EU Adds Chip-Making Machines and Advanced Chips to Export Licence List

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EU Adds Semiconductor Tools and Advanced Computing Chips to Export Control List from November 2026

The European Union adopted a delegated regulation on September 14, 2026, updating the export control list for dual-use items in Annex I to Regulation (EU) 2021/821.

The European Commission on 14 September 2026 adopted a rule adding chip-making machines, advanced chips and other high-tech goods to the EU export control list, from its publication after a two-month review.

Dual-use items are goods, software and technology that have both civilian and military uses1. The EU list of these items sits in Annex I of Regulation (EU) 2021/821, the EU’s main law on dual-use exports2.

In short, more high-tech goods will need a licence before they leave the EU. A shipment of the newly listed goods cannot simply go out once the new list takes effect. The exporter must first hold the right export permit.

What did the Commission adopt on 14 September?

The Commission adopted a Delegated Regulation, a type of EU rule that the Commission writes to update an existing law2. This one changes Annex I, the list of controlled goods. Its Commission reference is C(2026)63232.

The update follows decisions taken in 2025 by three international groups2. These are the Wassenaar Arrangement, the Australia Group and the Nuclear Suppliers Group. These are groups of countries that agree which sensitive goods need export controls.

The update also includes extra items that EU member states agreed to control as members of the Wassenaar Arrangement2. With this change, all EU countries will control these items in the same way. The Commission says uniform controls keep a level playing field for businesses2.

Which chip and computer goods join the list?

The largest group of new items concerns the making and testing of computer chips. The Commission’s news release lists these examples2:

  • Atomic Layer Deposition machines for molybdenum and ruthenium
  • machines to develop and inspect Extreme Ultra-Violet masks and reticles
  • single wafer cleaning machines
  • advanced computer chips (integrated circuits) and electronic assemblies
  • chips with one or more Digital Processing Units

Atomic Layer Deposition machines put very thin layers of metal onto chips. Masks and reticles are the patterns used to print circuits onto silicon. Makers and sellers of these goods in the EU will face new licence checks when they ship them outside the bloc.

The Commission says the update gives more effective EU-level controls on new technologies2. It links the change to its 2024 White Paper on Export Controls2. That paper set out how to make EU export controls work better at a time of growing tension between countries1.

What other goods does the 2026 update cover?

The list also adds goods used in engines, factories and high-heat settings. The news release names these items2:

  • heat-resistant ceramic materials reinforced with mullite (Ceramic Matrix Composites)
  • rotary encoders, sensors that measure turning, based on inductive sensing
  • 3D printing machines for energetic materials, such as explosives and fuels
  • Chemical Vapour Deposition machines that make silicon carbide fibres
  • technology to develop axial compressors for gas turbine engines

The update also changes some control limits and rewrites some technical definitions2. A good that was not controlled before may now fall inside the list because of a new limit.

The Commission has published a Comprehensive Change Note Summary for the 2026 update2. It gives an overview of changes across the 10 categories of Annex I2. These categories run from nuclear materials to aerospace and propulsion systems3.

When do the new dual-use rules start?

The new list does not apply yet. It enters into force upon publication in the Official Journal, the EU’s official law gazette2. Publication follows the usual two-month scrutiny period for the Council and the European Parliament2.

From adoption to the new list

Commission adopts the rule 14 September 2026
Two-month review Council and European Parliament study the text
Publication in the Official Journal New list enters into force

During this two-month review, the two bodies can study the Commission’s text. The news release does not give an exact publication date. Counting two months from adoption points to mid-November 2026 at the earliest.

The same process ran last year. The Commission adopted the 2025 update on 8 September 20254. That update was later published as Delegated Regulation (EU) 2025/20031.

How does an EU dual-use export licence work?

Any item on Annex I needs an export authorisation, which is official permission to export3. The EU uses four types of permits1. EU General Export Authorisations are open permits for certain goods and destinations. National General Export Authorisations are issued by single EU countries.

What exporters of listed items must do

Hold an export authorisation For any item on Annex I
Get a permit to move Annex IV items Even between EU countries
Keep records and registers Under the regulation

A global licence lets one exporter ship many items to many countries1. An individual licence covers one exporter and one end user abroad1.

The EU general permits cover exports to Australia, Canada, Iceland, Japan, New Zealand, Norway, Switzerland, Liechtenstein, the United Kingdom and the United States1. Other general permits cover repairs, trade fairs, telecommunications, chemicals, encryption and transfers inside one company group1.

Inside the EU, most dual-use items move freely1. A few very sensitive items, listed in Annex IV, still need a permit to move between EU countries1. Exporters must also keep records and registers under the regulation1.

Why does the EU update the list each year?

The EU list is typically changed at least once a year through a Delegated Act2. Each change follows decisions in the international export control groups. The EU says working with other countries is the most effective way to protect international security2.

Yearly updates to the EU list

8 Sep 2025 2025 update adopted Quantum computers, chip machines
14 Sep 2026 2026 update adopted Chip-making machines, advanced chips
20 Nov 2026 Export Control Forum 2026 Brussels

The 2025 update showed the same pattern. It added quantum computers, chip-making machines and peptide synthesisers4. The 2026 update continues the focus on chips and computing2.

EU countries enforce the rules and set penalties through their own national laws1. In some cases, EU sanctions add further limits on dual-use exports1. The Commission will hold its Export Control Forum 2026 in Brussels on 20 November 20261.

Sources

  1. ↩ Exporting dual-use items – Trade and Economic Security https://policy.trade.ec.europa.eu/help-exporters-and-importers/exporting-dual-use-items_en
  2. ↩ 2026 Update of the EU Control List of Dual-Use Items. https://policy.trade.ec.europa.eu/news/2026-update-eu-control-list-dual-use-items-2026-09-14_en
  3. ↩ Dual-use export controls | EUR-Lex – European Union https://eur-lex.europa.eu/EN/legal-content/summary/dual-use-export-controls.html
  4. ↩ 2025 Update of the EU Control List of Dual-Use Items https://policy.trade.ec.europa.eu/news/2025-update-eu-control-list-dual-use-items-2025-09-08_en

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