearer picture of EU export control implementation, support dialogue 
with non-EU countries and promote good reporting practices internationally. 

Second,  on  16 October  2024,  the  Commission  published  guidelines  for  exporters  of  cyber-
surveillance items with the intention to raise awareness of the risks of such items being misused 
and to provide exporters with practical tools to assess the possible human rights impacts of such 
misuse21. The guidelines aim to make EU export controls more effective and consistent across 
Member  States  by  helping  exporters  conduct  due  diligence  checks  through  a  step-by-step 
approach to  transaction  screening.  The guidelines strengthen the  ‘protect’ pillar of the 2023 
European economic security strategy by promoting responsible and secure export practices. 

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  they  engaged  in  discussions  on  several  specific 
implementation issues, as mentioned above. 

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

20 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 (OJ L 2024/214, 17.1.2024): http://data.europa.eu/eli/reco/2024/214/oj. 
21  Commission  Recommendation  (EU)  2024/2659  of  11 October  2024  on  guidelines  on  the  export  of  cyber-
surveillance items under Article 5 of Regulation (EU) 2021/821 of the European Parliament and of the Council, 
C/2024/7035 (OJ L 2024/2659, 16.10.2024): http://data.europa.eu/eli/reco/2024/2659/oj. 

9 

 
 
 
The enforcement coordination mechanism (ECM), set up in accordance with Article 25 of the 
Regulation, met six times in 2024 to support the exchange of information and direct cooperation 
between competent authorities and enforcement agencies of the Member States. 

Finally,  the  Capacity  Building  Technical  Expert  Group  (CB-TEG)  held  its  third  and  fourth 
progress  meetings  on  13  March  and  17 May  2024,  which  were  dedicated,  respectively,  to 
identifying the priorities for 2024 and to selecting the topic for the annual capacity-building 
event and setting up teams in charge of its organisation. Subsequently, an EU capacity-building 
technical seminar on dual-use restrictive measures was held in Budapest on 18 September 2024, 
hosted  by  the  Hungarian  Presidency,  back-to-back  with  the  17th  JRC-NNSA22  licensing 
seminar  on  the  same  topic  but  with  complementary  lectures  and  more  extended  non-EU 
attendance. 

Technical  support  for  the  preparation  of  updates  to  the  EU  control  list  and 

3.4 
national implementing measures 

The DUCG held a technical information session on 14 March 2024 to support the preparation 
of  the  proposal  for  a  Commission  delegated  regulation  updating  the  EU  control  list.  The 
Commission adopted the delegated act on 5 September 2024. 

The  DUCG  also  contributed  to  the  update  of  the  official  information  notice  on  national 
measures  published  on  2 October  2024  and  the  revision  of  the  EU  compilation  of  national 
control lists on 27 September 202423. 

3.5 

Licensing and implementation data exchange 

The DUCG initiated the collection of 2022-2023 licensing data under the 2024 guidelines on 
data gathering and processing, with a view to supplementing the annual report published on 
30 January 2025. 

IT tools for the exchange of information among Member States and for electronic 

3.6 
licensing 

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

DUeS functionalities were developed or updated, as follows: 

1.  allowing Member States to share with the Commission licensing data, as mandated in 
Article 26(3) of the Dual-Use Regulation, in accordance with the guidelines developed 
with  the  Member  States  on  data  gathering  and  processing  on  export  controls 
(transparency guidelines); 

22 United States National Nuclear Security Administration (NNSA). 
23 Information Note – Regulation (EU) 2021/821 of the European Parliament and of the Council setting up a Union 
regime for the control of exports, brokering, technical assistance, transit and transfer of dual-use items: Information 
on  measures  adopted  by  Member  States  in  conformity  with  Articles  4,  5,  6,  7,  8,  9,  11,  12,  22  and  23 
(PUB/2024/740), OJ C/2024/5881, 2.10.2024: http://data.europa.eu/eli/C/2024/5881/oj. 

10 

 
 
 
2.  allowing Member States to notify the Commission of the imposition of an authorisation 

requirement on the basis of a national control list, pursuant to Article 10; 

3.  allowing  voluntary  exchange  of 

the 
implementation of Articles 9 and 10, as foreseen in the Commission Recommendation 
2025/683 on the coordination of national control list24; and 

information  among  Member  States  on 

4.  existing functionalities were updated, in particular with reference to the management of 
exemptions/authorisations and denials related to the restrictive measures against Russia 
and Belarus, and with reference to the database of items subject to control pursuant to 
the Regulation. 

2024 was the fourth year of operation of the dual-use eLicensing system, which was used during 
the reporting period by Latvia, Romania, Italy, Slovenia and Belgium (Walloon authorities). 
Hungary and Belgium (Brussels Region) expressed an interest in joining the project. 

Beyond the EU, and as part of its cooperation with partner countries, the Commission explored 
the possibility of providing the eLicensing tool to partner countries. Bosnia and Herzegovina, 
Kyrgyzstan and Serbia expressed interest in using the tool. 

The  eLicensing  project  continuously  improves  the  interconnection  of  the  national  customs 
systems  via  the  EU  Single  Window  Environment  for  Customs.  This  makes  the  sharing  of 
information  across  borders  with  different  customs  authorities  much  easier,  reducing  the 
regulatory  burden  on  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  systems  has  been  operational 
since December 2022. The Romanian customs authorities have been part of the system since 
April 2024. 

At the request of the Member States that already used electronic licensing systems, in April 
2022 the Commission initiated a new ‘eLicensing bridge’ project to make it possible to connect 
national licensing systems to customs systems through eLicensing. Finland was part of the pilot 
project and tested the interconnection in 2024. 

4. 

EU EXPORT CONTROLS – KEY DATA 

Article 26  of  the  Regulation  provides  that  the  European  Commission’s  annual  report  on  the 
implementation  of controls  must include relevant  information  on authorisations,  denials  and 
prohibitions, as well as information on the administration and enforcement of such controls. 

This Section presents EU aggregated export control data for the reference year 2024. Due to 
their  volume,  the  underlying  data  provided  by  Member  States  are  presented  in  consolidated 
form in the staff working document that accompanies this report. 

The  data  have  been  made  available  in  accordance  with  specific  reporting  guidelines  (‘the 
Guidelines’)25. Under these guidelines, the data collection methodology is designed to remain 

24 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32025H0683. 
25  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’). 

11 

 
 
 
sustainable  over  time,  allowing  Member  States  to  provide  relevant  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 information on defence, foreign policy or national security. 

4.1  Methodological notes 

The Regulation primarily applies to the export of over 1 800 dual-use items listed in the EU 
control list, classified in 10 categories (Figure 3). That is the underlying rationale that led the 
EU to group the entries in Annex I to the Regulation in ‘types of items’ for the purpose of the 
EU annual report26. 

Figure 3: Number of dual-use items listed in the 10 categories of Annex I to the Regulation 

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 determining the types 
of items would build on the specific classification of dual-use items used in the Regulation at 
5-digit level while ensuring that the heading ‘types of items’ provides meaningful information 
from a security, policy and trade perspective27. 

Annex A to the Guidelines describes the list of 52 ‘types of items’ used for collecting licensing 
data and preparing this annual report. Authorisations are broken down by type of item and by 
relevant  destination  in  line  with  the  requirements  of  the  Regulation,  while  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 specific features 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  type28.  The  methodology  also 

26 Cf. Article 26(2) of the Regulation. 
27 E.g. ECCN 0A001: Nuclear reactors. 
28  This  includes  voluntary  data  on  uses  of  national  general  export  authorisations  and  EU  general  export 
authorisations. The data in these figures do not cover all 27 EU Member States. 

12 

 
 
 
 
acknowledges  that  authorisations  may  refer  to  more  than  one  individual  item  falling  under 
various types of items. 

Concerning cyber-surveillance items, the definition set out in Article 2(20) of the Regulation 
comprises  both  the  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 set out 
in Article 2(20). The 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  Surveillance  Technology  Expert  Group  (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 the 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 licence29 

In 2024, the total value of authorised dual-use trade amounted to EUR 77.6 billion, representing 
3% of extra-EU exports of goods (Figure 4) and an increase compared to 2023 (EUR 71 billion). 
In  terms  of  numbers,  that  corresponds  to  133 470  authorisations  and  notifications30.  With 
respect  to  the  types  of  authorisations,  most  transactions  fall  under  EU  general  export 
authorisations (89 388), national general export authorisations (23 406) and individual licences 
(18 549), which mirrors the ranking in 2023. In terms of value, the types of licences having the 
highest weighting were global export authorisations (EUR 36.5 billion, 47% of total authorised 
trade), individual export authorisations (EUR 24 billion, 31% of total) and EU general export 
authorisations (EUR 9 billion, 12% of total). 

4.3 

Denials and prohibitions 

In 2024, 487 denials were reported for a value of EUR 0.2 billion. Those figures show that only 
a small portion of EU exports were denied (0.01% of total extra-EU exports of goods that year). 
This  represents  both  a  lower  number  and  a  lower  value  of  denials  compared  to  2023  but 
accounts for the same percentage of extra-EU exports. 

29 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 5 below. 
30  This  includes  voluntary  data  on  uses  of  national  general  export  authorisations  and  EU  general  export 
authorisations. 

13 

 
 
 
Figure 4: Export authorisations by type of licence 

4.4 

Individual authorisations 

Individual  authorisations  are  licences  granted  to  one  specific  exporter  for  one  end-user  or 
consignee in a non-EU country and covering one or more dual-use items. As specified in the 
Guidelines, the following items are all considered individual licences 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. 

The overview of individual authorisations in 2024 by the 10 categories of items in Annex I to 
the Regulation as well as non-listed items subject to controls (Figure 5) indicates that the highest 
number of authorisations in terms of market value was granted to Nuclear materials, facilities 
and  equipment  (EUR 12.2  billion,  36%  of  total).  Telecommunications  and  ‘information 
security’  came  second  (EUR 6.7  billion,  20%  of  total),  and  Aerospace  and  propulsion  third 
(EUR 4.6 billion, 13% of total). Concerning the volume of individual authorisations, the largest 
figure  was  recorded  for  Materials  processing  (5 891,  27%  of  total),  followed  by 
Telecommunications and ‘information security’ (4 405, 20% of total) and Special materials and 
related equipment (4 293, 20% of total). 

14 

 
 
Figure 5: Individual export authorisations by category of items in Annex I to Regulation (EU) 
2021/821 

Breaking down the value of individual authorisations by type of items (Figures  6.1 and 6.2) 
shows that the top five items are Nuclear materials, facilities, plants and equipment (EUR 9.2 
billion, 27% of total), Information security and crypto-analysis items and equipment (EUR 5.5 
billion, 16% of total), Aerospace engines and gas turbines (except UAV) (EUR 3.5 billion, 10% 
of total), Other/non-listed items  (EUR  3.2 billion, 9% of total), and  Technology  for nuclear 
materials facilities and equipment (EUR 2.1 billion, 6% of total). 

15 

 
 
 
Figure 6.1: Individual export authorisations by type of items (Part 1) 

16 

 
 
 
Figure 6.2: Individual export authorisations by type of items (Part 2) 

17 

 
 
 
Of the destinations covered by individual authorisations (Figures 7 and 8), China was the top 
destination by value (EUR 9.6 billion, 36% of total), followed by the United States (EUR 2.7 
billion,  10%  of  total),  South  Korea  (EUR 2.6  billion,  10%  of  total),  the  United  Kingdom 
(EUR 1.2 billion, 5% of total) and India (EUR 1 billion, 4% of total). Overall, the top 25 extra-
EU destinations account for 94% of individual authorisations by value31. With respect to intra-
EU  transfers,  the  main  destinations  were  Hungary  (EUR 704  million),  France  (EUR 507 
million),  Belgium  (EUR 458  million),  Germany  (EUR 324  million)  and  the  Netherlands 
(EUR 234 million). Compared to extra-EU destinations, intra-EU transfers appear to be limited 
because  most  intra-EU  dual-use  exports  do  not  need  to  be  authorised  under  the  Regulation. 
Instead, export control authorisations for exports of dual-use items to another EU Member State 
are only  required  in  specific circumstances under the Regulation,  such as for items  listed in 
Annex IV to the Regulation pursuant to Article 11(1) or based on measures taken by a Member 
State pursuant to Article 11(8) of the Regulation. 

Figure 7: Individual export authorisations by destination 

31 Please note that export authorisations with a destination to the Russian Federation correspond to  trade taking 
place  under  the  limited  exemptions  and  derogations  under  the  EU’s  Russia  sanctions  regime.  See  Council 
Regulation  (EU)  No 833/2014  of  31 July  2014  concerning  restrictive  measures  in  view  of  Russia’s  war  of 
aggression against Ukraine. 

18 

 
 
 
 
Figure  8:  Individual  export  authorisations  by  top  extra-EU  destinations  and  by  intra-EU 
destinations 

4.5  Global export authorisations 

Global export authorisations most often contain estimated or open-ended export values and are 
granted either for one or multiple items for a single destination or for one or multiple items for 
multiple  destinations.  As  such,  global  authorisations  reduce  administrative  burden  for 
competent  authorities  and  exporters  when  handling  similar and/or  frequent  transactions.  To 
safeguard non-proliferation objectives, exporters are required to draft and submit an internal 
compliance programme in order to qualify for a global authorisation. As the Regulation leaves 
it  up  to  individual  Member  States  to  decide  on  the  concrete  configuration  of  global 
authorisations, practices vary from one EU country to another. 

19 

 
 
 
To provide meaningful information to the public while taking into account the different national 
practices and the rationale behind global export authorisations, the Guidelines have adapted the 
relevant data collection and reporting standards. Member States provide licensing data to the 
Commission  accordingly,  with  a  focus  on  (i)  the  total  value  of  global  export  authorisations 
(EUR 36.5 billion, equivalent to 47% of authorised value in 2024) and (ii) a breakdown of the 
total  volume  of  global  licences  by  type  of  items  (Figures  10.1  and  10.2)  and  destinations 
(Figures 11.1 and 11.2). 

By category of items in Annex I to the Regulation (Figure 9), the majority of authorisations 
were  granted  for  items  listed  under  Telecommunication  and  ‘information  security’  (31%  of 
total), Materials processing (19%) and Sensors and lasers (13%). 

The top five types of items covered by global export authorisations (Figures 10.1 and 10.2) are 
Information  security  and  crypto-analysis  items  and  equipment  (19%  of  total),  Optical  and 
acoustic  equipment,  related  components  and  materials;  other  sensors  (11%),  Explosives, 
propellants  and  related  equipment  (10%),  Software  for  telecommunications  and  information 
security  (8%)  and  Toxic  chemicals,  precursors,  pathogens,  toxins  and  genetically-modified 
organisms, related protective and detection equipment and components (8%). 

Figure  9:  Global  export  authorisations  by  category  of  items  in  Annex  I  to  Regulation  (EU) 
2021/821 

20 

 
 
Figure 10.1: Global export authorisations by type of items (Part 1) 

21 

 
 
Figure 10.2: Global export authorisations by type of items (Part 2) 

22 

 
 
 
Concerning destinations (Figures 11 and 12), the majority of authorisations by volume were 
granted for exports to China (3%), India (2%), Taiwan (2%), Brazil (2%) and Singapore (2%). 
Overall, the top 25 destinations account for only 37% of authorisations by volume of global 
export authorisations, as a global licence often covers multiple destinations32. 

Figure 11: Global export authorisations by destination 

32 Ibid. 

23 

 
 
 
Figure 12: Global export authorisations by top destinations 

24 

 
 
 
 
 
 
4.6 

National and EU general export authorisations 

National and EU general export authorisations (GEAs) are issued to facilitate trade in dual-use 
items  while  reducing  the  administrative  burden  for  exporters  and  export  control  authorities 
alike. EU general export authorisations (EU GEAs) provide the highest level of trade facilitation 
for  dual-use  goods.  They  are  granted  to  EU  exporters  who  comply  with  the  relevant  pre-
conditions established in the Regulation. The Regulation provides for eight types of EU GEAs33. 

The vast majority of uses of EU GEAs in 2024 (Figure 13) corresponded to EU001 (99% in 
terms of value, 99% of volume), for exports to the 10 destinations set out in the authorisation. 

Figure 13: 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. 

Figure  14  breaks  down  the  value  of  EU  and  national  GEAs  by  the  categories  included  in 
Annex I  to  the  Regulation.  The  highest  values  correspond  to  Telecommunications  and 
‘information security’ (EUR 3.5 billion, 44% of total), Electronics (EUR 3.3 billion, 42% of 
total), and Materials processing (EUR 0.3 billion, 4% of total). 

33 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 

25 

 
 
 
 
 
Figure 14: 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 type of items (Figures 15.1 and 15.2) 
indicates  that  the  top  five  items  are  Information  security  and  crypto-analysis  items  and 
equipment  (EUR 3.5  billion,  44%  of  total),  Equipment  for  the  manufacturing  and  testing  of 
semiconductor devices or materials (EUR 3.2 billion, 40% of total), Machines tools and systems 
and components for industrial equipment (EUR 0.2 billion, 2% of total), UAV and propulsions 
therefor (EUR 0.2 billion, 2% of total) and Lasers, related equipment and materials (EUR 0.1 
billion, 2% of total). 

26 

 
 
 
Figure 15.1: EU and national general export authorisations by type of items (Part 1) 

27 

 
 
 
Figure 15.2: EU and national general export authorisations by type of items (Part 2) 

28 

 
 
 
Of the destinations authorised under EU and national GEAs, the top five were the United States 
(EUR 5.3 billion, 55% of total), the United Kingdom (EUR 1.5 billion, 16% of total), Norway 
(EUR 0.6 billion, 6% of total), Switzerland (EUR 0.6 billion, 6% of total) and Japan (EUR 0.3 
billion, 4% of total). This indicates that the large majority of the dual-use exports covered by 
GEAs are directed towards countries listed in EU GEA EU001, also reflecting the fact that the 
value of exports authorised under EU GEAs is much higher than under national GEAs (EUR 9 
billion versus EUR 1 billion, as per Figure 4). 

Figure 16: EU and national general export authorisations by destination 

29 

 
 
 
Figure 17: EU and national general export authorisations by top destinations 

30 

 
 
 
 
 
 
4.7 

Registered users of national and EU general export authorisations 

In order to provide information on exporters’ notifications in accordance with the Regulation34, 
the annual report includes data on the number of exporters that have notified or are registered 
with the competent authority to use EU or national general export authorisations. 

In 2024, a total 12 093 exporters were using EU general export authorisations, of which 50% 
of  them  were  using  EU001,  and  37%  of  exporters  were  using  national  general  export 
authorisations. With respect to first-use notifications or registrations in 2024, the figures were 
1 044 for EU GEAs (45% for EU001) and 644 for national GEAs. 

Figure  18:  Exporters  registered  or  notified  to  use  EU  and  national  general  export 
authorisations 

5.  DATA ON DUAL-USE ITEMS CLASSIFIED AS CYBER-SURVEILLANCE ITEMS ACCORDING 

TO ARTICLE 2 (20) OF THE REGULATION 

In 2024, Member States received a total of 320 applications (Figure 19) for the export of cyber-
surveillance  items,  mostly  in  relation  to  telecommunications  interception  systems  (233 
applications), followed by communication monitoring software (46 applications) and intrusion 
software (18 applications). Figures 20.1 and 20.2 show the 71 destinations of applications for 
the export of cyber-surveillance items. In 2024, 293 authorisations were issued and 13 denied. 

34 In accordance with the provisions for EU general export authorisations in Annex II to the Regulation,  [t]he 
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. 

31 

 
 
 
 
 
This shows a rather stable number of licences for cyber-surveillance items (330 licences issued 
in 2023), signalling an end to the upward trend observed since 2020. The number of denials for 
the export of cyber-surveillance items35 appeared to be decreasing (20 denials in 2023). 

Figure 19: Applications for the exports of cyber-surveillance items36 

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

32 

 
 
 
 
 
 
Figure 20.1: Applications for the exports of cyber-surveillance items by destination 

Figure 20.2: Applications for the exports of cyber-surveillance items by destination 

6.  INFORMATION ON ADMINISTRATION AND ENFORCEMENT 

Member  States  communicated  the  following  information  on  the  administration  and 
enforcement of the Regulation in 2024: 

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

in the EU: 415; 

b)  number of outreach events organised in the reference year: 154; 

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

customs or other agencies: 1 353; 

d)  number of infringements reported: 270; 

33 

 
 
 
e)  number  of  administrative  and  criminal  penalties  or  fines  imposed  (by  any  relevant 
national enforcement agency) in case of infringement of export control regulations: 144; 
and 

f)  use of export control tools: 

−  Member States using the e-licensing system37: 19; 

−  Member States using classification tools38: 4; and 

−  Member States using other tools or software to support the application of controls: 9. 

37  e-Licensing  is  a  web-based platform  to  request  authorisations  for  exporting, brokering,  technical  assistance, 
transit and transfer of dual-use items, such as software and technology. 
38 Such tools can assist exporters and national authorities in classifying items. 

34