Export control - Dual-use goods
Dual-use goods classification per EU Annex I 2021/821. 378 ECN entries, technical thresholds, sanctions screening.
The Trade Hub's export control tool determines whether a good, technology or software is subject to export controls under the European dual-use regulation (EU 2021/821). It draws on the entirety of Annex I and the Wassenaar Arrangement 2025 control lists.
This tool is a classification aid. It does not replace the legal analysis of an export control expert nor the exporter's regulatory responsibility. In case of doubt, consult the relevant national authority (e.g. the French SBDU) or a specialized lawyer.
Regulatory context
Regulation EU 2021/821 requires every European exporter to verify whether their goods appear on the control list (Annex I) before any export outside the EU. This obligation covers:
- Physical goods (equipment, components, materials)
- Software specifically designed or modified for controlled purposes
- Technology required for the development, production or use of controlled goods
- Catch-all: unlisted goods intended for military or proliferation end-use
Non-compliance carries criminal penalties and potential suspension of export licenses.
Database
| Source | Volume | Detail |
|---|---|---|
| Annex I EU 2021/821 | 378 ECN entries | European Control Number - 10 categories (0-9) |
| Sub-entries | 2,287 | Detailed technical descriptions |
| Technical thresholds | 1,030 | Measurable parameters triggering control |
| Wassenaar Arrangement 2025 | Integrated | Updated multilateral control list |
The 10 Annex I categories
| Category | Domain |
|---|---|
| 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 |
How it works
Classification pipeline
The tool follows a structured multi-phase pipeline:
1. Intelligent triage
The user describes the good to be exported (nature, technical specifications, destination, end-user). The tool evaluates whether the information provided is sufficient for a reliable classification. If technical specifications are incomplete, clarification questions are asked.
Clarification questions do not consume quota. Only the final classification is counted.
2. Control database search
The pipeline queries our knowledge base containing the entirety of Annex I:
- Semantic search across technical descriptions of 2,287 sub-entries
- CN/ECN correlation (mapping between Combined Nomenclature codes and European Control Numbers)
- Reranking to isolate the most relevant ECN entries
3. Agentic classification
A reasoning model analyzes candidate ECN entries with specialized tools:
- Technical threshold verification: comparison of the good's specifications against 1,030 measurable Annex I thresholds (frequency, power, accuracy, resolution, etc.)
- Sanctions screening: verification of destination and end-user
- Catch-all assessment: diversion risk analysis even for unlisted goods
4. Structured result
The classification returns an immediately actionable verdict.
Results
| Element | Description |
|---|---|
| Status | Controlled or not controlled |
| ECN | Applicable European Control Number (e.g. 3A001, 5A002) |
| Thresholds triggered | Technical parameters exceeding limit values |
| License required | Type of export license needed |
| Catch-all risk | Diversion risk assessment |
| Justification | Detailed reasoning with Annex I references |
Interactive mode
The tool operates in conversational mode (SSE). The user progressively describes their good, the tool asks clarification questions if specifications are insufficient, then produces the full classification.
Each classification is saved in a session that can be consulted later. Sessions can be bookmarked for reference.
Who this tool is for
| Profile | Use case |
|---|---|
| Compliance officers | Systematic screening of goods before export |
| Exporters | Quick control status check for a product |
| Freight forwarders | Identification of goods requiring a license |
| Specialized lawyers | Regulatory analysis and compliance documentation |
| Consultants | Audit of clients' export compliance programs |
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