This article is part of the “Trade Pills” series, a column that provides brief, periodic updates on trade and sanctions-related topics.
Thanks to Arianna Daveri for collaborating on this article
On April 1, 2026, Council Regulation (EU) 2026/759 amending Regulation (EU) No. 2012/267 on restrictive measures against Iran and repealing Regulation (EU) No. 961/2010, entered into force (the “Regulation”).
The Regulation responds to the need to ensure consistency between the EU’s restrictive measures against Iran and the updated EU framework for controlling exports of dual-use goods and technologies, pursuant to Regulation (EU) 2021/821 of the European Parliament (“Dual Use Regulation”).
Key Amendments
The Regulation makes the following substantive amendments to Regulation (EU) No. 2012/267:
- Update to the dual-use goods reference framework to reflect the regime of Dual-Use Regulation. Annex I now covers goods and technologies, including software, qualifying as dual-use items as defined in the Dual Use Regulation, with the exception of certain goods and technologies specified in Part A of Annex I.
- Authorization procedure alignment. Authorization must be granted by the competent authorities of the member state in which the exporter is established, in accordance with the procedures set out in Article 14 of Dual-Use Regulation. Such authorizations are valid throughout the territory of the EU.
- Comprehensive Annexes Overhaul. The Annexes of Regulation (EU) No. 267/2012 are comprehensively replaced or amended (depending on the case) to reflect the Dual-Use Regulation and to expand the scope of controlled items across strategic sectors.
Practical implications
The updated sanctions framework represents a significant reinforcement of EU controls on strategic exports to Iran. The practical impact will vary depending on product classification, the applicable annex, and access to authorization pathways. Companies involved in providing, selling, transferring, or exporting goods and technologies covered by the updated annexes should assess whether their products fall within the categories listed therein and ensure that the required export authorizations have been obtained from the competent authorities of the member state in which the exporter is established, also in accordance with Dual Use Regulation.
