EU Publishes First Detailed Dual-Use Export Licensing Data
The European Commission last week published a first-of-its-kind report on dual-use export control licensing patterns that it says will give companies, governments and the public a “better understanding of how export controls are applied” within the bloc.
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The report is the first under a new approach by the EU to publish more detailed licensing data (see 2401250045). Previous annual reports included limited information on the number of dual-use export applications approved and blocked by member states (see 2310200038), and the EU said the new effort marks an “important milestone” to increase “transparency” about EU export control decisions.
The report includes a “complete overview” of 2022 licensing data and “key highlights” from 2023 and 2024, along with a 199-page document with detailed export licensing data sets from 2022. The EU expects to issue additional 2023 data later on in the “first quarter of 2025.”
Data covered by the report was submitted and compiled during a “great shift in the geopolitical landscape,” the report said, including Russia’s war against Ukraine and conflict in the Middle East. Those events have “only served to highlight the importance of effective controls on the export of dual-use items and such controls have been an increasingly important part of the Commission’s response to geopolitical developments, notably through sanctions.”
It also noted that the past several years have seen a rise in unilateral export controls outside the scope of traditional regimes. It specifically pointed to new restrictions over semiconductors and semiconductor manufacturing equipment as well as critical raw materials used to make “sensitive enabling technologies.” The Netherlands (see 2501150057), the U.S. (see 2501130026 and 2412020016) and Japan (see 2303310031) each have tightened their chip controls, while China has announced a series of restrictions over raw materials (see 2412030022).
The EU said its member states authorized about $60 billion worth of dual-use exports in 2022, or 138,764 general authorizations and individual licenses. They also issued 813 denials for exports that were worth close to $1 billion. The EU said both the number of authorizations and denials were higher than in previous years.
The exports that received the most number of approval authorizations or licenses by volume included nuclear-related items, materials processing exports and telecommunications exports. China was the largest destination by value for approved licenses, followed by South Korea and the U.S.
The report also includes a small section on enforcement. The EU said 110 export “infringements” were reported during 2022 -- leading to 30 fines -- while EU authorities carried out 1,062 compliance audits. Member states also reported a total of 392 full-time staff “directly involved in the administration of controls.”
Although the EU said it may be too early to draw comparisons between the numbers in this report and previous annual reports that weren’t as comprehensive, “it can be noted in broad terms that there was an upward trend for both authorised dual-use trade and denials” in 2022, it said.