UK amends export control regulations

20 November 2025

The UK has published the Export Control (Amendment) (No. 2) Regulations 2025, which amends the UK’s export control framework under the Export Control Order 2008, and retained EU law including retained Regulation (EC) 428/2009 (the assimilated dual-use regulation), and the retained Regulation (EU) 2019//125 (the assimilated torture regulation). The regulations will come into effect on 16 December 2025.

The Export Control Order has been amended to:

• Define “sub-orbital craft” as crafts that can transport people or cargo and can operate above the stratosphere, perform a non-orbital trajectory, and safely land back on Earth.

• Add a new technical note relating to Biopolymers and certain antibodies.

• Remove the entries of sensitive emerging technologies, which have been moved to the assimilated dual-use regulation.

• Remove Armenia and Azerbaijan from the list of countries subject to a UK embargo, following the Government’s decision to lift the embargo in July 2025.

The assimilated dual-use regulation has been amended to:

• Add control entries on sensitive emerging technologies which were removed from the Export Control Order. These are now referred to as “500 series” items, although old “PL” numbers are still included for reference.

• Add new control entities for sensitive emerging technologies including semiconductor manufacturing equipment.

These changes are designed to reflect the UK’s multilateral commitments including under the Wassenaar Arrangement, and to align with the recent amendments to the EU’s dual-use regulation, which came into effect last week.

The assimilated torture regulation has been amended to:

• Add items including leg irons, hoods and blindfolds and chemical dispersal equipment to the list of items in Annex II subject to a total export and import prohibition.

• Add items including leg cuffs and multi-projectile ammunition to the list of items in Annex III that require export authorisation.

The UK Export Control Joint Unit has published a notice to exporters outlining the amendments. See our UK export control pages for more information.