is this listed on annex I?

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Analysis EU dual-use export control — “Is this listed on Annex I?” Definitive answer based on the information provided Because no item/technology/software has been identified in your request no name, specs, function, performance thresholds, or technical parameters, there is no objective basis to match it to any specific Annex I entry. Operationally, that means you must treat the item as “not confirmed as Annex I-listed” at this stage. So, in compliance terms: - Annex I status: NOT CONFIRMED / cannot be asserted as “listed”. - You should proceed as non-listed unless and until a technical classification exercise maps it to an Annex I control entry Category 0–9. - However, even if non-listed, it can still be licensable under catch‑all / end-use controls see below. This approach is aligned with the EU’s own guidance that exporters must classify against the EU control list and apply licensing where required. See Commission guidance pages on exporting dual-use items and the note on list updates. Sources: Exporting dual-use items – European Commissionhttps://policy.trade.ec.europa.eu/help-exporters-and-importers/exporting-dual-use-itemsen, 2025 update of the EU control listhttps://policy.trade.ec.europa.eu/news/2025-update-eu-control-list-dual-use-items-2025-09-08en --- Regulatory framework what “Annex I” means in practice What Annex I is - Annex I is the EU Control List under Regulation EU 2021/821 Dual-Use Regulation. Items listed there are controlled dual-use items and generally require export authorisation. Updates - The EU control list is updated periodically; the Commission communicated a list update in September 2025. Source: 2025 update of the EU control listhttps://policy.trade.ec.europa.eu/news/2025-update-eu-control-list-dual-use-items-2025-09-08en --- Practical determination method what you must do internally 1 Run an Annex I “technical match” classification against the control list Use the item’s technical description datasheet, performance, accuracy, frequency ranges, materials, cryptography functions, tolerances, radiation hardness, etc. to match it to: - Category 0–9 and subcategories A–E of Annex I - The control parameters thresholds in the entry text > Operational rule: a commercial description is never sufficient to confirm Annex I status; only a technical match is. Commission operational reference: Exporting dual-use items – European Commissionhttps://policy.trade.ec.europa.eu/help-exporters-and-importers/exporting-dual-use-itemsen 2 Apply “non-listed but still controlled” checks catch-all / end-use Even where Annex I is not matched, you must run: - End-user screening sanctions lists / military end-users where relevant - End-use screening WMD, missile, nuclear, military/intelligence end-use red flags - Destination risk embargoes / restrictive measures This is exactly why “not listed” does not equal “no licence risk”. Commission operational reference: Exporting dual-use items – European Commissionhttps://policy.trade.ec.europa.eu/help-exporters-and-importers/exporting-dual-use-itemsen --- Deliverables you should produce audit-proof To make your decision defendable to Customs / licensing authorities, generate and archive: - Annex I classification memo mapping to entries reviewed + rationale why “no match” - End-use / end-user due diligence file screening evidence, red flags, mitigations - Destination control assessment EU restrictive measures check - Contractual controls no re-export/forbidden end-use clauses where needed --- Sources as provided / most relevant - Exporting dual-use items – European Commissionhttps://policy.trade.ec.europa.eu/help-exporters-and-importers/exporting-dual-use-itemsen - 2025 update of the EU Control List of Dual-Use Items – European Commissionhttps://policy.trade.ec.europa.eu/news/2025-update-eu-control-list-dual-use-items-2025-09-08en --- > ⚠️ This analysis is provided for information only and does not constitute legal advice. For transactions engaging your liability, consult a licensed customs representative or specialised counsel.

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is this listed on annex I?