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SI 2025/1197 operates in two functional layers:
Layer 1 — New ECCN-aligned dual-use entries. The regulations add three new control categories to Schedule 1 of the UK's assimilated Dual-Use Regulation:
systems including cryogenic control electronics, qubit arrays, and dilution refrigerators designed specifically for quantum computing. Licence required for exports to non-UK / non-approved destinations; aligns with US EAR 4A506 (added October 2023) and Wassenaar 2024 Plenary additions.
equipment and advanced lithography tools; 3A504 adds cryogenic semiconductor testing and characterisation equipment used in quantum device production — closing a gap where items moved from 3B (manufacturing equipment) to finished-device testing were escaping licence requirements.
tools operating below 77K, primarily relevant to superconducting qubit fabrication.
Layer 2 — Nationalisation of PL9013/PL9014/PL9015. Three existing national controls in Schedule 4 of the Export Control Order 2008 (covering quantum key distribution hardware, photonic quantum computing components, and ion-trap qubit systems respectively) are lifted from the national-control schedule and re-enacted as entries in the assimilated Dual-Use Regulation. This consolidation removes the bifurcated legal basis that applied different licence conditions depending on whether an item was caught by national vs. dual-use controls, simplifying compliance for exporters of hybrid quantum/classical systems.
"Wassenaar Minus One" calibration. The UK explicitly adopts 2024 Wassenaar Arrangement updates without waiting for the next Plenary cycle to confirm multilateral text. This reflects a post-Brexit posture of implementing strategic technology controls in step with the US and EU rather than awaiting full Wassenaar consensus — mirroring the Netherlands' approach on ASML photolithography tools in 2023 and the EU's 2024 Regulation (EU) 2024/1452 semiconductor equipment additions.
refrigerators (Oxford Instruments, Bluefors UK operations), photonic quantum systems (PsiQuantum UK supply chain, Xanadu UK), and ion-trap systems (Quantinuum, Oxford Ionics) now require UK export licences for shipments to non-allied destinations. China is the primary destination of concern; the UK Government has indicated that licences for China-destined quantum computing hardware are unlikely to be approved.
suppliers of cryogenic deposition systems (Edwards Vacuum, BOC Industrial Gases) that serve quantum device fabs. Even ancillary equipment (dilution refrigerator cold-finger assemblies, superconducting magnet coils) may require licensing if integrated into controlled quantum computing systems.
since Brexit, when UK export controls diverged from EU Regulation 2021/821 (as updated) and US EAR additions. UK, US, and EU controls on quantum and advanced semiconductor items now cover substantially the same technology perimeter — reducing the ability of entities to route quantum hardware through the UK to avoid US or EU licence requirements.
and advanced semiconductor controls are a priority enforcement area for 2026. Voluntary self-disclosures of prior unlicensed shipments are strongly encouraged before the ECJU commences compliance reviews.
automatic exemption for Five Eyes / NATO partners; whether a fast-track licence pathway analogous to the US EAR License Exception STA applies remains to be clarified by ECJU guidance.
Licences (OIELs) or Open General Export Licences (OGELs) referencing the national control entries must assess whether existing licences cover the new assimilated Dual-Use entries; ECJU has indicated a 90-day transition window but details have not been formally confirmed.
but does not yet extend to quantum algorithm software or quantum-error-correction technology transfers via cloud. ECJU has indicated a further consultation on technology/software controls is planned for 2026.