On 10 May, the Council of the European Union adopted a revised version of the EU’s Dual-Use Regulation. This is the first major reform to the structure of the EU’s export control regime since 2009.

The text, which was passed by the European Parliament on 26 March, has been under negotiation for five years and was agreed in November 2020 (see our previous blog post).  Key changes include two new general export authorisations, stricter controls on cyber-surveillance and technical assistance, changes to the licensing framework, and provisions allowing for increased co-ordination between Member States. We will be issuing a client alert with a fuller analysis of the changes.

We expect the revised Regulation to be published in the Official Journal of the European Union shortly. The new rules will take effect on the 90th day following publication.


Andrew joined Baker McKenzie's London office as a trainee in 2015 and qualified in 2017. His practice concentrates on compliance with EU/UK trade regulations, as well as anti-bribery and antitrust. Andrew previously was previously seconded to Baker McKenzie's European Competition Law Practice in Brussels.


Ross Evans is a senior associate in Baker McKenzie's Competition, Trade and Foreign Investment Department in London. He is a highly regarded advisor on sanctions, export controls, and foreign investment and national security laws, with particularly deep expertise in the technology, media and telecoms sector, and in relation to cryptography and cybersecurity, data infrastructure, AI, and key advanced and emerging technologies.