EU Export Restrictions 2025: Dual-Use and Advanced Technology Export Restrictions

In its October 16, 2025 guidance, the European Commission clarified major expansions of EU export bans on Russia (and, by extension, Belarus). These measures build on Council Regulation (EU) No. 833/2014 (as amended) and tighten controls over dual-use and advanced technologies, even for civilian purposes. Global businesses – including those in Türkiye (Turkey) – must understand the new rules. This article explains the expanded scope of the prohibitions, the affected sectors (electronics, IT security, marine equipment, chemicals, etc.), the narrow exemptions and licensing regimes (for humanitarian aid, civil nuclear safety, maritime and space projects), and the compliance requirements (due diligence, anti-circumvention and transit bans). We also clarify how Türkiye’s EU customs-union status and the EU’s Common Foreign and Security Policy (CFSP) affect Turkish exporters and intermediaries.

Expanded Scope of Export Prohibitions

The updated guidance emphasizes that the sanctions now prohibit exports of all dual-use items listed in Annex I of the EU Dual-Use Regulation, whether for military or civilian end‑use. In other words, anything on the EU dual-use list (Reg 2021/821) cannot be shipped to Russia/Belarus, even if intended for a purely civilian application. This ban is very broad, with only limited exemptions. In addition, the EU has created a new category of “advanced technology” items (Annex VII of the sanctions Regulation) which are also fully banned. These advanced technologies include high-end electronics, computers, telecommunications and information-security equipment, as well as specialized industrial goods that could bolster Russia’s tech capacity. For example, the guidance explicitly calls out items in sectors such as electronics, IT and cyber‐security, sensors and marine (naval) equipment, special chemicals (including chemical-weapon precursors), special materials and manufacturing machines. All exports of these listed items to Russia/Belarus are now prohibited, with very few exceptions.

Restricted Sectors and Technologies

In practice, this means the sanctions cover a wide range of civilian industries. Affected sectors include, but are not limited to:

• Electronics & Computing: Semiconductors, processors, telecom equipment, servers, storage and other computer hardware.
• Information Security: Cybersecurity systems, encryption devices and related IT security gear.
• Marine and Aerospace: Navigation and communication equipment for ships (e.g. marine lasers/sensors) as well as some satellite/space components.
• High-End Chemicals and Materials: Chemical precursors and materials used in advanced manufacturing or in the production of chemical agents.
• Manufacturing Equipment: Specialized machinery for electronics production and other sensitive industries (often overlapping with the above categories).

These categories roughly mirror the examples given in the Commission’s FAQs. In short, any high-tech product or ingredient that could enhance Russia’s industrial or military capability – even if currently destined for civilian use – is blocked. Exporters should carefully check their product against the CN codes and technical specifications listed in the annexes.

Exemptions and Licensing Process

Although the bans are broad, the Regulation still provides a few limited exemptions (Articles 2(3) and 2a(3)) for genuinely non-military needs. In particular:

• Humanitarian and Emergency Aid: Exports may be allowed for strictly humanitarian purposes, health emergencies or natural disaster relief. For example, medical equipment or aid kits sent to alleviate human suffering can qualify. (Such shipments typically must be declared to customs and notified to authorities.)
• Medical and Pharmaceutical Supplies: Medicines or medical devices intended to meet urgent health needs are exempt, provided they are not on certain banned lists.

These exemptions do not require a prior EU licence, but exporters must comply with conditions (e.g. notifying customs) to use them. Crucially, items destined for Russian defense entities or covered by the military/industrial annexes are never exempted.

For other civilian uses, exports are only possible via derogation licenses (Articles 2(4) and 2a(4)). These require a formal authorisation by the relevant national authority before export. Notable authorisation categories include:

• Civilian Space Cooperation: Equipment for purely civil space programs conducted government‑to‑government (e.g. satellites, launch components for joint projects).
• Civil Nuclear Projects: Goods for the operation, maintenance, fuel handling or research of civil nuclear facilities.
• Maritime Safety: Navigation, safety or rescue equipment for civilian ships (strictly for ensuring maritime safety, not for military vessels).
• Civil Telecommunications and Cybersecurity: Non‑military, non‑public telecom network components or devices ensuring civilian cyber/information security.
• Other Civilian Uses: This also covers exports to EU or partner‑owned companies, software updates, consumer communications devices and medical/pharmaceutical items (if listed in Annex XL).

Each of the above derogations is subject to strict authorisation. Until a licence is granted, export is prohibited. Exporters wishing to take advantage of any derogation must submit an application (using the official Annex IX form) to their country’s competent authority. The form must detail the item, end-use and justification, and should be filed electronically if possible. Importantly, even when a sanctions derogation applies, EU dual‑use export licensing rules still apply in parallel (see below).

Due Diligence and Anti-Circumvention Measures

The guidance places heavy emphasis on exporter vigilance. All companies in the supply chain must ensure robust due diligence so that banned items do not reach Russia. This includes verifying the identity and ownership of all customers and end-users, and confirming that the final destination is not Russia or Belarus. Exporters should insert explicit “no re-export to Russia” clauses in contracts and have contractual remedies if goods are diverted. It is recommended to maintain records of checks and even conduct post-shipment audits if needed.

Critically, the rules forbid any attempt to evade the ban. EU law expressly prohibits participating, “knowingly and intentionally,” in actions whose object or effect is to circumvent the export restrictions. If an EU shipment to a third country is subsequently re‑exported to Russia, authorities can treat the exporter’s failure to prevent that re-export as a breach of the sanctions. In practice, this means that Turkish or other companies handling EU-origin dual-use items should be as careful as if they were directly exporting from the EU.

Among anti-circumvention safeguards, the Commission has published a list of “Common High‑Priority Items” (electronics components found on the battlefield) to help exporters focus their checks. In summary, exporters must apply a risk‑based due diligence regime – screening all parties and supply-chain steps – and assume liability for negligence in compliance.

Compliance with EU Dual-Use Rules and Transit Prohibitions

Businesses must meet both the sanctions and the EU Dual-Use Regulation (2021/821) requirements. The Commission guidance states that the new export bans apply “without prejudice” to the dual-use licensing rules. In other words, even if a shipment falls under a sanctions exemption or derogation, it may still need a licence under Regulation 2021/821. Exporters should therefore verify product coverage in both lists and apply for any required dual-use licence alongside the sanctions notification. Standard forms and procedures from the Dual-Use Regulation are used “mutatis mutandis” for items in the advanced‑technology list.

Another key change is a strict transit ban. Articles 2(1a) and 2a(1a) now forbid overland transit of any listed dual-use or advanced tech items through Russian territory. This means shipments from the EU to third countries cannot pass through Russia (or Belarus, by analogy) unless a narrow exemption applies. The only transit exemptions mirror those for direct exports: humanitarian or medical emergencies, or urgent environmental/health purposes. Likewise, transiting goods for civilian space missions, nuclear maintenance, maritime safety, non-public telecom networks, etc., require a special license. In summary, companies must avoid routing banned goods via Russia under any circumstances.

Türkiye’s Status Under the Customs Union

A common question is how these EU sanctions affect Türkiye, which is in a customs union with the EU. Crucially, the EU‑Turkey customs agreement covers trade policy, not foreign policy. The EU’s sanctions are enacted under the Common Foreign and Security Policy (CFSP), which the customs union does not automatically extend to Türkiye. In practical terms, Turkey is treated like any other third country with regard to these export bans. Turkish law is not bound by EU CFSP decisions, and the Treaty of Ankara does not require automatic adoption of EU sanctions on Russia.

Nevertheless, Turkish exporters must navigate this landscape carefully. Under the Customs Union, Türkiye does commit to align with EU commercial policy (such as tariffs and trade controls), and in the past it has often copied EU export restrictions voluntarily. But legally, any Turkey‑origin dual-use goods shipped to the EU would still trigger the EU controls (and EU companies would apply the ban on onward exports to Russia). Likewise, EU companies dealing with Turkish intermediaries will require that the end use is not sanctioned. In short, Türkiye’s customs-union status means Turkish exporters can’t rely on an EU sanctions “loophole.” They should behave as though EU rules apply: check whether products fall under the EU lists and obtain authorisations accordingly. For dual-use compliance, Turkish businesses should adopt EU-style due diligence and licensing practices as a best practice, even though Türkiye is formally outside the CFSP regime.

Conclusion

The EU’s 16 October 2025 sanctions guidance makes clear that virtually all exports of controlled technologies to Russia or Belarus are banned – civilian or military – unless a strict exemption applies. Companies worldwide must update their compliance programs accordingly. Key steps include reclassifying products under EU lists, identifying any exceptions (humanitarian, civil nuclear, space, maritime, etc.), and applying for sanctions licences using Annex IX forms. Rigorous due diligence – vetting customers, final destinations and supply routes – is now mandatory. Transit of sensitive goods through Russia is generally forbidden.

For Turkish exporters and intermediaries, these rules mean extra caution: even though Türkiye is not legally bound by the EU’s CFSP sanctions, any involvement with EU-origin dual-use goods or transit into Russia will be subject to EU enforcement. In practice, aligning with the EU’s dual-use regulation (2021/821) and sanctions guidance is the safest course. By understanding the expanded prohibitions and using the official authorisation procedures, businesses can navigate the new 2025 regime and avoid inadvertent violations.