EU Regulation 2021/821, the recast dual-use regulation, establishes a common European framework for controlling the export, brokering, transit, and technical assistance related to dual-use items: goods, software, and technology that can be used for both civilian purposes and for the development or production of weapons, including weapons of mass destruction. The regulation entered into force in September 2021 and replaced the previous 2009 framework. It lists controlled items in Annex I and introduces new categories covering cyber-surveillance technology.
In the Netherlands, the regulation is implemented and enforced by the Centrale Dienst In- en Uitvoer (CDIU), part of the Dutch Customs Authority. Dutch exporters of controlled items must apply for licences from the competent authority. The regulation also introduces provisions on internal compliance programmes and requires operators to exercise due diligence. Sectors most affected include advanced electronics, semiconductors, aerospace, chemical technology, and cybersecurity.
For professionals working in Dutch defence and technology companies, awareness of dual-use classification is increasingly relevant, particularly given the interaction with US EAR and ITAR controls on technology of American origin. Companies with international supply chains or that provide technical services across borders should maintain a current export control compliance programme and ensure relevant staff are trained on applicable obligations.