Wassenaar Arrangement Under Strain: How the U.S., EU, Japan, and the UK Are Moving Beyond Multilateral Gridlock

Hello, this is Ryuta Hamamoto from TIMEWELL. For years, the Wassenaar Arrangement (WA) sat at the center of dual-use export controls. List updates have not moved as quickly as many participants hoped. Emerging technologies evolve on a monthly cadence; securing consensus among 42 participants at an annual plenary has not kept pace. What is moving instead is a set of national and regional workarounds: the U.S. Plurilateral Framework, the EU 500 series, Japan’s overhaul of supplementary (catch-all) export controls, and related UK amendments. Below I map why WA is often called “dysfunctional,” and how the U.S., EU, Japan, and the UK are responding.

What you will learn

• The basic structure of WA and the dilemma of the consensus rule
• Why experts started talking about “dysfunction” after 2022
• The core of four national responses: U.S., EU, Japan, and the UK
• Practical steps Japanese companies should take now

Four terms to know first

Term	Meaning
Wassenaar Arrangement (WA)	Multilateral framework for conventional arms and dual-use goods/technology. Established in 1996; 42 participants. A political arrangement, not a treaty with strong enforcement against non-compliant participants.
Dual-use	Goods and technology usable for both civilian and military purposes (e.g., advanced semiconductors, machine tools, quantum computers).
Consensus	List amendments require agreement of all participants. One objection blocks adoption.
Plurilateral	Align first among willing partners without waiting for full consensus. Middle ground between multilateral (everyone) and unilateral (one country alone).

In expert communities (CSIS, Arms Control Association, and others), you may also see the operational phrase “Wassenaar Minus One”: keep WA, but advance controls among remaining participants when one participant blocks an item. That is a technical description of process, not a political slogan targeting a named country.

Basic structure of the Wassenaar Arrangement

WA was established in July 1996 in Wassenaar, the Netherlands, as the successor to Cold War-era CoCom (1949–1994). The secretariat is in Vienna. Membership has stood at 42 since India’s accession in December 2017. China is not a participant, a fact that often appears in debates about effectiveness.

There are two lists: the Munitions List (combat aircraft, tanks, missiles, and the like) and the Dual-Use List (advanced semiconductors, machine tools, cryptography, lasers, and so on). In Japan, dual-use entries are reflected in Items 5–15 of Appended Table 1 of the Export Trade Control Order and licensed under the Foreign Exchange and Foreign Trade Act. Most current debate focuses on the Dual-Use List.

Why “dysfunction” became a common description

The proximate issue is stalled list updates. Multiple experts note that substantive dual-use list updates have largely stalled since 2022. At the December 2024 plenary, updates on intrusion software and IP network surveillance systems were adopted, but quantum computing controls did not reach agreement. National measures filled the gap.

Four structural drivers stand out:

Driver	Content
Consensus rule	One objection blocks an amendment. Diverging security priorities make agreement harder.
Geopolitical tension	Since February 2022, participants have more often split on security priorities.
Technology speed	Quantum, AI, and advanced semiconductors move on a multi-month cycle; an annual plenary cannot keep up.
Non-participation of China	A major technology exporter sits outside WA, which limits how far WA alone can cover global trade.

One nuance matters for tone: “dysfunction” is analyst and media language. Official WA descriptions tend to stay closer to fact: consensus was not reached. I take the same stance. This is a regime-level structural challenge, not a moral judgment about any one participant.

That structural challenge is increasingly recognized in official documents. The European Commission’s January 2024 Export Controls White Paper (COM(2024) 25 final) cited difficulty forming consensus in multilateral regimes, including WA, as a reason for autonomous measures. Japan’s Ministry of Economy, Trade and Industry (METI), in an April 2024 interim report of the Industrial Structure Council’s Security Export Control Subcommittee, stated that non-proliferation-style export controls not aimed at specific countries had reached a major turning point.

National and regional responses

As WA agreement became harder, major economies filled the gap with their own lists and procedures.

Country/region	Measure	Timing	Key point
United States	Plurilateral Export Controls Framework (BIS interim final rule)	Published 6 Sep 2024	New license exceptions for partner countries; covers semiconductors, quantum, additive manufacturing. Clear shift to aligning controls among willing partners without waiting for WA.
EU	500 series (Delegated Regulation (EU) 2025/2003)	Adopted 8 Sep 2025; effective 15 Nov 2025	Adds quantum computers, cryogenic electronics, and related manufacturing equipment as a “500 series” in Annex I of Regulation (EU) 2021/821.
Japan	Review of supplementary (catch-all) export controls	Promulgated 9 Apr 2025; effective 9 Oct 2025	Designates machine tools, ICs, and UAV parts by HS code; end-use/end-user checks even for general destinations; independent items added to Appended Table 2.
United Kingdom	Export Control (Amendment) (No. 2) Regulations 2025	Effective 16 Dec 2025	Replaces earlier national entries (PL9013/9014/9015) with EU 500-series-aligned numbering.
Others	AUKUS; Canada’s Export Control List revisions	Ongoing	All point toward plurilateral alignment rather than waiting for full WA consensus.

A short note on Japan’s reform: list controls alone (permission for items written into Appended Table 1) were no longer enough, so Japan expanded supplementary and catch-all controls (permission when end use or end user raises concern) and also built independent national entries. For more on the EU 500 series, see our overview of EU Dual-Use Regulation 2025/2003.

Other WMD-related regimes (MTCR, the Australia Group, and the Nuclear Suppliers Group (NSG)) face similar consensus stresses to varying degrees. In Japan these are often grouped as “international export control regimes” and reflected in Appended Table 1 of the Foreign Exchange and Foreign Trade Act.

Impact on Japanese companies and five practical steps

From a corporate desk, three things are happening at once. First, the center of gravity is shifting from list controls toward catch-all controls, so that from October 2025 even ordinary dual-use goods (machine tools, ICs, drone parts) need meaningful screening for general destinations. Second, the same item may be controlled differently under the U.S. EAR, the EU 500 series, and Japan’s national lists. Third, where partners have aligned controls, such as new BIS license exceptions, procedures can actually become simpler.

Step	Action
1. Reclassify the product master against multiple lists	Re-run classification against Appended Table 1, EU Annex I (including the 500 series), and the U.S. CCL. Prioritize quantum, semiconductor manufacturing equipment, and advanced computing.
2. Check HS-coded catch-all items	Match the HS-coded items designated in the October 2025 catch-all reform against export history data.
3. Standardize end-user and end-use due diligence	Where “if the exporter itself judges concern, a license is required,” document the rationale. Put screening steps and escalation criteria into internal rules.
4. Multiply monitoring channels	Parallel-watch BIS, the European Commission Trade DG, the UK DBT, and METI’s Trade and Economic Security Bureau. CISTEC member reports and JETRO Brussels updates remain useful.
5. Share and accumulate classification knowledge	Capture past rationales, reference lists, and internal Q&A so manufacturing, sales, and legal apply the same standard, and so you are ready for authority inquiries and audits.

Annual monitoring is no longer enough. Quarterly review is more realistic, and for some product lines I would go monthly.

Common misconceptions / FAQ

Q1. Is the Wassenaar Arrangement “over”?

No. The organization still exists and holds annual plenaries. What has weakened is the speed and scope of consensus. Participants are adding national controls in parallel. As of 2026, WA is better described as a complementary reference framework than as a standalone system that fully covers emerging technology.

Q2. If WA is weaker, do Japanese companies face looser controls?

The opposite. Multilateral agreement has slowed, while the U.S., EU, Japan, and others have tightened their own rules. For companies, that means more lists, more fragmentation, and more laws to check.

Q3. Is China’s non-participation a problem?

It has long been flagged as a structural issue. China participates in the Australia Group and NSG but not in WA or MTCR. WA alone therefore does not cover every major technology exporter, which constrains effectiveness.

Q4. What risks appear when controls diverge?

Typical risks: the same product being license-free, license-required, or effectively blocked depending on jurisdiction; delayed shipments from heavier classification work; extraterritorial exposure under U.S. EAR de minimis (foreign-made items with enough U.S.-origin content); and administrative or criminal risk from missed end-user screening.

Latest developments as of July 2026

While multilateral consensus remains slow, bilateral and minilateral alignment among trusted partners has become more concrete. The 16th annual Japan–India summit on 2 July 2026 produced a joint statement on economic security cooperation across semiconductors, critical minerals (rare earths), clean energy, ICT (subsea cables), and pharmaceuticals, with investment on the order of about ¥2 trillion (joint press conference, Prime Minister’s Office of Japan, July 2026). That is a practical example of the plurilateral coordination discussed above. It is an investment and cooperation framework, not a unified export-control list. Companies still need to consult each country’s list in parallel. See also Japan–India Summit 2026 and economic security.

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Key takeaways

The operating conclusion is short: WA is still a reference, not a complete shield. Parallel national lists are the real workload.

• The Wassenaar Arrangement, established in 1996, is a 42-participant dual-use and conventional-arms regime run on consensus.
• Since 2022, agreement on emerging technologies (quantum, AI, advanced semiconductors) has been hard, and list updates have stalled. Analysts describe this as “dysfunction” or “Wassenaar Minus One.”
• Filling the gap in parallel: the U.S. Plurilateral Framework (Sep 2024), EU 500 series (Nov 2025), Japan’s supplementary export-control reform (Oct 2025), and UK alignment amendments (Dec 2025).
• Japanese companies have moved from “list controls alone are enough” to parallel consultation of multiple countries’ lists, which needs updated internal systems and knowledge management.

Related articles

• Full guide to the EU Dual-Use Regulation 2025 amendment (2025/2003)
• List controls vs catch-all controls: the basic structure Japanese companies need
• Export control guide: practical list and catch-all operations

If multi-jurisdiction lists feel unmanageable

The spread of national lists after WA gridlock means export-control teams face frequent multi-law change. Watching the U.S. EAR, EU 500 series, Japan’s catch-all reform, and UK amendments at once is hard with people alone.

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References

• Wassenaar Arrangement official site
• METI: review of supplementary export controls (effective 9 Oct 2025)
• METI: Industrial Structure Council Security Export Control Subcommittee interim report (24 Apr 2024)
• U.S. Department of Commerce BIS
• European Commission: 2025 dual-use control list update
• European Commission White Paper on Export Controls (Jan 2024)
• CISTEC
• CSIS: Rethinking the Wassenaar Minus One Strategy
• Covington & Burling: U.S. Plurilateral Export Controls Framework (Sep 2024)
• Hogan Lovells: EU updates dual-use control list