New Chemicals Added to the 2024 EU Dual-Use List

On September 5, 2024, the European Commission presented a draft proposing the addition of three new items to the EU Dual-Use List. This update will result in controlled exports for these chemicals, reflecting ongoing efforts to balance legitimate commercial use with potential security concerns.

1. Iodine Pentafluoride (CAS 7783-66-6) – New code 1C011.e.

 Iodine pentafluoride (IF5) is an interhalogen compound composed of iodine and fluorine. This highly reactive fluorinating agent appears as a colorless to pale yellow liquid.

 Applications:

- Fluorinating agent in organic synthesis

- Specialized chemical manufacturing processes

 Hazards:

- Extremely corrosive and toxic

- Reacts violently with water, releasing dangerous hydrofluoric acid

- Strong oxidizer that can cause fires or explosions when in contact with combustible materials

- Exposure can cause severe chemical burns to skin, eyes, and respiratory tract

 Dual-Use Concern:

Its potential use in chemical warfare agents research likely contributed to its inclusion on the list.

2. Dipropylamine (CAS 142-84-7) – New code 1C350.90.

Dipropylamine (C6H15N) is an organic compound in the amine family, appearing as a colorless liquid with a strong fishy or ammonia-like odor.

 Applications:

- Intermediate in the synthesis of various chemicals

- Production of pesticides and herbicides

- Manufacturing of certain pharmaceuticals

- Some rubber processing applications

 Hazards:

- Flammable liquid and vapor

- Toxic if swallowed, inhaled, or absorbed through the skin

- Causes severe skin burns and eye damage

 Dual-Use Concern:

Its potential as a precursor for certain chemical agents likely led to its inclusion on the list.

3. Neosaxitoxin (NEO) – New insertion into code 1C351

 Neosaxitoxin (NEO) is a powerful neurotoxin belonging to the saxitoxin family, naturally produced by certain species of dinoflagellates and cyanobacteria.

Applications:

- Medical research into potential anesthetic applications

- Marine toxin testing

- Studied for its mechanism of action on sodium channels

 Hazards:

- Extremely toxic, even in small quantities

- Blocks sodium channels in nerve cells, leading to paralysis

- Can cause respiratory failure and death if ingested or absorbed

- No known antidote

 Dual-Use Concern:

While not known to be actively used in military applications, its high toxicity makes it a potential subject of chemical warfare research.

Implications of the Update

 The addition of these chemicals to the EU Dual-Use List signifies their recognition as substances with both legitimate commercial uses and potential for misuse. Companies and researchers working with these chemicals will need to comply with new export control requirements.

 This update underscores the ongoing challenge of balancing scientific and industrial needs with security concerns. It also highlights the importance of staying informed about changes in chemical regulations, especially for those in industries that may be affected.

 As always, proper safety measures and adherence to regulations are crucial when handling these substances. Companies involved in the manufacture, use, or trade of these chemicals should review their compliance procedures to ensure they meet the new requirements.

Patrick Goergen, Founder & CEO, RespectUs

The Export Control Expert & Explainer

10 September 2024