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Order ECM/536/2026 updates the annexes of the Regulation on the control of foreign trade in defence material, following the transposition of Directive (EU) 2026/325. Exporting companies must review and update their lists of affected products according to the new criteria defined in the amended annexes (Art. 2). This change reflects a regulatory update to ensure the control of dual-use and defence products in foreign trade.
Companies exporting defence material or dual-use products are required to update their product lists in accordance with the new annexes. Competent authorities may apply controls more strictly. Foreign trade advisors should review product lists and verify if any new products are subject to control. Export operators must manage the 30-day deadline to adapt their records.
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