Export Control Update - October 2025

Sweden introduces National Control List for Dual-Use Items

Effective 1 November, 2025

The Swedish Government formally adopted a National Control List for Dual-Use Products and Technologies on 25 September, 2025, to cover certain dual-use items not already included in Annex I of the EU Dual-Use Regulation (an updated version to come, see below).

From 1 November, 2025, an export authorization will be required for exports from Sweden to destinations outside the EU for the products and technologies specified in this national list (constituting supplements to Categories 2, 3, and 4 of the EU Control List).

The initiative reflects Sweden’s response to rapid technological developments with growing security and geopolitical significance, particularly in areas such as:

• Manufacturing equipment for advanced semiconductors

• Integrated circuits for artificial intelligence and quantum computing

• Quantum computers and related components

• Additive manufacturing (AM/3D-printing)

The new control list has been introduced through amendments to the Ordinance (2000:1217) on the Control of Dual-Use Items and of Technical Assistance, with the National Control List appended to the ordinance.

An updated EU Dual-Use Export Control List

Expected to be effective in November, 2025

An updated EU Dual-Use Export Control List was adopted by the European Commission on 8 September 2025. It is set to take effect after the standard two-month review by the Council and the European Parliament and on the day following its publication in the Official Journal of the European Union.

This update includes the addition of various dual-use items, including:

• Quantum technology (e.g. quantum computers, electronic components designed to work at cryogenic temperatures, parametric signal amplifiers, cryogenic cooling systems, cryogenic wafer probers)

• Semiconductor manufacturing and testing equipment and materials (e.g. Atomic Layer Deposition equipment, equipment and materials for epitaxial deposition, lithography equipment, Extreme Ultra-Violet pellicles, masks and reticles, Scanning Electron Microscope equipment, etching equipment)

• Advanced computing integrated circuits and electronic assemblies like Field Programmable Logic Devices and Systems

• Coatings for high-temperature applications

• Additive manufacturing (AM/3D-printing) machines and related materials (e.g. inoculants for powders)

• Peptide synthesisers

• Modification of certain control parameters and update of certain technical definitions and descriptions.

Most of the new entries are made in Category 3 (Electronics), and quite a few new entries in Categories 4 (Computers), 2 (Materials processing) and 1 (Special materials and related equipment). Some new additions of notes and references to other entries are also made in Category 9 (Aerospace and propulsion).

If you would like to receive a copy of the new Swedish National Control List of Dual-Use Items or the Updated EU Dual-Use Control List, or if you have any questions, please contact us using the button below.

junli.shu@maqs.com