Swiss Federal Council eases export controls

The Federal Council decided on May 27, 2026, to expand Switzerland’s export control legislation. Starting July 1, 2026, the facilitation for foreign transactions involving military material will be extended to all EU and EFTA states. This particularly concerns the adjustment of the annexes of three regulations, which will now also include the EFTA states and several EU states.

The changes affect Annex 2 of the Military Material Ordinance (MMO), Annex 7 of the Goods Control Ordinance, and Annex 34 of the Ukraine Ordinance. Newly added are the EU states Bulgaria, Estonia, Croatia, Latvia, Lithuania, Malta, Romania, Slovakia, Slovenia, and Cyprus, as well as the EFTA state of Iceland. Thus, starting July 2026, all states of the European Economic Area (EEA) will benefit from the same export control facilitations that already apply to the majority of EU states and Norway.

Background of the Decision

The Federal Council’s decision follows the goal of harmonizing existing export control regulations. All EU states already apply internationally harmonized goods lists due to applicable EU regulations and are bound by the same export control principles as Switzerland. Iceland has also committed to these principles.

The adjustment of the annexes is also intended to lay the groundwork for the planned referendum vote in the fall of 2026. On December 19, 2025, the Parliament passed a revision of the Military Material Act (MMA), which, among other things, stipulates that partner states involved in armed conflicts may receive military material, provided that it is not used in the conflict and that neutrality rights and human rights are upheld.

Details on Export Control Facilitations

The facilitations granted by Annex 2 of the Military Material Ordinance include several points. For example, the requirement for individual permits for the mediation or trade of military material is eliminated. The conclusion of contracts for the transfer of intellectual property, including know-how for military material, is also possible without individual permits. Furthermore, the issuance of a general transit permit will be enabled.

Another aspect is the waiver of a non-re-export declaration for the export of individual parts and assemblies when their manufacturing value is less than 50 percent of that of the finished goods. On-site verification of military materials delivered from Switzerland will also no longer be required.

Annex 7 of the Goods Control Ordinance regulates the issuance of general export permits for nuclear goods as well as goods that can be used for civilian and military purposes. Annex 34 of the Ukraine Ordinance lists the states to which goods may be delivered for installation, with certain exceptions from embargoes and permit requirements provided that the manufacturing costs of the delivered goods are less than 50 percent of the manufacturing costs of the finished armaments.
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