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GermanyRechtsprechung des Bundes

Germany replaces arms export list, lifts Zimbabwe arms ban

The 23rd AWV amendment in force 17 October replaces the Ausfuhrliste, drops Zimbabwe from the §74 arms embargo list, extends §76a exemptions to EU sanctions bans and adds Russia, Belarus, Iran and DPRK offences to §82.

By Taxxa AI OyPublished 16 October 2026

Financial Sector & Markets Legal & Corporate

Industry: Across industries

On 17 October 2026 Germany's foreign-trade controls change on four frontsBund. The Dreiundzwanzigste Verordnung zur Änderung der AußenwirtschaftsverordnungBund, dated 14 October 2026 (Berlin), promulgated in Bundesgesetzblatt Jahrgang 2026 Teil I Nr. 300 (distributed at Bonn on 16 October 2026), enters into force on the day after promulgationBund. It replaces the national export list (Anlage 1, Ausfuhrliste)Bund, removes Zimbabwe from the arms export bans of § 74 AWVBund, rewrites the individual-case exemptions of § 76a AWV, and extends the administrative-offence provisions of § 82 AWV that back EU sanctions with German finesBund.

Deleting § 74 Absatz 1 Nummer 13Bund ends the German ban on selling, exporting or transiting Part I Section A arms-list goods to ZimbabweBund, which had stood on that list alongside Myanmar, Iran, Syria and others. The brokering ban of § 75 AWV is untouched by this change and still lists Simbabwe among the destination countries, so arranging deals in listed arms goods for Zimbabwean end use stays prohibited even where the goods themselves may now ship. The rewritten § 76a extends individual exemptions beyond § 74 Absatz 1 and § 75 to prohibitions flowing from directly applicable EU legal actsBund: German authorities can be licensed to export or transit goods for official duties — deviating from EU-act bans only to protect national security under Article 4 Absatz 2 Satz 3 of the Treaty on European Union — and sales, exports, transits and brokering deals can be licensed where the goods serve exclusively the self-protection of diplomatic or consular missions, except missions of the § 74 Absatz 1 embargo countries, or of offices of international intergovernmental organisations and their affiliates.

Section 82, which turns breaches of EU sanctions into German Ordnungswidrigkeiten, is brought up to date and extendedBund. The no-claims catalogue of Absatz 1 is re-issued against the current versions of some twenty EU sanctions regulations, reaching from 1990s Iraq and Haiti instruments to the current Russia, Belarus, Iran, Syria, North Korea, Myanmar, Venezuela, Sudan and South Sudan regimes. New offences back the latest EU tightenings: Belarus breaches listed in the new § 82 Absatz 4 AWV tied to Regulation (EG) Nr. 765/2006 in the version of 23 July 2026, including ownership, control or post-holding permitted after 16 October 2026, listed transactions, changes and support; cooperation caught by Article 17 Absatz 4 of the Iran Regulation 267/2012; nineteen new Russia-related offences under Regulation 833/2014; and four North Korea offences under Regulation 2017/1509 covering joint ventures, activities, agreements and representations. A transposed-digits typo is corrected to Regulation 2368/2002 for the Kimberley diamond rule.

The replaced Ausfuhrliste remains the reference for every AWV licence and ban decision: §§ 8, 11, 46, 52b, 74, 75, 77 and 79 for Part I, § 10 for Part II plant-origin goods. Section A keeps the 0001–0022 arms, munitions and military-equipment list; Section B the nationally controlled goods 1E901–9E992, including related technology and software. Country-specific entries concentrate on Iran and North Korea: handling equipment for biological agents, coating and radar equipment, heavy trucks, helicopters and UAV engines for Iran; fermenters and trucks for North Korea; helicopters also for Cuba, Libya, Myanmar and North Korea; military-featured land vehicles for Libya, Myanmar, Somalia and Pakistan; and digital trunked-radio base stations for Sudan and South Sudan. Licence and ban decisions taken from 17 October 2026 apply the new list textBund, so classifications relying on the previous Anlage 1 need checking.

Legal basis: Dreiundzwanzigste Verordnung zur Änderung der Außenwirtschaftsverordnung (BGBl. 2026 I Nr. 300), amending §§ 74, 76a and 82 and replacing Anlage 1 of the AußenwirtschaftsverordnungBund, enacted under §§ 4, 5, 12 and 19 of the Außenwirtschaftsgesetz.

Re-screen product classifications and open files against the replaced Ausfuhrliste and update sanctions screening for the new Russia, Belarus, Iran and North Korea offences in § 82 AWV.

Sources

Germany replaces arms export list, lifts Zimbabwe arms ban

By Taxxa AI OyPublished 16 October 2026

Industry: Across industries