Regulatory Alert — EU 2026 Common Military List
EU CML 2026 published. ML7.g military vs 1A004 dual-use boundary reaffirmed. Classification review required for ICP. Sensor and detection equipment exporters most affected.
EU Common Military List Updated — Classification Boundaries Hold
The EU published its 2026 Common Military List on 13 March, adopted by Council on 23 February. This replaces the February 2024 edition and defines what requires a military export licence under Council Common Position 2008/944/CFSP. Switzerland aligns through the Wassenaar Arrangement Munitions List. (Source)
The Line That Matters: ML7.g vs 1A004
A radiation detector sold to a customs authority is dual-use under 1A004. The same detector integrated into a military CBRN defence platform could be ML7.g. Same hardware, different classification — depending on design intent and end-use.
ML7.g — Equipment specially designed or modified for military use, for detection or identification of radioactive, chemical, or biological agents. Only carve-out: personal dosimeters.
ML5.b.2 — Military fire control and surveillance detection/recognition equipment.
ML11.a — Electronic equipment specially designed for military use, including C2 and signals intelligence.
What To Do
→ Review classifications. If your ICP references the CML, note you've reviewed the 2026 edition. Wording in ML7.g, ML5, ML11 is unchanged — log as reviewed, no action required.
→ Check boundary cases. If you sell the same technology to both civilian and military customers, confirm each transaction is classified correctly. The "specially designed for military use" test hasn't changed, but each deal needs its own assessment.
→ Update references. Pending licence applications should cite C/2026/1640 as the current edition.
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