Which version of the dual-use list did you classify against?

A company that classified a product against the European dual-use list between 14 November 2025 and 9 February 2026 read, in the Italian text, an entry that no longer exists. If that classification comes back onto the table — an inspection, a customer, a due diligence — the question will not be which entry you picked. It will be which version of the list, and on what date.

The entry that said something else for eighty-seven days

Annex I to Regulation (EU) 2021/821 is the common list of dual-use items: the text every exporter classifies against, in machine tools as in electronics, optics and defence. Commission Delegated Regulation (EU) 2025/2003 of 8 September 2025 replaced it in full, published on 14 November 2025 and effective the next day.

In the version as published, entry 3B501.f.1.a. — semiconductor lithography equipment — read “A light source wavelength shorter than 193 nm; or”. On 9 February 2026 a corrigendum (OJ L, 2026/90092) ruled that the text should read “Not used;”. Eighty-seven days. In today’s consolidated text that line carries the ►C3 marker and says not used. The corrigendum came out in every version we checked — Italian, English, French, German, Swedish: the error was in the act, not in one translation.

On 21 September a corrigendum enters into force that does not concern Italian

Commission Delegated Regulation (EU) 2026/1405 of 26 June 2026, published on 1 September 2026, is a regulation “correcting certain language versions of Regulation (EU) 2021/821”. It enters into force on the twentieth day following publication: 21 September. It corrects eight versions — Greek, Irish, Lithuanian, Dutch, Slovak, Slovenian, Swedish and Hungarian — on four points, and for each one the recitals repeat the formula: the error “affects the substance of that provision”.

How much substance shows when you compare the consolidated texts. At entry 2B510.b.2 — additive manufacturing equipment for metal components — the Swedish version required a vacuum “lika med eller mer än 100 Pa”, equal to or greater than 100 Pa; the corrected text says “lika med eller mindre än 100 Pa”, equal to or less than. The threshold was inverted. The same reversal in Dutch, from “gelijk aan of groter dan 100 Pa” to “gelijk aan of kleiner dan 100 Pa”, and in Slovenian, from “100 Pa ali več” to “100 Pa ali manj”. It lasted 310 days. At entry 3B501.n.4 the Swedish said “kobolt”, cobalt, where the Italian says tungsten; at 3B501.n.7.b.1 it said “järnfilter”, iron filter, against “jonfilter”, ion filter — one letter. The definition of nuclear reactor in Part I, wrong in Lithuanian, Slovak, Swedish and Hungarian, comes instead from Delegated Regulation (EU) 2022/1: in circulation since 6 January 2022, corrected 1,719 days later.

Article 1 of Regulation 2026/1405, in the Italian version, reads in its entirety: “(non riguarda la versione italiana)”, does not concern the Italian version.

The Italian consolidated text changes its number, not its words

The consolidated text 02021R0821 dated 21.09.2026 carries version 008.001 and adds act M8 to the table of amendments. Compared line by line with the one in force until 20 September (15.11.2025, version 007.002), not one word of the Italian text changes: only the header and the list of acts. In the Swedish version, over the same days, four entries change.

For anyone keeping a classification register this is the awkward case: the list reads as updated and there is nothing to re-read, while elsewhere the same code changes meaning.

Every language has its own history of corrigenda

The consolidated text lists, under “Corrected by”, the corrections applied to that version. In Italian there are three. The C2 (OJ L 92 of 30.3.2023) is Italian and nothing else: at entry 1C351.d.4. the text said “ricino”, the castor plant, and the corrigendum changes it to “ricina”, the ricin toxin of the Chemical Weapons Convention — the same correction in Annex IV, where the ►C2 marker is still visible. Between the act and the corrigendum, 448 days passed. The same document requested in English, French or German does not exist: that corrigendum is Italian only.

The other languages have different lists and even different labels. The C2 in the Swedish and Dutch consolidated texts is not the 2023 corrigendum: it is the one of 9 February 2026. Dutch additionally has a corrigendum of 5 May 2026, with sixteen corrections to Regulation 2025/2003 alone; Swedish one of 30 June 2026, with twenty-seven. The ►C2 marker does not mean the same thing in two languages.

And the list is about to change again

On 14 September 2026 the Commission adopted the delegated regulation updating the list for 2026 (act C(2026)6323). It is not yet in the Official Journal: “The updated EU control list enters into force upon publication in the Official Journal after the usual two-month scrutiny period for the Council and the European Parliament”. Among the announced additions: semiconductor manufacturing and testing equipment, advanced computing integrated circuits, ceramic matrix composites with mullite, inductive rotary encoders, additive manufacturing equipment for energetic materials. Anyone who classified in 2025 will reclassify before winter.

What has to be kept, from now on

None of this is solved by reading the list more carefully: it is solved by keeping a record of what was read. Each classification needs the consolidated version used — “02021R0821 — IT — 15.11.2025 — 007.002” is an identifier, not a detail —, the language, the date, the text of the entry as it stood that day, and the ►M◄ and ►C◄ markers active on that line. Classification is done by the exporter before its own authority, and it is done on a date: the file has to be reopenable at that date, not at today’s.

Why a closed system

This case says what an internal regulatory archive has to contain, and why it cannot sit outside. The official versions of the list number twenty-four and can diverge: you need all of them, because the customer, the subsidiary or the authority reading that code reads its own text. Each has its own history of corrigenda, with labels that do not line up: you need the dates, the acts and the line-by-line diffs, kept, not recomputed from memory. And the indexed object is not the legislation: it is the association between one of your products, a customer, a destination and an entry in the list — that is, the technical and commercial portfolio, covered by secrecy and often bound by clauses with the customer. An archive like that is not built by pasting texts and bills of materials into a service that forwards them to somebody else’s model, and it has to remain searchable in five years with today’s fidelity: the authentic copy, not a summary.

On this subject the two axes are easy to see. Complying: the twenty-four versions go into a system that watches EUR-Lex and Cellar, downloads each new consolidated text, computes the diff against the one you classified on and opens a check only on the entries that concern you, leaving the dated trail to produce — not an opinion that ends in a PDF. Deciding: the same base holds together bills of materials, customers, destinations, licences and shipments in a single operational model, on which AI agents prepare the revision of the files and close it with an operator who decides. Compliance is the way in; the decision-making system is what stays. Both delivery modes: on-premise on autonomous machines that need no deep integration into your network, or a dedicated cloud with a data centre in Italy; and shared management, because you need not already have staff administering models in-house.

If you cannot show which version of the list you classified against: write to us.

What we do not know

We do not know how many Italian classifications went through entry 3B501.f.1.a. in that window: no public data says so. We did the line-by-line comparison on Swedish, Dutch and Slovenian; for Greek, Irish, Lithuanian, Slovak and Hungarian we report what the recitals of 2026/1405 state. For the 2026 update we report what the Commission stated, not the text: the act is not yet published. And this article describes the public framework: it does not say how to classify an item.