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Regulation (EU) 2021/821

Export Control - Dual-Use Items

EU export control brings together all the rules that determine whether a product requires an export licence. Regulation 2021/821, Annex I, Wassenaar Arrangement, catch-all - everything is here, structured and navigable.

Regulation (EU) 2021/821 of 20 May 2021 establishes the EU regime for the control of exports of dual-use items. It applies to any exporter established in the EU who wishes to ship goods, software or technology listed in Annex I or likely to be diverted for military purposes (catch-all clause, Articles 4 and 5).

378
ECN entries
2 345
sub-entries
1 117
technical thresholds
158
Case law

Resources

Annex I - Control List

378 ECN entries, 10 categories, 2,287 sub-entries, 1,030+ technical thresholds. Browsable by category.

6 211

CN - ECN Correlation

6,211 mappings between Combined Nomenclature (CN) codes and Export Control Numbers (ECN). Indicative DG TAXUD table.

158

Case law

97 real enforcement cases: BIS sanctions, criminal prosecutions, BAFA, ECJU, SBDU decisions. ECNs cited and legal findings.

Practical guides

Encryption (5A002 & Crypto Note), catch-all (Art. 4 & 5), EU export license procedures.

Technical glossary

30 definitions and 121 technical acronyms from Regulation (EU) 2021/821 and the Wassenaar Arrangement.

Countries & destinations

19 embargoed countries, 28 high-risk countries, EU001 authorized destinations. Risk scores and legal bases.

EU authorizations

8 EU General Export Authorizations (EU001-EU008), conditions, exclusions and Annex IV items.

How export control analysis works

1

Specification extraction

The AI extracts key technical parameters from your description: frequencies, data rates, accuracies, power levels, wavelengths.

2

Annex I search

Vector search across 378 ECN entries and 2,287 sub-entries. Each specification is compared against control thresholds.

3

Technical threshold verification

Systematic comparison of each technical parameter against regulatory thresholds. A single exceedance triggers control.

4

Decontrol notes and exceptions

Verification of decontrol notes (Crypto Note, GSN, Software Note) that may exempt a product from control even if thresholds are exceeded.

5

Catch-all and sanctions screening

Catch-all risk assessment (Articles 4 and 5) for non-listed items that may be diverted for military use. Screening against EU, UN and OFAC sanctions lists.

Regulatory framework

Regulation (EU) 2021/821

Legal basis of the EU export control regime. Latest update: Delegated Regulation (EU) 2025/2003 (in force since 15 November 2025). Defines exporter obligations, licensing procedures and control measures.

Catch-all clause (Articles 4 and 5)

Even if your product is not listed in Annex I, a licence may be required if you know (or have grounds to suspect) that the product will be used for military purposes, for WMD, or in connection with internal surveillance in certain countries.

Wassenaar Arrangement

Multilateral export control regime. 42 participating states coordinate their control lists. The EU Annex I transposes these lists at European level, with annual updates.

Frequently asked questions

What is a dual-use item?
A dual-use item is a product, software or technology that can be used for both civilian and military purposes. Examples: routers with advanced encryption, high-power industrial lasers, precision inertial navigation units, multi-axis machine tools. Annex I of Regulation (EU) 2021/821 lists 378 ECN entries across 10 categories.
When do I need an export licence?
A licence is required in two cases: (1) your product is listed in Annex I and its technical specifications exceed the control thresholds, or (2) your product is not listed in Annex I but the catch-all clause applies (Articles 4 and 5) - for example if you know the end-user intends military or WMD-related use.
What is an ECN number?
The ECN (Export Control Number) is the unique identifier of an Annex I entry. It consists of a digit (category, 0-9), a letter (sub-category: A=Systems, B=Test, C=Materials, D=Software, E=Technology) and a sequential number. Example: 5A002 = Category 5 (Telecommunications), Systems, entry 002 (information security).
What is the catch-all clause?
The catch-all clause (Articles 4 and 5 of Regulation 2021/821) allows authorities to impose a licence requirement on items NOT listed in Annex I. It applies if the exporter knows (or has grounds to suspect) that the items will be used for weapons of mass destruction (WMD), military use in an embargoed country, or internal surveillance.
What are the 10 categories of Annex I?
0 - Nuclear materials, facilities and equipment. 1 - Special materials and related equipment. 2 - Materials processing. 3 - Electronics. 4 - Computers. 5 - Telecommunications and information security. 6 - Sensors and lasers. 7 - Navigation and avionics. 8 - Marine. 9 - Aerospace and propulsion.
What are decontrol notes?
Decontrol notes are exceptions built into Annex I entries that exempt certain products from control. The most well-known is the Crypto Note (5A002 Note 3) which exempts mass-market encryption products. Other important notes: the General Software Note (exemption for publicly available software) and the General Scientific Note (exemption for basic scientific research).
What is an EU General Export Authorisation (EU GEA)?
EU GEAs are pre-approved licences by the EU that simplify exports to certain destinations for certain types of goods. EU001 covers exports to Australia, Canada, Japan, New Zealand, Norway, Switzerland, Liechtenstein, the United Kingdom and the United States. Other EU GEAs exist for repairs, telecommunications, etc.
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