EU Dual Use List: Updated December 2014
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The European Commission has updated the EU control list of dual-use items, effective December 31, 2014, incorporating approximately 400 changes from 2011 to 2013. This includes new controls, deletions, and amendments across multiple categories such as nuclear, special materials, electronics, and telecommunications. Exporters must comply with these changes, which may require obtaining licenses for new items and freeing previously controlled items from licensing requirements.
EU Dual Use List: Updated December 2014
- 1. EU Dual-Use Control List Updated: 31 December 2014 1
- 2. At last The European Commission has updated the EU control list of Dual-Use Items (Annex I to Council Regulation 428/2009) last amended June 2012 Now incorporates some 400 changes made by the multilateral export control regimes in 2011, 2012 & 2013 Includes: new controls deletions changes to technical parameters other amendments 2
- 3. What does this mean? legal effect across the EU on 31 December 2014 If your exports – equipment, materials, software, technology – have been added to the lists, they are now subject to export controls and require a licence to be exported outside the EU (or an ‘Article 22(10)’ note if within the EU) If your exports have been deleted from the lists, they no longer require a licence (subject to their not being caught by sanctions or end-use controls) The inclusion or exclusion of your exports may be affected by changes to some technical parameters or Notes 3
- 4. Headlines Cat 0: changes from the Nuclear Suppliers’ Group Fundamental Review Cats 1, 2, 3, 6, 7 and 9: wide range of additions, deletions and amendments Cat 4: New controls relating to intrusion software. Aimed at controlling items that generate, operate, deliver or communicate with intrusion software and not intrusion software itself. Cat 5 Part 1: New controls for equipment for mobile communications interception, CIED communications and for Internet Protocol network communications surveillance Cat 5 Part 2: updates and clarification of the Cryptography Note 4
- 5. Category 0: Nuclear As a result of the NSG Fundamental Review, 54 amendments covering: Nuclear Reactors Fuel Fabrication Industrial Equipment Miscellaneous Reprocessing Weaponisation 5
- 6. Category 1: Special Materials & Equipment 1A004 Clarification for Face Masks, Filters and Powered Air Purifying Respirators (PAPR) Masks and Filters 1A005 Body armour revised. Any soft armour and hard plates below NIJ III. Armour that doesn’t provide ballistic protection decontrolled 1B001 Clarification to distinguish between Tape Laying and Tow Placement machines 1B201 Amendment to Filament Winding Machine control text 1B227 Removal of Ammonia Synthesis Converters 6
- 7. Category 1 (cont…) 1B228 Amendment to controls on Hydrogen-Cryogenic Distillation with new Technical Note 1B233 Amendment to controls on Lithium Isotope Separation Systems including two new entries on Ion Exchange Systems and Chemical Exchange 1B234 Introduction on controls High Explosive Containment Vessels, not controlled under the UK Military List. 1C001b Decontrol for RF absorbing materials. 1C001c Decontrol for polymeric materials in liquid form. 7
- 8. Category 1 (cont…) 1C008 Decontrols for some polymeric substances by raising glass transition temperature thresholds. 1C111a2b New control on metal powders of either boron or boron alloys with a boron content of 85% or more by weight. 1C116 Amendment to control on Maraging Steels, including two new Technical Notes. 1C216 Lowering of the control parameter for Maraging Steels. 1C229 Amendment to controls on Bismuth 1C241 New control on Rhenium, including sub-paragraphs detailing control. 8
- 9. Category 1 (cont…) 1C351 Control entries combined for Human and Animal Pathogens and the list alphabetically re-ordered, with the addition of the following: Herpes Hog Cholera Rabies (clarified) Clostridium Baratii, Botulinium Neurotoxin-producing strains Coxiella Francisella E.Coli 9
- 10. Category 1 (cont…) 1C354 Addition of following plant pathogens: Peronsclerospora philippinensis (Peronsclerospora sacchan) Sclerophthora ravssiae var. zeae Synchutrium endobioticium Tilletia indica Thecaphora solani 10
- 11. Category 2: Materials Processing 2A225 Amended wording to control on Crucibles. 2B001 Decontrol for dental prostheses machines. 2B001b 5 axis or more milling machines reviewed and split into 4 sub-items. Axis less than 1m Axis 1m to 2m Axis greater than 2m All parallel mechanism machines Results in lower accuracy machines being decontrolled 2B001f Components for deep-hole drilling machines deleted. 2B006b1 Clarification for LVDTs 2B009 Spin forming machines with two axis decontrolled. 2B206 Amendment to control on CMM, with new Technical Note. 11
- 12. Category 2 (cont…) 2B230 Control on pressure transducers amended, including a local definition; sub-paragraphs amended; and New Technical Note 2B232 Amendment to control on High-velocity Gun System with new Nota Bene 2B233 New control for bellow-sealed compressors and vacuum pumps, including 3 sub- paragraphs and a Nota Bene. 12
- 13. Category 2 (cont…) 2B350g Valves containing controlled Casings or Liners, but not having all surfaces with listed materials, only controlled if – Nominal size between 25.5mm (1”) and 101.6mm (4”) Closure element designed to be interchangeable 2B352b Addition of components for Fermenters. 2B352h New control for Spray Drying Equipment. 13
- 14. Category 2 (cont…) 2D003 New control for optics measurement and machine coding software for operating optical polishing machines. 2D202 New note for Machine Tool Software, decontrolling some types of software. 14
- 15. Category 3: Electronics General Purpose Integrated Circuits 3A001a5 & 7 ADC convertors & FPGAs parameters updated resulting in a small number being decontrolled. 3A001a13 New control for Direct Digital Synthesiser. Microwave or Millimetre Wave components 3A001b2, 3, 4 & 11 MMICs, Discrete Microwave Transistors, Solid State Amplifiers, Frequency Synthesisers and Frequency Synthesiser assembly controls clarified and more focussed, resulting in some being decontrolled High Energy Devices 3A001e2 Secondary Cells updated with a small number decontrolled 15
- 16. Category 3 (cont…) 3A002a Magnetic Tape Recorders deleted 3A002a7 New control for oscilloscopes 3A002c4, 3A002d & 3A002e Signal Analysers, Signal Generators and Network Analysers updated and more focussed with a number being decontrolled 3A225 Control chapeau for frequency changers amended; control parameters in sub-paragraphs amended, (including the removal of harmonic distortion parameter); new Nota Bene for software & technology; new decontrol Note for certain constrained equipment; and new Technical Note 2. 16
- 17. Category 3 (cont…) 3A229 Return of control on Detonator Firing Sets and the addition of control on Micro Firing Sets. 3A230 Addition of Pulse Heads to control. 3A231 Amendment to control on Neutron Pulse Generators, with two new sub-paragraphs. 3A233 Amendment to controls on Electron Bombardment Mass Spectrometers, with two new sub- paragraphs; 3A234 New control on Straplines, with a voltage rating greater than 2kV and an Induction of less than 20nH. 17
- 18. Category 3 (cont…) Production equipment 3B001h - IC Wafer production masks updated with a small number decontrolled. Materials 3C001 & 2 IC Wafer and Resist materials updated with a small number decontrolled. Software 3D225 New control on software capable of releasing constraints of Frequency Changers. Technology 3E002 Decontrol for a small number of ICs development and production technology. 3E225 New control on technology capable of releasing constraints of Frequency Changers. 18
- 19. Category 4: Computers 4A003a Fault tolerant computers deleted. 4A003b, 4D001b & 4E001b Adjusted Peak Performance raised for hardware, software and technology related controls. 4A005, 4D004 & 4E001a New controls relating to intrusion software. Aimed at controlling the items that generate, operate, deliver or communicate with intrusion software and not intrusion software itself. 19
- 20. Category 5 Part 1: Telecommunications 5A001b3 Decontrol for civil communications earth stations. 5A001f New controls for mobile communications interception equipment. 5A001h New controls for CIED communications equipment. 5A001j New controls for Internet Protocol network communications surveillance equipment. 5B001b5 Equipment for common signal channelling deleted. 5E001d Controls for Technology relating to telecoms MMICs updated and more focussed. 20
- 21. Category 5 Part 2: Information Security • Cryptography Note updated to include hardware and software components • New Note to provide clarification to the Cryptography Note • New Note (i) decontrolling Personal Area Network equipment. • New Note (k) decontrolling business local access equipment not decontrolled by the Cryptography Note 21
- 22. Category 6: Sensors and Lasers 6A001a1a2b New control for shallow survey equipment. 6A001b Arrays added for object location/detection equipment. 6A001e Arrays added for swimmer and delivery vehicle detection equipment. 6A001a2a New piezoelectric materials included for hydrophone sensor elements. 6A001a2b New control for arrays having accelerometer based sensors. 22
- 23. Category 6 (cont…) 6A001a2e New control for bottom or bay cable arrays having Accelerometer Based Sensors. 6A001a2g New control for Accelerometer Based Hydro-acoustic Sensors. 6A005a6 Decontrols for ‘industrial’ lasers using new parameters Beam Parameter Product and Brightness. 6A005b4, 6 New controls for Femtosecond Lasers. 6A008k, l Clarification for marine radars with a limited decontrol. 6A107 Amendment on the controls on Gravity Meters 6A203 Rewrite of control text with new Nota Benes, Note and Technical Note 6A205 New control on Carbon Monoxide Lasers, includes four new sub-paragraphs. 23
- 24. Category 6 (cont…) 6A225 Amendment to Note on Velocity Interferometers. 6A226 Control on Shock Pressure (Manganin) Gauges amended. 6C004 New optical materials. 6D203 New control on Camera Software to enhance or release the performance of cameras or imaging devices to meet the characteristics of 6A203.a. to 6A203.c 6E203 New control on Camera Technology to enhance or release the performance of cameras or imaging devices to meet the characteristics of 6A203.a. to 6A203.c 24
- 25. Category 7: Navigation & Avionics 7A001a2 Decontrol for accelerometers exceeding 15g. 7A003 Major revision for Inertial Measurement Equipment/Systems. The aim is to clarify the controls and base them on equipment/systems available that have multiple outputs, addressing their greater flexibility. 7A004 Gyro-astro compasses replaced by star trackers and updated. 7D003 Source code deleted for a variety of avionic related items. 25
- 26. Category 7 cont 7D004 New control for source code incorporating development technology for avionics previously listed in 7D003 7D005 New software control for decrypting GNSS data. 26
- 27. Category 8: Marine 8A002 Fibre optic connectors for marine applications deleted 27
- 28. Category 9: Aerospace 9A001 Gas Turbines incorporated in to APUs now treated in the same manner as propulsion gas turbines. 9A012 Clarification with the addition of Unmanned Airships. 9A101 New local definition added to control on Turbojet and Turbofan Engines, including reference to using ICAO standard atmosphere. 9A102 Amended to make reference to ICAO standard atmosphere. 9A105 Amendment to control on Liquid Propellant Rocket Engines. 9A106 Amendment to control on Propellant Control Systems 28
- 29. Category 9 (cont…) 9A117 New Nota Bene referencing new entry 9A121. 9A121 New control for Missile/Rocket Connectors, with Technical Note. 9B105 Control on Wind Tunnels expanded to include Shock Tunnels, amendment to Technical Notes and new Note. 9B106 Amendment to control on Test Chambers incorporating vibration test equipment (Shaker Units). 9E003a2 Technology for combustors clarified with a small level of decontrol. 29
- 30. Category 9 (cont…) 9E003a5 Technology for turbine blades, small level of decontrol. 9E003c Technology for manufacturing cooling holes clarified. 9E101 amended to make reference 9A120 and 9A121. 9E102 amended to make reference 9A120 and 9A121. 30
- 31. Where to find the details Comprehensive Change Note Summary for Regulation 428/2009 trade.ec.europa.eu/doclib/docs/2014/october/tradoc_152854.pdf Draft Annex ec.europa.eu/transparency/regdoc/rep/3/2014/EN/3-2014-7567-EN- F1-1-ANNEX-1.Pdf 31
- 32. Richard Tauwhare Green Light Exports Consulting Email: richard@greenlightexports.co.uk Web: www.greenlightexports.co.uk Phone: +44(0)770 311 0880 32