The European Quantum Industry Consortium (QuIC) has published a position paper titled “Optimising Dual-Use Controls for European Quantum Technologies,” addressing the European Commission’s open consultation on the evaluation of the EU Dual-Use Regulation (Regulation (EU) 2021/821).
Following the November 2025 integration of quantum computers, cryogenic amplifiers, and wafer probers into Annex I of the EU dual-use control list, QuIC warns that fragmented national implementation across the 27 EU Member States is imposing severe administrative friction, delayed shipments, and lost international revenue for European startups and scale-ups.
| [ QuIC Policy Recommendations for EU Quantum Export Controls ] | ||
|---|---|---|
| Policy Pillar | Current Industry Challenge | QuIC Recommended Reform |
| • Single Market Harmonization | • Divergent national licensing speeds and duplicated classification decisions across Member States. | • Implement digital, interoperable e-licensing portals, mutual recognition of product classifications, and 30-day non-binding technical opinions from the Emerging Technology Expert Group. |
| • Allied Trade Expansion | • Key trading partners (e.g., South Korea) remain excluded from EU001 general export authorizations. | • Expand Union General Export Authorisation EU001 to South Korea, extend EU008 encryption rules to QKD/Quantum Communication, and pursue trade reciprocity via DG TRADE. |
| • Intangible Transfers & Cloud | • Unclear regulatory rules regarding cross-border cloud access, remote maintenance, and algorithm access. | • Establish a “safe harbour” for remote maintenance/updates of lawfully exported QPU hardware and issue clear Commission guidance distinguishing usage from know-how transfer. |
| • Supply Chain & SMEs | • Passive sub-assemblies face the same export scrutiny as fully integrated quantum computing systems. | • Establish capability-based parameter distinctions between complete QPUs, listed enabling units (e.g., cryostats, amplifiers), and passive component sub-assemblies. |
Coordinated by lead authors David Morcuende (QuIC) and Ulrich Mans (QuantWare)—with contributions from industry leaders including Pasqal, planqc, IQM, Qblox, Bluefors, Qilimanjaro, and Indra—the paper emphasizes that export controls must align with the upcoming EU Quantum Act to ensure European commercial competitiveness without introducing uncoordinated trade barriers.
Review the full position paper on the QuIC Portal here and download the complete policy document from QuIC Publications here.
October 17, 2026
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