Practice area

Dual-use goods

Classify, license and secure your dual-use goods, technologies and software.

The scope of dual-use

Dual-use goods — usable for both civilian and military purposes — are listed in Annex I of EU Regulation 2021/821. The challenge is first technical: precisely mapping a product, component or software to an entry, then drawing the licensing consequences.

The most underestimated issue is the intangible transfer: remote access, a SaaS licence, a cloud upload or a demo can constitute an export requiring authorisation, even within the same group.

How I help

ClassificationMapping against Annex I and the cryptography notes; consistency with customs classification.
LicensingIndividual, global and general licences; preparing and tracking files.
Intangible transfersMapping SaaS / cloud / cryptography flows and contractual safeguards.
Due diligenceEnd-user and end-use checks, export clauses in contracts.

FAQ

What is a dual-use good?

A good, software or technology usable for civilian and military purposes, listed in Annex I of EU Regulation 2021/821.

Are my software or cloud concerned?

Possibly: cryptography and certain technologies are controlled, and mere remote access can count as an export.

Which licence do I need?

Depending on the good, destination and end-user: general, global or individual licence.

Related areas

Export controlsITAR & EARCustoms

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