United Kingdom: a major overhaul of the export control regime in 2025
In 2025, the United Kingdom has launched a significant overhaul of its export control framework, reflecting the growing importance of technological sovereignty, security concerns, and international coordination. These reforms aim to modernise national rules, strengthen alignment with international commitments, and incorporate recent European developments in dual-use regulation.
A central element of this reform is the alignment between Great Britain and Northern Ireland. Former national controls on sensitive emerging technologies, including PL9013, PL9014, and PL9015, have been repealed and replaced by new “500-series” entries under the UK’s assimilated Dual-Use Regulation. This change is intended to simplify compliance for companies operating across Great Britain, Northern Ireland, and the European Union.
At the same time, amendments to the Export Control Order 2008 have introduced several important clarifications. These include a new definition for suborbital craft and the removal of certain PL categories now covered by dual-use legislation. Most notably, Armenia and Azerbaijan have been reclassified from Part 2 to Part 4, reducing their export-control sensitivity. While this change does not affect sanctions regimes, it results in lighter export licensing requirements for these destinations under UK law.
The reform also introduces new dual-use control entries targeting advanced and high-risk technologies. These include advanced semiconductors, lithography and chip manufacturing equipment, specialised materials, quantum computing technologies, additive manufacturing equipment, and related software. The expansion of these controls reflects the UK’s intent to tighten oversight of strategic technology flows.
In addition, the UK regulation addressing goods that could be used for torture or inhuman treatment has been updated to include a broader range of restricted items, further reinforcing the country’s human rights–based export control objectives.
With phased implementation beginning in November and December 2025, these reforms require companies to review their classifications, exportability assessments, and internal compliance procedures. For businesses active in sensitive sectors, the UK’s updated framework underscores that export control compliance is no longer a peripheral obligation, but a core element of regulatory and strategic risk management.