EU consultation
15 submissions from 15 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission received 20 submissions on this file. Shown here: the 15 from organizations. Not shown: 5 from private individuals. Their submissions are personal data; the Commission publishes them under its own legal basis, and republishing them by name here would need one we do not have. Organizations act in a public capacity, so their positions are public record. About this data →
10 submissions from industry (companies and their trade associations) against 3 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 3.3 industry submissions for every one from civil society.
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations: a body that filed twice is counted twice.
The file, right now
The consultation is open: 1 day left to submit. It closes on 15 Oct 2026.
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How it got here
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Evl.
Showing 15 of 15 submissions.
Call for evidence – feedback from the European Safety Federation Dual-use export controls – evaluation of the Dual-Use Regulation Date : 14/10/2026 The European Safety Federation (ESF) welcomes the European Commission’s evaluation of the Regulation (EU) 2021/821, which governs the export, brokering, technical assistance, transit and transfer of dual-use items.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 13 Oct 2026 · source
Call for Evidence 2026 Evaluation of the Dual-Use Regulation The geo-political complexity has increased dramatically in recent year, calling for a growing focus on security. This has had a massive effect on research being performed at universities and other research performing organisations.
· · filed 13 Oct 2026 · source
The European Export Control Association for Research Organisations (EECARO) welcomes the evaluation of Regulation (EU) N° 2021/821. This paper offers the perspective of practitioners in the research sector. The central question for this Evaluation is not whether the Regulation applies to research, but how it can be applied consistently and proportionately to the research sector.
Protect.ngo (formerly the CyberPeace Institute) is a Dutch- and Swiss-based nonprofit that exposes the human impact of cyberattacks on civil society and defends those targeted. Our Cyber Tracer platform is an evidence-led, peer-reviewed repository that has documented commercial cyber-intrusion incidents.
This evaluation statement regarding the EU regulation on Dual Use Export Control are jointly submitted by family-owned investment company Sandberg Development, and their portfolio companies GAIM Professional and ISEC Monitoring Systems including subsidiary Visatec.
The Dual User Regulation strengthens transparency in freight transport. Harmonisation between German and EU law should be pursued further. 1. Processing times of up to more than 6 months are not acceptable for a global aviation supplier. This applies to new applications and renewals of authorisations, whether they are based on EU or national law. 2.
Filed in German · English published by the European Commission
SEMI Europe welcomes the evaluation of Regulation (EU) 2021/821 and the opportunity to provide evidence on its effectiveness, efficiency, relevance, coherence and EU added value. The semiconductor value chain is globally integrated. Companies operate across multiple EU and non-EU jurisdictions, use distributed digital infrastructure and collaborate through cloud-based engineering and research environments.
· · filed 7 Oct 2026 · source
Currently diverging national requirements for transit authorisations within the EU complicate international transport, lead to delays and increase administrative costs for businesses. We therefore consider greater harmonisation of procedures between Member States to be an important area for improvement.
Filed in Czech · English published by the European Commission
· · filed 17 Sept 2026 · source
Main troubles and difficulties we face with the Export Licenses for Dual-Use is the timming. It takes about 6-8 weeks to have an answer in the best cases. Otherwise it can take longer. In business, when you need to manufacture a machine, this is too much time. We do also have problems to get answers when some doubts appear for certain business and operations.
Several European Union Member States have announced plans to construct new nuclear power plants as part of their efforts to strengthen Europe's energy security and achieve its net-zero objectives over the coming decades. This renewed commitment to nuclear energy will require large-scale capital projects supported by complex, pan-European supply chains involving hundreds of suppliers across multiple Member States.
· · filed 10 Sept 2026 · source
Cassandra Foundation recommends that the evaluation distinguish simpler administration from weaker controls. This contribution proposes evaluation methods; it does not offer exporter testimony, original survey results or estimates of compliance costs.
The evaluation of Regulation (EU) 2021/821 should consider not only the effectiveness of export-control decisions themselves, but also the end-to-end administrative, evidentiary and financing frictions created when those decisions and regulatory states must be used across exporters, competent authorities, customs, logistics operators and regulated financial institutions.
· · filed 31 Aug 2026 · source
The "principal element rule" contained in General Note 2 of Annex I is rather vague and open to different interpretations. The exporters cannot predict in advance what position the authority will take regarding the classification of a component as principal element.
The Europe India Centre for Business & Industry (EICBI) welcomes the European Commissions evaluation of Regulation (EU) 2021/821, which governs the export, brokering, technical assistance, transit and transfer of dual-use items.
· · filed 17 Aug 2026 · source
The Dual-Use Regulation is an important building block for maintaining international security and preventing undesirable proliferation. From the point of view of an export-oriented industrial company, the Regulation has in principle contributed to greater harmonisation of export control requirements within the European Union.
Filed in German · English published by the European Commission
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed”. You read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.