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Dual‑use goods: what you need to know

Many common industrial and technological products are used daily in civilian applications, but they can also have military potential. This makes these goods both valuable and sensitive. That is precisely why they fall under specific European export control regulations: to safeguard international security, increase transparency, and ensure that companies within the EU operate on a level playing field.

The European Commission updates this list of dual‑use goods regularly. The most recent updates can be found in the publication 2025 Update of the EU Control List of Dual‑Use Items – European Commission. These updates help companies continue exporting correctly, safely, and efficiently.

What are dual‑use goods?

Dual‑use goods are products, technologies or software that:

can have both civilian and military applications
have commercial or specialised uses within the defence and security industry
are subject to EU export controls (Regulation (EU) 2021/821)

Examples include advanced machinery, sensors, electronics, communication technology, or certain chemical substances.

Logistical impact

Dual‑use regulations may apply to:

Exports outside the EU
Intra‑EU transfers
Transit through the EU
Brokering activities outside the EU (for example, when facilitating trade between two third countries)

Who controls what?
Strategic Goods Control Service (DCSG)
→ Implementation and assessment of dual‑use goods
General Administration of Customs & Excise (AADA)
→ Supervision of compliance during customs procedures

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Code Y901 in the customs declaration

In Box 44 of the customs declaration, code Y901 indicates that the goods are not subject to licensing requirements under the Dual‑Use Regulation.

Important: Regulation (EU) 2021/821 does not always apply, but it can still be relevant if a product appears on the dual‑use list.

How do you know whether your product qualifies as dual‑use?
The key question is:
Has your CN code been linked to an ECCN code (Export Control Classification Number) from the dual‑use list?
You can verify this by following the guidelines below.

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Correlation Table (EU Taric Library)

Here you can find, for each CN code, whether a dual‑use classification has been added.
Example: a CN code may be linked to ECCNs such as 0B001b or 2B350g.

TARWEB (FOD Finance– Belgium)

Via TARWEB ou can automatically see, based on the CN code, which dual‑use rules (e.g. DU405 or DU576) apply.
By clicking on them, you can view the corresponding ECCN description.

TARIC Consultation (Europese Commissie)

Here too, the CN code shows whether export control rules apply.

What if an ECCN code applies?
If an ECCN code is applicable, you must then verify:

Is there a prohibited end‑use?
Each ECCN code contains detailed specifications — sometimes spanning several pages.
Example: ECCN 0B001b lists 14 different applications.

Is a licence required?

No prohibited end‑use and no sanctioned party involved
→ Y901 allowed (no export licence required)

Prohibited end‑use or delivery to a sanctioned party
→ Licence required / export prohibition

What is a “prohibited end‑use”?
This can be found, based on the ECCN, in the list provided in Regulation (EU) 2021/821.

Due diligence obligation

Even if your product is not listed as dual‑use, controls may still be required.
You must always assess the following:

Product level

Is dual‑use legislation applicable?
Does it qualify as military equipment (Directive 2025/290)?
Are there any other export restrictions or sanctions?

End‑use

Does the transaction involve a risk of prohibited end‑use, for example the production of military equipment?

Final destination

Are sanctions or embargoes in place (e.g. Russia, North Korea, Iran…)?

Parties involved

Are customers or intermediaries listed on a sanctions list?

Advice: request confirmation from DCSG in due time

In case of doubt, the exporter can:

Request a release letter (confirmation of “not subject to licensing requirements”)
Obtain written confirmation that the product is not considered dual‑use → via csg@vlaanderen.be

Essential information you must include:

End‑use
End‑user / consignee
Technical datasheet of the item
ECCN description, including a justification for why it does not apply

Questions? We are happy to support you.

If you have additional questions after reading this information, or if you would like to verify together with our experts whether dual‑use regulations apply to your shipment, feel free to contact us.

We are glad to think along with you and provide proactive support.