Study - EU trade in dual-use items with conflict-affected regions - 21-01-2026
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This study examines the extent to which the EU’s legal framework and Member States’ practices on dual-use export controls align with their respective legal obligations, particularly as they relate to conflict-affected regions. There is a lack of high-quStudy - EU trade in dual-use items with conflict-affected regions - 21-01-2026
This study examines the extent to which the EU’s legal framework and Member States’ practices on dual-use export controls align with their respective legal obligations, particularly as they relate to conflict-affected regions. There is a lack of high-quality data on EU trade in dual-use goods. While the EU’s annual report has improved in recent years, it continues to lack granularity regarding what is actually exported. Some Member States produce annual reports, including a few that offer a good level of data granularity. Customs trade data including from Eurostat COMEXT is also examined. However, the limited correlation between this data and specific dual-use goods means that it does not significantly close the gap. Despite this, the current dual-use Regulation 2021/821 does provide Member States with a sufficient basis to implement their international commitments for listed items. The situation is different for non-listed items. Many conflict-affected countries are not subject to UN or EU arms embargoes. While sanctions issues are usually considered separately from dual-use export control issues, there is an important provision in Regulation 2021/821 which allows for the control of non-listed goods to military end uses which is only available to Member States when the country is subject to an arms embargo. The study concludes that the EU should improve reporting so that trade in dual-use goods with conflict-affected regions can be monitored, should discourage the use of open and general licences for conflict-affected regions, should solidify its ability to add items to the EU list outside of the multilateral export control regimes, and should issue additional guidance on interpreting licensing criteria when assessing exports to conflict-affected regions, including how to integrate IHL considerations. Overall, the EU should shift to a more proactive approach to risks associated with dual-use trade with conflict-affected regions. Source : © European Union, 2026 - EP Read more
