The export control regulations for advanced semiconductor manufacturing equipment have recently evolved, with the Netherlands revising its rules and the European Commission issuing its first annual report on the revised EU Dual-Use Regulation. These updates serve as pivotal measures aimed at bolstering international security and protecting strategic sectors amid increasing geopolitical tensions.
On March 3, 2025, the Netherlands implemented updated export control regulations targeted at advanced semiconductor manufacturing equipment. These new laws specify the types of equipment requiring licenses for legal exports based on specific technology usage or performance thresholds. According to the Center for Strategic and International Studies (CSIS), "the update clarifies the legislative basis for the original regulations and revises the appendix to include the latest technical insights." This legislative shift indicates the country's effort to maintain its position within the global semiconductor ecosystem, which has become increasingly competitive.
Previously, regulatory frameworks struggled to adapt swiftly to rapid technological advancements, necessitating these revisions. The update is particularly significant as it aligns with broader European efforts to enforce stricter controls on dual-use items—technologies applicable for both civilian and military endeavors.
On January 30, 2025, the European Commission published the inaugural annual report on the implementation of the revised EU Dual-Use Regulation (Regulation (EU) No 2021/821), covering the period from 2022 through 2023. This report arrives at a time when export controls have heightened due to international challenges, especially concerning the conflict with Russia and the necessity to safeguard technology-critical sectors.
The report shed light on the enforcement activities of EU member states, detailing the nature of licensing decisions. It revealed trends and statistics indicative of the rising complexity of compliance requirements. For example, EU countries authorized dual-use exports amounting to €57.3 billion and denied licenses for goods valued at €0.98 billion. Strikingly, denials amounted to only 0.04% of the value of total extra-EU27 exports for the year, indicating strong majority approvals of export applications.
The report also highlighted which industries have felt the most significant impacts from the Dual-Use Regulation, including cyber-surveillance, information security, cryptocurrencies, quantum computing, and artificial intelligence (AI). Information security and crypto-analysis items represented €4.81 billion of national general export authorizations — accounting for 45% of the overall total. Notably, this category also occupied prominent positions within individual and global authorizations.
Taking heed of the global climate, the EU demonstrated enhanced cooperation on export control with various nations, particularly the United States. This collaboration followed the establishment of the Trade and Technology Council, originally formed in June 2021. By actively working together, these nations collectively identified key technologies—referred to as 'common high priority items'—that may be utilized by the Russian military amid its actions against Ukraine.
The report specified the leading destination for goods categorized under the EU Dual-Use Regulation. The United States emerged as the primary recipient by value, constituting approximately 24% of export authorizations. China followed as the second most significant destination, accounting for 19%, and the United Kingdom fell third with 7% of the same authorizations.
Overall, both the Netherlands and EU's recent updates on exports reflect a growing awareness of the need for stricter licensing and enhanced transparency. Compliance continues to be increasingly relevant amid global economic pressures and shifts dictated by international relations. The European Commission articulated this reality, stating: "EU export control is becoming increasingly relevant and sophisticated, with enhanced data collection, stricter enforcement and greater collaboration with global partners."
Through these developments, businesses involved with dual-use technologies would need to be more proactive than ever to mitigate legal risks and maintain access to global markets. The rising complexity suggests firms must stay informed of the shifting regulatory environment to navigate compliance successfully.
With export controls becoming integral to safeguarding both national and international security, the Netherlands' strengthened regulations alongside the EU's comprehensive review signal unified efforts to prioritize technological integrity and secure supply chains across borders. These measures are not merely regulatory changes; they reflect the industry's evolution and growing recognition of the significant role technology plays on the world stage.