Norway adds national Annex III to dual-use export-control regulation, capturing semiconductor manufacturing, quantum and additive-manufacturing technologies

Mechanism

Norway is a Wassenaar Arrangement and Australia Group participant but is not an EU member, so its dual-use export-control architecture sits on a Norwegian regulation (the Eksportkontrollforskrift) that incorporates by reference the EU Dual-Use Regulation 2021/821 Annex I (Wassenaar / international- regime controls) plus a national Annex II. The October 2024 amendment introduces a third national annex — Annex III — for emerging or disruptive technologies that Oslo judges control- worthy but that have not yet been added to the EU list.

Annex III items require a licence from the Ministry of Foreign Affairs (Utenriksdepartementet, UD) for export to any destination, including EU/EEA partners, and trigger a catch-all obligation: exporters of items not listed must apply for a licence if they know or are informed that the item is or may be intended for use in development of WMD, conventional weapons in a sanctioned theatre, or "of military end use" in a controlled destination.

Technical scope of Annex III as published:

• Semiconductor manufacturing equipment — dry-etching

apparatus, deposition equipment and related sub-systems for advanced-node logic and memory fabrication.

• Substrates and ICs — enriched silicon and germanium

substrates; high-performance integrated circuits beyond defined performance thresholds.

• Reverse-engineering software/technology — software and

technology that can extract layout data from microchips to generate circuit netlists.

• Quantum computers — systems above specified controlled-

qubit thresholds, plus quantum software and quantum technology.

• Additive manufacturing — equipment for additive

manufacturing of metal or metal-alloy components, where the geometry/precision profile maps to defence-relevant end use.

This is Norway's first dedicated national emerging-technology list — prior to the amendment, controls outside the EU Annex I were handled almost entirely through catch-all and ad-hoc licensing.

Downstream implications

• Closes a Nordic gap in the plurilateral perimeter. With

Norway, Denmark and Finland now publishing national emerging- tech lists alongside the US BIS Sep-2024 IFR, NL national rule, UK and Japan, the licensing perimeter around advanced semis, quantum and metal-AM is increasingly continuous across the Wassenaar plurilateral signatories. Re-export and tech-transfer pathways through Oslo are no longer a softer alternative to Brussels-routed shipments.

• Norwegian quantum and AM firms now under licensing. Norway

has a small but non-trivial quantum sensing / silicon-photonics ecosystem (Equinor-funded R&D, SINTEF-spinouts) and an active metal-AM cluster (Norsk Titanium, Equinor-aligned subsea AM). Annex III brings these under UD licensing for any export destination — a compliance overhead increase, particularly for university tech-transfer.

• First Norway export-control filing in the IPTM register.

This fills a structural gap flagged in wake-discovery: Norway previously had only seabed-mining + Meld.St.16 + the US-Norway CRM MoU on the books, with no export-control instruments.

Open questions

• What licence-approval rates is UD running for Annex III items

to China and other "controlled destinations"? No statistics have been published yet — the leading indicator of whether Norway runs a strict-tilt (closer to NL/JP/US) or permissive- tilt (closer to EU general-authorisation defaults) regime.

• Will Norway follow the EU 2025 dual-use update (Commission

Delegated Regulation 2025/2003) and migrate Annex III items into the harmonised EU list, retiring the national annex? Same question facing the other national lists (NL, DK, FI, ES, UK).

• Does Annex III interact with the **US-Norway critical-minerals

MoU** (Jan 2025)? The MoU does not cover dual-use tech, but there is a question of whether Norwegian quantum/AM firms with US end-customers will see overlapping US (BIS) + Norwegian (UD) licence requirements for the same transactions.