Rutger Brattström // 21 October 2026

The Commission is evaluating whether the EU’s Dual-Use Regulation is still fit for purpose. One of the Regulation’s aims is to reduce administrative burden on businesses. Yet the Commission publishes no data on licence processing times, sets no deadline for licensing decisions and has no current estimate of compliance costs. Its only quantified claim about exporters’ costs has never been verified.

In this briefing, Rutger Brattström of Timbro argues that this gap matters more than ever. Commercial technologies such as drones and sensors now shape modern warfare and change within months, while updating EU control lists can take years. He concludes that simplification is a matter of European security.

The main findings of the briefing include:

• Measure and publish licence processing times and compliance costs.
• Introduce statutory decision deadlines, with a right to reasons.
• Broaden EU General Export Authorisations, including for Ukraine and NATO allies.
• Create a de-listing mechanism based on a foreign availability test.
• Keep control lists at Union level rather than national level.
• Avoid US-style extraterritorial reach.