What Is the "Akiraka Guideline"? Japan's 20-Point Test for the Objective Condition of Catch-All Controls, Explained [Updated for the October 2025 Reform]

Hello, this is Hamamoto from TIMEWELL.

If you spend enough time reading the statutes and notices behind export control, sooner or later you run into a document with a slightly odd nickname: the "Akiraka Guideline." Its formal title is the "Guideline for Exporters to Judge When It Is Clear." From the name alone it is hard to tell what it does. In practice, though, it is a heavy piece of judgment — the thing that decides whether you may proceed with a transaction or have to stop it.

This guideline was rewritten on October 9, 2025¹. Work from an old copy and your basis for decisions quietly drifts out of step with the rules in force. In export control, that is a frightening place to be. In this article I want to lay out what the Akiraka Guideline is actually meant to judge, how to read its 20-point checklist, and what changed from the old version — all grounded in Japanese government primary sources. If you are worried about whether your own transactions might get caught, running the free export control check first will help you read the rest of this with your own situation in mind.

"When it is clear" decides the exit of catch-all controls

Start with where this sits in the bigger picture. Catch-all controls (formally, supplementary export controls) require a license even for general-purpose goods that are not on the control list, if there is a concern they will be used to develop weapons of mass destruction or conventional weapons. Whether that regime triggers a license application is decided in roughly two stages. First, does the deal hit the "use requirement" (what it will be used for) or the "end-user requirement" (who will use it)? Second, does it fall under the "inform requirement," where notice arrives from the Minister of Economy, Trade and Industry, or the "objective condition," which the exporter judges through its own checks? I unpacked how these requirements interlock in the guide to the use, end-user, and inform requirements, which is worth reading alongside this piece.

The Akiraka Guideline governs the second half of that: the objective condition. Even with no inform notice from the government, there are situations where information gathered during a deal should let an exporter notice for itself that "this could be used for weapons development." Put the other way around, if you can clear all 20 items and state plainly that "it is clear these goods will be used for purposes other than weapons development," no license application is required¹. The Akiraka Guideline, then, is the yardstick by which an exporter decides — on its own responsibility — the exit of a deal: apply, or don't. Ship goods while that judgment stays vague and you walk straight into unlicensed export, a violation of the Foreign Exchange and Foreign Trade Act.

Why the guideline was rebuilt in October 2025

Before reading the text itself, it helps to understand why the guideline was revised in 2025; that context makes the 20 items click into place. In an April 2025 document, METI cites the spread of dual-use technologies such as semiconductors and communications, the advance of military-civil fusion, and the return of state actors as a central security concern². General-purpose goods are increasingly diverted straight into weapons development, even as it grows harder for exporters to verify end-use on their own. The reform was built to answer that contradiction.

Concretely, for general destinations the reform added the use requirement and the end-user requirement for certain items (item 16(1) of the Export Order), and for arms-embargoed destinations it added the end-user requirement across all items². The specific items covered fall into six categories — machine tools, radar and aeronautical radio equipment, integrated circuits, aircraft and unmanned-aircraft parts, navigation equipment, and inspection equipment — each specified down to the HS code. And to judge the objective condition, the Akiraka Guideline was formally built in alongside the Foreign End User List. In short, a yardstick that had mainly assumed weapons of mass destruction was rebuilt to also handle the general-purpose-goods risk of conventional weapons. For the wider shape of this reform, see the article on how list controls and catch-all controls relate; the thinking on target destinations is covered in the guide to white countries (Group A).

Reading the 20 items through seven angles

The current Akiraka Guideline organizes its 20 checkpoints under seven groups¹. This is not something to memorize; it works far better if you treat it as a list of angles — different directions from which to spot the unnatural in a deal. Here is the whole map.

Angle	Item numbers	What you are checking
End-use and specifications	①②	Is there a clear account of the end-use, and does that end-user have a rational reason to genuinely need these goods?
Installation site and setup	③④⑤	Is the site clear? In a military-adjacent or classified area, is there no doubt about the use? Are excessive safety measures being demanded?
Related equipment	⑥⑦⑧⑨	Is there an account of the raw materials handled alongside it, is the combination with equipment coherent, and is there no abnormally large spare-parts order?
Marking, shipping route, packaging	⑩⑪⑫	Is there anything unnatural about the marking, shipping, route, or packaging?
Payment and warranty	⑬⑭	Are the payment terms not abnormally generous, and is a normal level of performance warranty being sought?
Setup refusal and confidentiality	⑮⑯	Is the customer not refusing the expert dispatch that would normally be needed, and not demanding excessive secrecy about the final destination?
Foreign End User List and other	⑰⑱⑲⑳	For deals with listed entities, can the concern be dispelled? Is there no communication pointing to military use? Are there no suspicious points in the transaction?

Lay it out this way and the knack of judging becomes visible. One item tripping does not mean automatic rejection. Conversely, each item can look fine on its own, yet reading the whole thing leaves you feeling "this deal simply doesn't add up." That discomfort — and turning it into concrete, checkable questions — is what the 20 items are for. A customer who stubbornly refuses installation, an end-user who insists on hiding the final destination, payment terms far more generous than the market. Any one of them may have an explanation; stacked together, they become a warning sign. I wrote up how to dig into the trustworthiness of the counterparty itself in the article on end-user screening.

The real discipline: don't turn a blind eye to inconvenient information

More than the content of the 20 items, what I find matters most on the ground is a single line at the top of the guideline. Exporters should confirm through documents obtained from the counterparty within the bounds of ordinary commercial practice, and must "not turn a blind eye to information, among what they have obtained, that is inconvenient to themselves"¹. It is a plain sentence, but it goes to the heart of export control. The hungrier you are for the sale, the more you want to pretend you never saw the inconvenient fact. The government has deliberately written into the text that you must not do this.

The 2025 version reinforced that idea with concrete examples, which is the bigger change. Take the item on whether an end-user has a rational reason to need the goods. The text now adds that where the goods' performance does not match the counterparty's business — "a small bakery ordering several high-performance lasers" — or where the end-user has almost no experience in that field, or where the final end-user is a freight company, "a rational reason is presumed not to exist"¹. A counterparty reluctant to explain the use is presumed to have given "no clear account"; one reluctant to name the installation site is presumed to have left it "unclear." In other words, the guideline now tells exporters to read suspicious silence against themselves. This mirrors the "Know Your Customer" thinking and red flags of the U.S. BIS³. The world over, export control is the job of drawing out what the other side won't say. If a check leaves doubts, resolve them before advancing the deal; when the judgment is genuinely hard, you can consult METI's Security Export Control Policy Division. Keeping that order is the shortest path to never being told, later, that you "should have caught it."

If keeping export control moving without breaking your team is the problem, it is worth weighing a system like TRAFEED, which uses AI to support classification and end-user screening. Manual checks are exactly where "overlooking the inconvenient fact" tends to slip in.

How the 2012 and 2025 versions differ

Plenty of teams are still working from an old copy. To tell whether the PDF on your desk is current, it helps to know how the old and new versions differ. The original Akiraka Guideline came from a 2012 notice (Trade Bureau Notice No. 1 of March 23, 2012; Export Note 24, No. 24) and had 19 checkpoints⁴. The current version, effective October 9, 2025, has 20¹.

The item count is not the only thing that moved. First, ordinances and notices on conventional-weapons development were added to the legal basis, so a single yardstick now covers conventional-weapons catch-all controls as well as WMD. Second, as with the bakery example above, judgments that used to rest on practitioners' tacit knowledge are now written into the text as "presumptions." Third, the item on entities listed on the Foreign End User List was subdivided into an (a) and a (b), and a new item was added covering deals bound for the regions in Appended Table 3-2 of the Export Order or with non-residents as end-users. What used to be the "other" item slid down to number 20. These look like fine adjustments, but by widening the coverage to the general-purpose-goods risk of conventional weapons, their practical impact is far from small.

Working it into the daily routine, and a closing thought

Finally, here is how the Akiraka Guideline drops into everyday work. The steps themselves are simple.

• First confirm whether the deal involves a specified item or a controlled category
• Gather what you can obtain on the use and the end-user — contracts, emails, and the like
• Go through the 20 items one by one, checking for anything unnatural or unexplained
• If doubts remain, confirm with the counterparty before shipping; if you cannot resolve them, move to a license application

Written out it looks obvious, yet running this properly every single time, on a busy floor, is harder than it sounds. That is precisely why it pays to invest in a process where gaps are less likely to slip through. I have come to think of export control as the craft of doubting. The wish to trust your counterparty, and the discipline not to look away from inconvenient information — whether you can hold both is what separates a capable practitioner from the rest. The 20-point checklist is the frame that supports that discipline from the outside. Start by checking whether your current workflow really covers all 20. When a specific transaction leaves you unsure, you can also talk it through with the TRAFEED team.

If you are reviewing export-control operations or classification workflows, download the TRAFEED product catalog (PDF) or contact us.

References

Footnotes

1. Guideline for Exporters to Judge "When It Is Clear" (effective October 9, 2025) — Ministry of Economy, Trade and Industry — accessed July 8, 2026 (Japanese) ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶

2. On the Review of Supplementary Export Controls (April 2025) — METI Trade and Economic Security Bureau — accessed July 8, 2026 (Japanese) ↩ ↩²

3. Basics of Export Control — Center for Information on Security Trade Control (CISTEC) — accessed July 8, 2026 (Japanese) ↩

4. Guideline for Exporters to Judge "When It Is Clear" (Trade Bureau Notice No. 1 of March 23, 2012 / Export Note 24, No. 24) — Ministry of Economy, Trade and Industry — accessed July 8, 2026 (Japanese) ↩