Transferring dual-use items within the EU also require registration

Under the EU Dual-Use Regulation, the export of dual-use items between EU member states generally does not require an export license. This intra-EU transfer is typically free from licensing requirements to facilitate the smooth functioning of the internal market. That does not mean you don’t have to do anything. Recording the transaction is a legal requirement. Are you looking for extensive information and services regarding export compliance regulations? Export Control Group can help you.

What is the EU Dual-Use Regulation?

The EU Dual-Use Regulation is a set of rules within the European Union that controls the export of certain items, technologies, and software that can be used for both civilian and military purposes. These rules are in place to prevent such items from reaching wrong hands or being used in harmful ways, ensuring international security and peace. The regulation requires exporters obtain export licenses when exporting dual-use items outside of the European Union. Within the European Union, it is typically free from licensing requirements, except for certain highly critical dual-use items (annex IV). However, you still have a number of minimal legal requirements.

Requirement 1: Dual-use statement, inform your client

Article 11, sub 9 of the EU dual-use regulation 2021/821 requires the so-called “dual-use statement. For internal transfers within the European Union of dual-use items that are listed in Annex I, it’s important that all related business papers clearly show these items are under export control if they leave the EU. This means documents like sales contracts, order confirmations, invoices, or delivery notes should all specifically mention this control status.

Requirement 2: Record your intra-EU dual-use transaction

Chapter 8 of the EU dual-use regultaion 2021/821 describes the controls measure. The first articles states that records and documents related to the internal EU transfers of Annex I dual-use items, must be maintained for a minimum of three years following the end of the year when the transfer occurred. Upon request, these records should be presented to the relevant authority of the EU Member State from which the items were originally transferred. Hence, your dual-use registration should not only cover dual-use exports outside of the EU, but also within.

Our solution pillars

We offer a unique Export Control & Compliance program, called the “A4 approach”. The A4 aproach, combines solid compliance structure with Lean Six Sigma / Lean Thinking techniques. Why? Because it is simple, easy to understand and a perfect base to find the compliance starting point withing your organization


Most companies are not aware of sanctions & export control regulations. We create awareness by straight forward, to-the-point training.


What is the maturity of your sanction & export control compliance? We have developed a lean compliance assesment tool called SCAN365.


Now you’re aware of the gaps in your compliance process, fixing them is the next challenge. Translating the gaps in your processes into solid solutions.


Outside assistance and coaching will keep you sharp. Because you can’t know everything in the volatile domains of sanctions & export controls.

Avoid the risk of receiving penalties and fines

EU export control regulations are just the beginning of international export rules and regulations. It is important to make sure you comply with the right regulations, know if you are exporting controlled items and avoid the risk of receiving penalties and fines.

Work together with Export Control Group

Export Control Group offers a unique control and compliance programme to help you with export compliance regulations. We call this the A4 approach: Aware, Assess, Adapt, and Assist. We do not only provide you with the right guidelines, we make them work. For example, with our unique Export Control Officer as a Service™. 

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