EU 2023 Update of Dual-Use Export Control List (Commission Delegated Regulation 2023/66)

Mechanism

Regulation (EU) 2021/821 empowers the European Commission to update Annex I (the controlled dual-use items list) by delegated act under Article 17, subject to a non-objection scrutiny period from the European Parliament and Council. Commission Delegated Regulation (EU) 2023/66 — adopted 21 October 2022 — is the first annual Annex I refresh under the 2021/821 recast regime, replacing the Annex wholesale with a version incorporating the 2022-cycle decisions of the Wassenaar Arrangement, MTCR, Australia Group, NSG and CWC. It was published in OJ L 9 on 11 January 2023 and took effect the following day, 12 January 2023.

This is the routine maintenance layer that keeps the EU list current with multilateral consensus each year; the 2025 sequel (Commission Delegated Regulation (EU) 2025/2003, filed separately) is the same mechanism applied to the 2024 multilateral cycle, with far larger semiconductor-equipment additions.

Downstream implications

• Sets the CN-code baseline for EU dual-use export licensing that all

subsequent annual Annex I updates (2024, 2025) amend forward from.

• Routine multilateral-regime transposition — no single-sector shock, unlike

the 2025 update's semiconductor-equipment expansion.

Open questions

• Full CN-code-level diff (7 removed / 8 added per GTA) not independently

itemised here — flag if a specific code becomes relevant to a dossier.