Dual-use item
A good, piece of software or technology that can serve both civilian and military purposes, and whose export can therefore require a licence.
How it works
The European Commission defines dual-use items as goods, software and technology that can be used for both civilian and military applications. A semiconductor manufacturing tool, an encryption program or a magnet alloy can all fall into this category; what matters is not the product itself but the purposes it could serve.
In the EU the regime rests on Regulation (EU) 2021/821, adopted on 20 May 2021. Annex I of the regulation contains the EU's common control list, which is updated regularly through delegated regulations; the latest update came on 14 September 2026. An item not on the list can still fall under control if the end user is linked to a weapons of mass destruction programme or to human rights abuses.
Licences come in four forms: EU general export authorisations for specified destinations, national general authorisations issued by member states, global licences covering many items and buyers for a single exporter, and individual licences for a single buyer. Licences are issued not by Brussels but by each member state's own authority.
The trap lies in the national layer. Member states can impose additional controls on unlisted items on public security or human rights grounds. Processing times and outcomes for the same item can therefore differ across the EU's 27 countries, and exporters must track both Annex I and the national rules of the country concerned.
Why it matters here
Dual-use licensing has become a two-way bargaining chip. In October 2026 the EU won a green channel for rare-earth licences from China and in return agreed to prioritise dual-use licences destined for China. One side's technology controls are being traded against the other's raw-material controls. For Türkiye the issue is compliance: a Turkish company passing an EU-origin component to a third country can be subject to both the EU and the US licensing regimes.