India: update of the SCOMET list and strengthened control of dual-use items
On September 23, 2025, Indian authorities published a significant revision of the SCOMET (Special Chemicals, Organisms, Materials, Equipment and Technologies) list, marking a further strengthening of India’s export control framework for dual-use items. The revision was issued by the Directorate General of Foreign Trade (DGFT) and introduces a new Category 7, dedicated to emerging technologies and related items.
This new category expands export controls to a range of strategically sensitive technologies. Items now subject to licensing requirements include quantum computing technologies, advanced semiconductors, additive manufacturing equipment used in metallurgy, and a variety of specialized materials. These materials notably include isotopically pure silicon and germanium, as well as ultra-pure fluorides, hydrides and chlorides used in semiconductor manufacturing, along with cryogenic systems.
This regulatory development reflects India’s broader effort to align its export control regime with global strategic and security concerns surrounding critical technologies. It demonstrates the growing importance attached to controlling the dissemination of advanced technological capabilities that may have both civilian and military applications.
For exporting companies, the revised SCOMET list requires adjustments to existing compliance frameworks. Classification processes, destination risk assessments, end-use analysis and due diligence procedures will need to be updated to reflect the new controls. The revised list will enter into force on October 23, 2025, i.e. thirty days after its official publication, giving companies a limited timeframe to ensure compliance.
More broadly, this update highlights a global trend: critical and emerging technologies are increasingly becoming a central focus of export control policies worldwide. Companies engaged in international trade must therefore enhance regulatory monitoring and anticipate the progressive expansion of export control obligations to new technological fields.