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FAQ: EU Guidelines on the Export of Cyber-Surveillance Items

In October 2024, the EU published Guidelines on Export Cyber-Surveillance Items under Article 5 of Regulation (EU) 2021/82. Here are the essential FAQs that you asked us.


Questions we answer:

  • What is the purpose of the Union Export Control Framework established by Regulation (EU) 2021/821?

  • Why were these new controls introduced?

  • What are the new requirements for exporters under Regulation (EU) 2021/821?

  • What are the key legal provisions under Regulation (EU) 2021/821?

  • What key definitions should exporters understand?

  • What constitutes internal repression and human rights violations?

  • What technical aspects should exporters be aware of regarding cyber-surveillance items?

  • What due diligence measures must exporters take?

  • What are some red flags exporters should watch for?

  • What should exporters do if risks are identified?

  • Where can exporters find a summary of controlled cyber-surveillance items?


You can also download the document below.

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