NTE 2025/30: updates to export control regulations
Published 20 November 2025
Introduction
The Export Control Joint Unit (ECJU) has amended the following legislation:
- the Export Control Order 2008 (“the 2008 Order”)
- the assimilated Council Regulation (EC) No 428/2009 of 5 May 2009, setting up a community regime for the control of exports and the transfer, brokering and transit of dual-use items (“the assimilated Dual-Use Regulation”)
- the assimilated Regulation (EU) 2019/125 of 16 January 2019, concerning trade in certain goods which could be used for capital punishment, torture or other cruel, inhuman or degrading treatment or punishment (“the assimilated Torture Regulation”)
These amendments update the UK’s export control framework to align with international commitments, and to bring the control lists for dual-use items and for goods usable for capital punishment torture in line with changes to the corresponding EU controls. In particular, we are deleting the national controls on sensitive emerging technologies (control entries PL9013, 9014 and 9015) and replacing them with new “500 series” controls list entries in the assimilated Dual-Use Regulation. This ensures alignment between Great Britain and Northern Ireland, where EU controls apply directly, simplifying compliance requirements for businesses across the UK.
The Export Control (Amendment) (No. 2) Regulations 2025 will come into force on 16 December 2025.
The EU have published Commission Delegated Regulation (EU) 2025/2003 of 8 September 2025 amending Regulation (EU) 2021/821 of the European Parliament and of the Council as regards the list of dual-use items. The changes came into force, including in Northern Ireland, on 15 November 2025.
Amendment to Export Control Order 2008
The Export Control (Amendment) (No. 2) Regulations 2025 include the following changes:
- in Schedule 2, a definition of sub orbital craft was added, and in ML7h, the technical note was updated
- in Schedule 3, control entries PL9013, PL9014 and PL9015 were removed – these control entries have been moved to Annex 1 of the Assimilated Council Regulation (EC) number 428/2009
- in Schedule 4, Armenia and Azerbaijan have been moved from Part 2 to Part 4
Changes to assimilated Dual-Use Regulation
The Export Control (Amendment) (No. 2) Regulations 2025 include changes to Annex I of the assimilated Dual-Use Regulation.
The following new control entries have been added – these are the control entries which have been moved from Schedule 3 of the Export Control Order 2008. The previous PL control entries are shown in brackets for reference only.
| Reference | Control entry description |
|---|---|
| 2B510 | Additive manufacturing equipment (PL9015a1) |
| 2E503 | Technology for coating systems for ceramics (PL9015d2) |
| 3A501a15 | CryoCMOS ICs (PL9013a1) |
| 3A501a16 | Advanced ICs (PL9013a4) |
| 3A501b13 | Parametric signal amplifiers (PL9013a5) |
| 3A504 | Cryogenic cooling systems (PL9013a6) |
| 3B501k | Dry etching equipment (PL9013a2) |
| 3B501l | EUV masks and reticles (PL9013a7) |
| 3B503 | Scanning electron microscope (PL9013a3) |
| 3B504 | Cryogenic wafer probing equipment (PL9013a8) |
| 3C507 | Epitaxial materials (PL9013b1) |
| 3C508 | Fluorides, hydrides, or chlorides of silicon or germanium (PL9013b2) |
| 3C509 | Silicon, silicon oxides, germanium or germanium oxides (PL9013b3) |
| 3D507 | Software to extract GDSII information (PL9013c3) |
| 3E505 | Technology for development /production of ICs using GAFFETs (PL9013d2) |
| 4A506 | Quantum computers (PL9014a1) |
| 4A507 | Computers, etc. containing advanced ICs (PL9014a2) |
The following new control entries have been added.
| Reference | Control entry description |
|---|---|
| 1C513 | High-entropy alloy or refractory metal and alloy powders |
| 3A502.i. | Electronic assemblies, modules or equipment, containing user configurable Field Programmable Logic Devices (FPLDs) |
| 3B501.a.4 | Equipment designed for epitaxial growth |
| 3B501.f | Lithography equipment |
| 3B501.m. | Pellicles specially designed for EUV lithography |
| 3B501.n | Semiconductor manufacturing deposition equipment |
Changes to the assimilated Torture Regulation
The Export Control (Amendment) (No. 2) Regulations 2025 include the following changes to Annex II and Annex III to the assimilated Torture Regulation:
-
Annex II has been updated to add items including leg irons, hoods and blindfolds, weighted batons, spiked and serrated body armour, sjamboks, and enclosed-spaces chemical dispersal equipment
-
Annex III has been updated to add items including leg cuffs, kinetic impact launchers, multi-projectile ammunition, and malodorant chemical mixtures
Changes to the EU Dual-Use Regulation
The Changes to the EU Dual-Use Regulation are set out in the Summary of amendments to Regulation (EU) 2021-821 for 2025.
Contact ECJU
General queries about strategic export licensing
Export Control Joint Unit
Department for Business and Trade
Old Admiralty Building
Admiralty Place
London
SW1A 2DY
Email exportcontrol.help@businessandtrade.gov.uk
Telephone 020 7215 4594