EU Dual-Use Export Control Checker

Assess whether your export needs an EU dual-use licence under Reg (EU) 2021/821 — pick a destination, declare the item and end-use, and get the licence type, multilateral overlay, sanctions exposure, and required documentation.

Overall verdict

EU general authorisation (EUGEA) applies

Licence type: EU General Authorisation EU001 (allied destinations — Annex II Section A)

Export control number (EU prefix)
5A2
Destination status
eu general allied
Articles of Reg 2021/821 triggered
Art. 3 (Annex I listed)
Multilateral regime overlay
WASSENAAR
EU sanctions exposure
No sectoral sanctions identified for the destination
Check before relying on this
  • EU001 does not cover Annex II Section I items (all Annex IV items plus listed entries such as 0C001/0C002, 1C351, 9A117). Verify your exact Annex I entry before relying on it.
Required documentation
  • End-use certificate (EUC) signed by the consignee.
  • End-user statement detailing civilian application.
  • Technical specifications matching the Annex I/ECCN classification.
  • Commercial invoice + packing list + transport documents.
  • Internal compliance programme (ICP) reference, if held.
  • EU001 use: declare EU001 in the customs declaration and notify your Member State authority of first use within 30 days (some Member States require prior registration).
Licensing authority (exporter's Member State)
Select the Member State where the exporter is established — licences are issued there (Art. 8/11), not in the destination country.
Dataset last verified 2026-06-11. Indicative only — confirm with your national licensing authority. Reg (EU) 2021/821 Art. 27 keeps the exporter responsible.

Dataset last verified: 2026-06-11

Rule set in force: Reg (EU) 2021/821 of 20 May 2021; Annex I as replaced in full by Commission Delegated Regulation (EU) 2025/2003 of 8 September 2025, in force since 15 November 2025; Russia sanctions per Reg (EU) 833/2014 as amended through the 20th package, adopted 23 April 2026.

Methodology — how this assessment is derived

The checker applies a deterministic rule chain over Regulation (EU) 2021/821: (1) embargo / restrictive-measures screen for the destination (Reg 833/2014, 765/2006, 267/2012, 2017/1509, 36/2012, 2013/255); (2) Annex I category match for the declared item; (3) Art. 4 WMD and Art. 5 cyber-surveillance catch-alls from the declared end-user / end-use and free-text specifications; (4) authorisation routing per Annex II — EU001 for allied destinations except Annex II Section I items, EU007 only for intra-group software/technology to its listed destinations (never physical goods), Annex IV intra-EU transfers, otherwise individual or global licence. The remaining general authorisations (EU002–EU006, EU008) cover specific Annex I entries, so they are flagged for manual verification rather than auto-granted; (5) multilateral overlay (Wassenaar, Australia Group, NSG, MTCR, CWC) and licensing-authority pointers for the Member State where the exporter is established.

All rules run locally in your browser against a versioned dataset — no inputs leave your device. The output is an indicative assessment, not a binding classification: Annex I is amended by Commission Delegated Regulations and sanctions lists change faster than any monthly refresh. Confirm with your national licensing authority (e.g. BAFA, SBDU, Douane) before shipping.

What this checker covers

  • All ten Annex I categories (0–9) plus cyber-surveillance items under Article 5 and emerging-technology overlays (quantum, additive manufacturing).
  • Article 4 WMD and military end-use catch-all screening from your declared end-user and end-use.
  • Authorisation routing per Annex II: EU001 (allied destinations, minus Annex II Section I items), EU007 (intra-group software/technology only — never physical goods), Annex IV intra-EU transfers, individual or global licences. Entry-specific authorisations (EU002–EU006, EU008) are flagged for manual checking.
  • Destination screening against EU restrictive measures, including the Russia / Belarus regimes and the EU arms embargo on China.
  • Brokering, transit and technical assistance flags under Title III.
  • Licensing-authority pointers for the Member State where the exporter is established (DE, FR, IT, ES, NL — the largest EU exporters; other Member States via the Commission's directory).

What it deliberately does not do

  • It does not issue a binding Annex I / ECCN classification — only your national competent authority can.
  • It does not screen named parties against the EU consolidated sanctions list — run your counterparties through the official list separately.
  • It does not cover national control lists that go beyond Reg (EU) 2021/821 (for example German AWV Part I Section B).
  • It does not confirm entry-level eligibility for EU002–EU006 and EU008 — those general authorisations cover specific Annex I entries that a category-level checker cannot verify; it flags them instead.
  • It covers 25 frequent destinations, not the full country list — a destination missing from the dropdown is simply not assessable here.
  • It does not replace an Internal Compliance Programme — EU007/EU008 and global licences presuppose one.
  • It stores nothing and sends nothing: every rule runs locally in your browser.

EU dual-use export licences — frequently asked questions

Do I need an export licence to ship dual-use items to the United States or the United Kingdom?

Usually not an individual one. For the allied destinations of Annex II Section A — Australia, Canada, Iceland, Japan, New Zealand, Norway, Switzerland/Liechtenstein, the United Kingdom and the United States — Union General Export Authorisation EU001 covers every Annex I item except those listed in Annex II Section I. You declare EU001 in the customs declaration and notify your Member State authority of first use within 30 days (some Member States require prior registration). If your item sits in a bucket containing Section I entries — for example 0C001/0C002 (nuclear), 1C351 (pathogens) or 9A117 (rocketry) — this checker routes you to an individual or global licence instead.

What changed in the EU dual-use control list for 2026?

Annex I — the EU control list — was most recently replaced in full by Commission Delegated Regulation (EU) 2025/2003 of 8 September 2025, in force since 15 November 2025. It folds in the 2024–2025 decisions of the multilateral regimes (Wassenaar Arrangement, Australia Group, NSG, MTCR), including quantum-technology and additive-manufacturing entries spread across the existing categories 0–9 rather than collected in a new category of their own. This checker's dataset was last verified against that text on 2026-06-11; if you are reading this later, check whether a newer delegated regulation has replaced Annex I again.

Can I export AES-256 encryption hardware or software without an individual licence?

Often, yes — but the route depends on the destination. Standard commercial cryptography sits in Annex I Category 5 Part 2 (declaration prefix 5A2, Wassenaar-derived). To EU001 allied destinations such as the United States, EU001 applies. To Brazil, India, Singapore, South Africa or Türkiye, EU008 covers specific encryption entries (5A002.a.2, 5A002.a.3 and related sub-entries) that use published or commercial cryptographic standards — but EU008 is entry-level, so this checker flags it for manual verification rather than auto-granting it. Inside the EU, Category 5 Part 2 is not on Annex IV, so intra-EU movements need no transfer authorisation.

Are dual-use exports to Russia or Belarus still possible?

As a rule, no. Regulation (EU) 833/2014 — amended through the 20th sanctions package adopted on 23 April 2026 — prohibits the export of dual-use goods and technology to Russia, and Regulation (EU) 765/2006 (reinforced by Reg 2024/1865) mirrors the prohibition for Belarus. This checker returns "Export prohibited" for any Annex I item, military end-user, WMD or cyber-surveillance flag toward an embargoed destination; the same logic covers Iran (Reg 267/2012), North Korea (Reg 2017/1509), Syria (Reg 36/2012) and Myanmar (Reg 2013/255). Even items outside Annex I require case-by-case verification before any shipment to these destinations.

Do intra-EU transfers of dual-use items need an authorisation?

Mostly not — Annex I items circulate freely within the single market. The exception is Annex IV (Article 11 of Reg 2021/821): the most sensitive items, which in this checker live in Category 0 (nuclear), Category 1 (special materials and pathogens) and Category 9 (aerospace and propulsion), still need a national transfer authorisation even for a shipment from, say, Spain to Germany. The checker shows this case as "Intra-EU transfer authorisation required (Annex IV)" and routes it to the national general authorisation issued by your Member State.

Which authority issues my export licence — the destination's or mine?

Always the Member State where the exporter is established, never the destination country (Articles 8 and 11 of Reg 2021/821). In Germany that is BAFA, in France the SBDU, in Italy UAMA, in Spain the SGCE and in the Netherlands the CDIU at Douane. Exporters established in the other 22 Member States should use the European Commission's directory of national competent authorities. The checker's last step links the authority for the five largest EU exporters once you select where your company is established.

What is EU007 and when can I use it for intra-group transfers?

EU007 (Annex II Section G) is the Union General Export Authorisation for intra-group exports of Annex I software and technology — it never covers physical goods. The consignee must be a wholly-owned subsidiary or sister company with the controlling parent established in the EU or an EU001 country, use is limited to commercial product development, an Internal Compliance Programme is mandatory, and you must register before first use and notify at least 30 days before the first export. Software and technology related to entries 4A005, 4D004, 4E001.c, 5A001.f and 5A001.j are carved out. Of this checker's 25 destinations, Brazil, India, Singapore and South Africa are EU007-eligible.

Is the result of this checker a binding classification?

No. The output is an indicative assessment under Reg (EU) 2021/821 — not a binding Annex I/ECCN classification and not legal advice. Article 27 keeps the exporter responsible for the accuracy of the export declaration. Annex I is amended by Commission Delegated Regulations and the sanctions lists move faster than any monthly dataset refresh, so confirm the verdict with your national licensing authority — and screen your counterparties against the EU consolidated sanctions list, which this tool deliberately does not do — before shipping.

Related ShipCost Lab tools

Export control is one step of a cross-border shipment. These sibling tools from the same lab cover the adjacent decisions: