Every year, the European Commission publishes a report that almost nobody reads — until the day a shipment is held at customs. This year’s edition, covering 2024 data under Regulation (EU) 2021/821 (the “dual-use regulation”), was published on 25 June 2026. The document is technical and dense, but it carries a clear signal: export controls are no longer a compliance formality. They are becoming a structural part of how companies plan their commercial activity.
Here is what the figures actually say, and why they matter more than they used to.
The headline figures
In 2024, the EU authorised €77.6 billion in dual-use trade — the civil-and-military technologies such as semiconductor manufacturing equipment, encryption software and nuclear material. That is up from €71 billion in 2023, and represents roughly 3% of the EU’s total exports outside the bloc.
That trade broke down into 133,470 authorisations and notifications. The majority — 89,388 operations — went through EU general authorisations, the fastest and least demanding route. Individual licences, reviewed case by case (18,549 in total), accounted for the largest share by value: €24 billion, or 31% of the total.
Only 487 licence applications were refused, worth €0.2 billion — 0.01% of all extra-EU exports. The system is built to let trade move. Refusals remain the exception, not the rule.
Where the value concentrates
Four categories dominate individual and general licences, accounting on their own for 60% of the value authorised:
- Nuclear materials, facilities and equipment: 22%
- Information security and cryptanalysis (encryption, cybersecurity): 21%
- Semiconductor manufacturing and test equipment: 9%
- Aerospace engines and gas turbines: 8%
If your business touches encryption, cybersecurity software, semiconductor manufacturing equipment or anything nuclear, you are squarely in the categories the EU watches most closely — the ones where licence volumes are highest.
Destination matters as much as the product
By value, the main destinations for individual and general authorisations are China (25%), the United States (21%), the United Kingdom (7%), South Korea (7%) and Ukraine (3%). But the report flags an important distortion: this ranking is skewed by a single general authorisation covering ten close allied countries, including the United States and the United Kingdom. Strip that bias out and look only at individual licences, and China becomes clearly the top destination at 36% of the value, followed by the United States (10%), South Korea (10%), the United Kingdom (5%) and India (4%).
Meanwhile, destinations such as Taiwan, Brazil, Singapore and Israel do not rank near the top by value, but stand out clearly by volume in global licences — a sign of frequent shipments rather than a few large one-off deals. Companies that export regularly to these markets are part of a pattern the Commission is watching closely.
Enforcement is tightening
This is the easiest point to miss in the executive summary, but it matters for any company that actually ships goods: the number of reported infringements rose from 192 in 2023 to 270 in 2024, an increase of 41%. Fines and penalties imposed by national authorities followed the same path, from 122 to 144. Compliance audits across the EU reached 1,353 in 2024 — carried out largely by customs and national enforcement agencies, with 415 full-time equivalents devoted to administering controls.
This rise comes even though staffing stayed broadly flat year on year. In practice, it means the authorities are getting better at spotting problems: audits and enforcement are scaling up without a proportional increase in headcount, thanks in large part to better data-sharing tools.
Cyber-surveillance under watch
The report devotes an entire section to cyber-surveillance items — telecommunications interception systems, intrusion software, communications-monitoring tools — reflecting the EU’s concern about their potential use for repression or human-rights abuses. In 2024:
- 320 applications were received, overwhelmingly for telecommunications interception systems (233)
- 293 authorisations were granted, and 13 were refused
- Volumes were broadly stable versus 2023, but refusals fell (from 20 to 13)
In October 2024, the Commission published specific due-diligence guidelines for exporters of these items, in practice asking companies to build a human-rights check into their internal compliance programmes if they want to keep benefiting from simplified licensing procedures.
Why this weighs on growth more than before
Three developments in this report explain why export controls are becoming a strategic issue rather than an administrative task.
The system is going digital and interconnected
The EU’s electronic licence-management system (the Dual-Use e-System) is expanding, and licence data now feeds national customs systems automatically through the CERTEX platform — live since December 2022, with Romania joining in April 2024 and Finland testing a new interconnection bridge (the eLicensing bridge). In plain terms, customs holds increasingly rely on real-time cross-checked data rather than manual verification. A classification error or gap is now far more likely to be caught immediately than months later.
The list of controlled items keeps growing
In September 2024, the EU updated Annex I — the master list of more than 1,800 controlled items — adding new nuclear equipment, chemical precursors and noise-reduction technologies. A company that thought its product was out of scope one year can find it controlled the next. The Commission’s January 2024 white paper even proposes adding items to the EU list before formal agreement from the multilateral bodies, which would let Brussels act faster and more independently than in the past.
Russia-related restrictions keep tightening
Three new sanctions packages in 2024 extended controls on the “advanced technology items” linked to Russia’s military-industrial base, and the EU now actively coordinates with 39 partner countries — through the global coalition on sanctions against Russia — to close circumvention and diversion routes, including through third countries. If your supply chain runs through Central Asia, the Gulf or re-shipment hubs in South-East Asia, this increased cooperation raises the odds that an unusual routing pattern gets flagged.
What to take away, in practice
None of this means trade is getting harder overall. Authorised trade actually grew year on year, and refusals remain rare. But the report shows a system gaining in precision, not permissiveness. General authorisations exist precisely to reward companies with a solid compliance programme; individual licences and tighter enforcement weigh disproportionately on those without one.
For companies active in the categories or destinations above, a few questions are worth asking now. Is our product classification up to date against the latest Annex I update? Are we eligible for a general export authorisation, or do we default to slower individual licences? Is our internal compliance programme documented well enough to withstand a customs audit — given that these audits are both increasing and becoming automated?
Export controls used to be an annual classification exercise. They are increasingly a live data feed, wired straight into the customs desk. Treating them that way — rather than as a once-a-year box to tick — becomes a real competitive advantage for companies looking to grow beyond the EU’s borders.
— Amandine Mozer, Borie Consulting