Defence & Military II (EN)
What does “dual-use” mean in export control?
In export control, dual-use means goods, software and technology that can be used for both civil and military purposes. Exporting listed dual-use items out of the European Union requires a licence under Regulation (EU) 2021/821. Catch-all rules can also make unlisted items licensable when a critical end use is known or notified.
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What the term covers
Regulation (EU) 2021/821 defines dual-use items as goods, including software and technology, which can be used for both civil and military purposes. It expressly includes items that can contribute to nuclear, chemical or biological weapons and their delivery systems.
The regulation covers export, brokering, technical assistance, transit and transfer. For engineering and manufacturing businesses one point deserves attention: technology counts as well. Drawings, 3D models, process know-how and their transmission by electronic means can all be controlled activities, not only physical shipments.
When a licence is required
- Listed items: exporting an item that appears in Annex I of the regulation out of the customs territory of the Union requires a licence.
- Catch-all: unlisted items become licensable if the authority informs the exporter of a critical end use, such as weapons of mass destruction or military end use in an embargoed country. An exporter who is aware of such an end use must inform the authority.
- Inside the EU: the especially sensitive items in Annex IV require a licence even for transfers within the Union.
- Cyber-surveillance: separate controls apply where serious human rights concerns arise.
Licences, authorities and other regimes
The regulation provides individual, global and national general licences, plus Union general export authorisations for defined items and destinations. Individual and global licences are normally valid for up to two years and usually require an end-use statement. They are issued by the competent authority of the member state where the exporter is established — in Germany the Federal Office for Economic Affairs and Export Control.
Dual-use control sits alongside other regimes. Military goods are controlled under national military lists rather than the dual-use regulation, and exporters shipping to or from the United States also encounter separate US rules. Classification is detailed work against the control lists, so treat this article as background and obtain professional export control advice for a specific case (as of July 2026).
Key points
- Dual-use means usable for civil and military purposes — software and technology included.
- Listed items in Annex I require a licence when exported from the EU.
- Catch-all rules can capture unlisted items when a critical end use is known.
- Military goods follow separate national lists, not the dual-use regulation.
Related questions
Who is responsible for classifying an item?
The exporter. It must check whether the item is listed, whether catch-all provisions apply and whether sanctions affect the transaction. Customers often state the classification of their end product, but a supplier should ask for that statement in writing rather than rely on a verbal assurance.
Does export control apply to repairs and spare parts?
It can. Technical assistance and technology transfer are covered, so sending a part out of the Union for repair or transmitting know-how to a recipient outside the Union both need checking. The value of the shipment is irrelevant to whether a licence is required.
Are ordinary machined parts dual-use items?
Usually not. Control lists generally describe items by specific performance characteristics or material properties. A standard steel or aluminium part rarely meets those criteria, but the check still has to be made — particularly for special alloys and unusually tight specifications.
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