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EU Regulation 2021/821 governs the EU dual-use export-control regime through its Annex I (the EU control list). Article 9 of that regulation lets a Member State unilaterally subject additional items to national export-licensing when public-policy or public-security considerations require it — a national "add-on" list that sits on top of the EU baseline. The Arrêté du 2 février 2024 was France's first substantive use of that Article 9 option.
The original 2024 arrêté required prior authorisation for exports to non-EU third countries of two technology baskets:
1. Quantum computing — quantum computers, qubit devices (superconducting, trapped-ion, photonic, neutral-atom), control electronics, cryogenic measurement systems, and associated software/technology. 2. Advanced electronic components manufacturing equipment — specialised dry-etching systems and other tools for design, development, production, test and inspection of advanced semiconductors.
The 27 March 2025 amendment (Arrêté du 27 mars 2025) replaced the entire annex with explicit technical thresholds, aligning France's national list with the more granular metric-based controls then being adopted across the allied perimeter (US BIS quantum/biotech rule of September 2024, Norway's Annex III emerging-technologies order of October 2024).
The 10 March 2026 abrogation (entry into force 11 May 2026, i.e. today) repeals the French national list entirely. The legal grounding given is an EU delegated regulation updating dual-use controls — i.e. the items previously controlled at the French national level have now been folded into the EU Annex I baseline (EU Delegated Regulation 2025/2003), so the Article 9 national-list overlay is no longer needed.
national overlay → 2025 metric tightening → 2026 absorption into EU Annex I) is a clean example of how EU Reg 2021/821 Article 9 national lists tend to function as forward operating bases for items that subsequently migrate to Annex I. The repeal does not signal liberalisation — it signals that the EU-wide perimeter has caught up.
of US BIS quantum/biotech/additive-manufacturing controls (September 2024), Norway's Annex III (October 2024), and South Korea MOTIE's emerging-technology amendments. With France's national overlay sunset on 11 May 2026 and EU Delegated Regulation 2025/2003 now in force, the EU side of the allied quantum/advanced-electronics perimeter is harmonised at the EU baseline rather than fragmented across Member State annexes.
filings on US BIS, Norway, South Korea, the EU dual-use update, and the UK ECJU controls, this gives the IPTM register a complete picture of the 2024-2026 build-out of the multilateral quantum-computing export-control perimeter and its consolidation into EU Annex I.
national overlay? French DGRIS data is published annually but with a lag.
French annex's qubit-error thresholds, or did some sub-thresholds drop out in the EU harmonisation process?
technologies (post-quantum cryptography, neuromorphic computing) before EU-level catch-up?