New EU rules on dual-use items: what do they mean for EU exporters?

Lourdes Catrain
Lourdes Catrain
Attorney-at-Law, Partner, Hogan Lovells International LLP, Belgium
Eleni Theodoropoulou
Eleni Theodoropoulou
Attorney-at-Law, Associate, Hogan Lovells International LLP, Belgium
Published 15 Oct 2021
New EU rules on dual-use items: what do they mean for EU exporters?
Topic spotlight
Sanctions
On 9 September 2021, the revised EU rules on exports of dual-use items set out in Regulation (EU) 2021/821 (“Recast Regulation”) came into force. While the Recast Regulation does not fundamentally change the EU rules underpinning dual-use exports, it brings new elements in the EU regime, aiming to make it apt to respond to modern challenges. This short article provides an overview of the most important changes and their impact on exporters.

Related content

View glossary entry

Territorial import bans: the ban set by origin, and the proof that lifts it

09 Aug 2026

What a territorial import ban is, the EU bans in force, and how goods clear one - by proving, in the right form, that they do not originate in the…

Sanctions
EU sanctions: where listed and what consequences

EU sanctions: where listed and what consequences

Aušra Šablinskienė
Aušra Šablinskienė
03 Aug 2026

On 23 July 2026, the Council of the European Union formally adopted its 21st package of restrictive measures against Russia - the largest single round of designations since the full-scale…

Sanctions
Topic spotlight
View glossary entry

Exporter of dual-use items: a definition that changes with the regulation

03 Aug 2026

Who counts as the exporter differs across the customs code, the dual-use regulation and the anti-torture regulation - and naming the wrong one can leave an export unlicensed.

Restrictions
Sanctions
View glossary entry

EU sanctions: the goods they restrict, and the national rules on top

03 Aug 2026

How EU sanctions restrict goods by commodity code, the national measures member states add on top, who must comply, and the penalties - the full EU picture for traders.

Sanctions
View glossary entry

EU sanctioned persons: who you cannot pay, supply or trade with

03 Aug 2026

Who is an EU sanctioned person, who designates them, and what is prohibited - including the 50% ownership rule that catches companies on no list, and the penalties.

Sanctions
View glossary entry

Making funds and economic resources available: what an asset freeze prohibits

01 Jun 2026

What the prohibition on making funds and economic resources available means under EU sanctions, why it reaches goods as well as money, and how it applies - with a worked…

Sanctions