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Dual use

Applicability of U.S. Export Controls on Emerging Technology

As discussed in our previous post, the report published earlier this year by the EASME regarding the dual-use potential of certain Key Enabling Technologies (KETs) highlights the importance for companies in this area to be aware of the possibility of such technologies being or becoming subject to control under the EU Dual Use Regulation.   By Megan Gajewski Barnhill & Roland…

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Dual-use application of Key Enabling Technologies

A recent study report (accessible here), originally ordered by EASME (the European Executive Agency for SMEs), addresses the dual-use potential of Key Enabling Technologies (KETs). The report deserves the particular attention of SMEs involved in KET research and development, because the dual-use potential of these technologies, if realized, is likely to bring the activities of these SMEs within the scope…

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Opposites attract: linking HS and ECN classification

On 16 January 2017, the European Commission published its latest update of the TARIC CN-DU Correlation Table which establishes links between the customs classification codes (HS/CN) and export control classification codes (ECN). By Bert Gevers, Yassine el Bojaddaini & Megan Gajewski Barnhill , 21 February 2017. As this correlation table sometimes confuses exporters when determining whether an item is controlled for…

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EU updates its list of dual-use items

The EU Commission recently updated the EU list of dual-use items, through the adoption of its annual Delegated Regulation. This update follows the decisions taken within the different framework of the international non-proliferation regimes and export control arrangements in 2015, and comes after the publication of the new draft Dual-Use Regulation, which provides for the control of specific cyber-surveillance technologies…

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EU Commission publishes its proposal for the recast of the Dual-Use Regulation

The European Commission published its long debated proposal for the recast of the Dual-Use Regulation. By Olivier Coulon, Bert Gevers & Gerard Kreijen, 29 September 2016 The proposal, which remains close to the draft that was leaked earlier in July, sets out important changes, likely to impact EU businesses.

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Recast of the EU Dual-Use Regulation Part III – Concerns About Cyber-Surveillance Technology

As reported in one of our earlier posts on the leaked proposal for recasting the EU control regime for dual-use items (Regulation 428/2009), the Commission specifically aims to subject cyber-surveillance technology to control. This is part of a broader move to introduce human rights as a factor for consideration when exporting dual-use items (see also our post on export controls…

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Recast of the EU Dual-Use Regulation Part II – an Ambitious Draft

In 2014, the EU Commission announced its intention to recast Regulation 428/2009 (“the Dual-use Regulation”), triggering a long process of internal discussion and public consultation. The project now seems to have reached a milestone with a draft proposal from the Commission. In particular, as explained in a previous post, the leaked document foresees the inclusion of a human rights factor…

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EU Commission to take a tough stance on the issue of human rights in the recast of the Dual Use Regulation

The recast of Regulation 428/2009 (“the Dual-use Regulation”), which has been an on-going project for the last two years, now appears to have come to a turning point, with a draft proposal from the EU Commission. The leaked document (link), yet to be formally communicated to the EU Parliament and Council, foresees a range of important changes that should be…

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