North Macedonia Advances Export Controls: Draft Law on Dual-Use Goods Aligned with EU Regulation 2021/821

North Macedonia has taken an important regulatory step by publishing for public consultation a Draft Law on the Control of Exports of Dual-Use Goods and Technologies. The draft law is substantially aligned with Regulation (EU) 2021/821, which establishes the EU regime for the control of exports, brokering, technical assistance, transit, and transfer of dual-use items.

This development is highly relevant for businesses operating in advanced manufacturing, ICT, electronics, engineering, chemicals, logistics, and R&D, as well as for institutions involved in cross-border technology transfer.

Key elements of the draft law

The proposed legislation introduces a modern and comprehensive export-control framework, with several notable features:

Full alignment with EU standards
The draft law replaces the existing framework and transposes the core concepts of Regulation (EU) 2021/821, ensuring regulatory convergence with the EU acquis and international non-proliferation regimes.

Expanded scope of control
Controls apply not only to physical exports, but also to:

• brokering services,
• technical assistance,
• transit,
• and intangible transfers, including software and technology transmitted electronically (e-mail, cloud services, remote access, etc.).

Catch-all and cyber-surveillance controls
Export authorisation may be required even for non-listed items where there is a risk of:

• military end-use,
• weapons of mass destruction proliferation,
• internal repression or serious human-rights violations, particularly in relation to cyber-surveillance technologies.

Internal Compliance Programmes (ICP)
Exporters, brokers, and providers of technical assistance are expected to implement risk-based internal compliance programmes proportionate to their size and activities—bringing compliance responsibility closer to industry.

Flexible licensing system
In addition to individual licences, the draft law introduces:

• global licences,
• general licences,
• licences for large projects,
  aimed at reducing administrative burden while maintaining effective control.

Stronger institutional coordination and enforcement
The law reinforces the role of the Ministry of Economy, customs authorities, and the Export Control Commission, and introduces proportionate and dissuasive sanctions for non-compliance.

Why this matters for North Macedonia

As a NATO member state and EU candidate country, North Macedonia has clear obligations to maintain robust export-control mechanisms that support international security, non-proliferation, and human-rights protection.

This draft law demonstrates:

• alignment with NATO and EU security policies,
• commitment to international non-proliferation regimes (NSG, MTCR, Wassenaar Arrangement, Australia Group),
• increased credibility and predictability for foreign investors and strategic partners.

Impact on industry

For businesses, this legislation is not merely a compliance exercise—it is a strategic regulatory shift. Companies may need to:

• reassess whether their products, software, or know-how qualify as dual-use,
• introduce or upgrade internal compliance procedures,
• review contracts, distribution models, and technology-transfer arrangements,
• ensure licensing and reporting obligations are met before engaging in cross-border transactions.

At the same time, alignment with EU rules facilitates smoother cooperation with EU-based partners and improves market access in regulated sectors.

How Law Office Lazarov can assist

Law Office Lazarov has longstanding experience in:

• export-control and trade compliance,
• EU regulatory alignment,
• defence-adjacent and dual-use industries,
• risk assessment, licensing strategies, and internal compliance programmes.

We actively follow the legislative process and advise clients on practical implementation, not only legal theory. Businesses and institutions affected by the new draft law are encouraged to engage early and prepare proactively.

For tailored advice, compliance assessments, or guidance during the public consultation phase, feel free to get in touch with our team.