The European Union (EU) has formally integrated human rights into its external policies, yet tensions continue to exist between these commitments and other objectives within the filed of export controls. The main export control regimes in the EU – the Dual-Use Goods Regulation and the EU Common Position on Arms Exports – both integrate human rights commitments but differ in terms of their legal bases, substantive rules and procedural mechanisms. This article examines whether these instruments ensure coherence, understood not merely as the absence of contradictions but as the mutual reinforcement of human rights considerations. Through legal analysis, this research finds that the fragmentation between the two frameworks, in combination with the wide Member State discretion, undermines a coherent EU approach. Divergences in denial obligations, the lack of common definitions and the absence of EU-level risk assessments show how institutional and procedural disparities can weaken human rights protection in practice. Ultimately, the article provides recommendations for strengthening the coherence between the two frameworks, situating these within the broader challenge of reconciling economic, security and human rights priorities within EU external action.
European Foreign Affairs Review