EU Dual-Use Export Controls: The Dual-Use Regulation in Practice

Introduction

The EU Dual-Use Regulation (Regulation (EU) 2021/821) governsthe export of goods, software, and technology that have both civilian andmilitary applications. The 2021 recast introduced significant new provisions,including strengthened human security and cybersurveillance controls, enhanceddue diligence obligations, and expanded internal compliance programmerequirements. This course provides a thorough, practical guide to the Dual-UseRegulation, covering classification, licensing, due diligence, and theobligations that apply across the EU's 27 member states.

Who ThisCourse Is For

This course is designed for export compliance professionals,trade lawyers, supply chain managers, and engineers at EU-based or EU-connectedcompanies that export dual-use goods, technology, or software. It isparticularly relevant to sectors including defence, aerospace, electronics,chemicals, and cybersecurity.

WhatYou'll Learn

•      The structure and scope of the EU Dual-Use Regulation(EU) 2021/821

•      How to classify items using the EU Common Military Listand Annex I control lists

•      The licensing system: individual, global, and generalexport authorisations

•      EU General Export Authorisations (EUGEAs) and theirconditions

•      Enhanced due diligence and catch-all controls for itemsnot on the list

•      Cybersurveillance technology controls: a new EUpriority

•      Internal Compliance Programme (ICP) requirements

CourseStructure

Format: Live onlinesession with Q&A, also available as on-demand recording

Duration: 2 hours

Level: Intermediate

Assessment: Noformal assessment — attendance certificate issued on completion

Technical Requirements

This course is compatible with most operating systems andmodern web browsers. Live sessions are delivered via video conferencing.On-demand recordings are accessible via the course platform. A stable internetconnection is recommended. If you experience access issues, please contact yourorganisation's IT department or the course provider.

Course Content

1. The Dual-Use Regulation:Structure and Scope

•      Legal basis and objectives of the 2021 recast

•      Definition of dual-use items: goods, software, andtechnology

•      Scope: exports, brokering, technical assistance,transit, and transfer

•      Relationship with the EU Common Military List

2. Classification and the AnnexI Control List

•      Ten categories of dual-use items

•      Reading an Annex I entry: technical parameters andcontrols

•      Classification methodology and self-assessment

•      Requesting binding tariff information andclassification rulings

3. The Licensing System

•      Individual Export Authorisations (IEAs)

•      Global Export Authorisations (GEAs)

•      EU General Export Authorisations (EUGEAs): scope andconditions

•      National General Export Authorisations and divergencesacross member states

4. Catch-All Controls and DueDiligence

•      Catch-all: controls on non-listed items with WMDend-use

•      Enhanced due diligence obligations under Article 4

•      Know-your-customer obligations and end-user statements

•      Red flags and escalation procedures

5. Cybersurveillance Technology

•      Scope of cybersurveillance controls under the 2021recast

•      Intrusion software and internet protocol networksurveillance systems

•      Human security considerations in export decisions

•      Compliance implications for technology and softwarecompanies

6. Internal ComplianceProgrammes

•      ICP requirements under Article 12(1)

•      Key elements of an effective dual-use ICP

•      Member state differences in ICP expectations

•      Monitoring, auditing, and updating your ICP

Level
Intermediate
120min
Written by
Alexander Witt
Founder of Sanctions Center

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