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What Is Appended Table 1 of Japan's Export Trade Control Order? A Beginner's Complete Guide to Items 1-16, Classification, and How to Look Things Up (2026 Edition)

Published2026-07-07濱本 隆太

A beginner-friendly deep dive into Appended Table 1 (beppyo dai-1) of Japan's Export Trade Control Order. We map where the table sits in the legal hierarchy from the Foreign Exchange and Foreign Trade Act down to the Goods and Technologies Ministerial Ordinance, lay out the structure of Items 1 through 16 plus Item 3-2 in a single reference table, explain the relationship between list controls and the Item 16 catch-all controls, contrast the table with the Foreign Exchange Order's appended table, and walk through how classification is actually done in practice — all based on the statutory text on e-Gov and primary sources from METI.

What Is Appended Table 1 of Japan's Export Trade Control Order? A Beginner's Complete Guide to Items 1-16, Classification, and How to Look Things Up (2026 Edition)
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Hello, this is Hamamoto from TIMEWELL. When I sit down with companies to talk about export controls, there is one term that comes up within the first ten minutes, almost without fail: "Appended Table 1" — 別表第1 (beppyo dai-1) in Japanese, often shortened to just betsu-1 in day-to-day conversation. Which item of Appended Table 1 does our product fall under? What is Appended Table 1 in the first place? If you cannot answer these questions, export control work simply cannot move forward. Japan's security export control system is built around a single starting point: checking whether the goods you intend to export are caught somewhere in Appended Table 1 of the Export Trade Control Order. That check is called classification — gaihi hantei — and everything else flows from it. In this article, I want to walk through Appended Table 1 from the ground up, based on the statutory text you can verify on e-Gov, Japan's official legal database, written so that someone encountering export controls for the first time can follow along. By the end, you should have a working map of Items 1 through 16 in your head.

Let me start with the big picture. The foundation of Japan's export regulations is the Foreign Exchange and Foreign Trade Act — gaitame-ho for short, and often abbreviated FEFTA in English. Article 48, Paragraph 1 of that act provides that exporting specific kinds of goods to specific destinations requires a license from the Minister of Economy, Trade and Industry. The statute itself, however, does not spell out which goods are covered. The concrete details are set by a cabinet order: the Export Trade Control Order (Cabinet Order No. 378 of 1949), which practitioners abbreviate as the "Export Order" (yushutsu-rei). Article 1 of the Export Order defines the exports that require a license as "exports of the goods listed in the middle column of Appended Table 1, destined for the regions listed in the lower column of the same table"[^2].

In other words, Appended Table 1 of the Export Trade Control Order (別表第1) is the catalog of goods whose export requires a license from the Minister of Economy, Trade and Industry. The structure of the table is simple: the middle column lists "goods," and the lower column lists "regions"[^1]. The middle column identifies the item; the lower column identifies which destinations trigger the control. Whether a license is required is determined by the combination of these two columns.

At this point, let me pin down the term that runs through this entire article: classification, or gaihi hantei. Classification is the procedure of determining whether the goods you intend to export, or the technology you intend to provide, falls under the control list or not. If it does, you proceed to a license application. If it does not, you move on to a check against the catch-all controls — more on those later — and then to export. For any company involved in exporting, practical work almost always begins with this determination.

There is one more thing worth knowing up front, because it makes everything that follows much easier: Appended Table 1 sits in the middle of a layered legal hierarchy. From the top down, the layers are the Foreign Exchange and Foreign Trade Act (the statute); Appended Table 1 of the Export Trade Control Order together with the appended table of the Foreign Exchange Order (cabinet orders, which set the categories of items and the regions); the Goods and Technologies Ministerial Ordinance (a ministerial ordinance, which sets the concrete specifications); the operational circulars and service circulars (interpretation); and finally the Matrix Table, a practical working tool[^10]. Appended Table 1 only goes as far as deciding which categories of goods belong to which item numbers. The actual specifications — so many millimeters or more, so many watts or more — are delegated to the ministerial ordinance. If you stare at Appended Table 1 alone without knowing about this division of labor, you cannot actually perform a classification. I will come back to this in detail in a later section.

Incidentally, if you are not sure how mature your company's export control setup is in the first place, I would suggest taking the free export-control readiness check before reading on. Knowing where you currently stand makes the rest of this article far more concrete.

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The Structure of Items 1 Through 16, at a Glance

The item numbers in Appended Table 1 run from Item 1 to Item 16 — but the table does not actually have 16 rows. Between Item 3 and Item 4 sits "Item 3-2" as an independent row, so the table effectively consists of 17 item rows: the 16 numbered items plus Item 3-2[^1]. This is a point where first-time readers stumble almost without exception, so let me put the whole picture in a table before going any further.

Item Field Examples of goods listed in the middle column
1 Arms Firearms and ammunition with their accessories and parts, explosives, gunpowder, military fuels, etc.[^3]
2 Nuclear Nuclear fuel materials and source materials, nuclear reactors and related equipment, etc.[^4]
3 Chemical weapons Precursor substances for military chemical agents and equipment for their manufacture, etc.[^4]
3-2 Biological weapons Organisms and toxins usable as raw materials for military bacterial agents; equipment for their development, manufacture, or dispersal, etc.[^4]
4 Missiles Rockets, unmanned aerial vehicles, individual stages of multistage rockets and reentry vehicles, etc.[^4]
5 Advanced materials Advanced materials whose specifications are set by ministerial ordinance[^5]
6 Materials processing Machine tools, bearings, etc.[^5]
7 Electronics Integrated circuits, etc.[^5]
8 Computers Computers whose specifications are set by ministerial ordinance[^5]
9 Telecommunications Communications-related equipment whose specifications are set by ministerial ordinance[^5]
10 Sensors and lasers Underwater detection equipment, optical detectors, etc.[^5]
11 Navigation Accelerometers, gyroscopes, etc.[^5]
12 Marine Submersibles, etc.[^5]
13 Propulsion Gas turbine engines, space vehicles, etc.[^5]
14 Other Powdered metal fuels, explosives precursors, etc.[^5]
15 Sensitive items Formed inorganic fiber products, radar-absorbing materials, etc.[^5]
16 Catch-all A broad range of goods not covered by Items 1-15. Details below[^6]

These 17 rows become much easier to memorize if you view them as four blocks with distinct characters. The first block is Item 1, arms: military materiel as such, including conventional weapons — firearms, explosives, and so on[^3]. The second block runs from Item 2 through Item 4 (including 3-2) and covers the weapons-of-mass-destruction cluster: nuclear, chemical weapons, biological weapons, and missiles[^4]. The third block, Items 5 through 15, is the so-called dual-use block. "Dual-use" means usable by both military and civilian sectors — items that circulate perfectly normally in civilian markets but that could, depending on their performance, be diverted to weapons development. Machine tools, integrated circuits, accelerometers, and similar items are arranged here by field[^5]. And finally Item 16, alone among the items, serves a different purpose entirely: it is the receptacle for the catch-all controls[^6].

Item 1 has a feature that no other item shares. While most items from Item 2 onward list goods with the qualifier "those meeting specifications prescribed by ordinance of the Ministry of Economy, Trade and Industry," Item 1 spells out its specifications directly, without delegating to a ministerial ordinance[^3]. My reading of this is that it reflects a philosophy: weapons themselves are controlled regardless of how high or low their performance is.

Reading the Item Numbers and the Goods and Technologies Ministerial Ordinance: Why the Cabinet Order Alone Cannot Give You an Answer

Suppose you looked at the table in the previous section and formed a hunch: "Our product probably relates to Item 7, electronics." Can you now read Item 7 of Appended Table 1 and complete your classification? No — and this is the single biggest quirk of Appended Table 1.

The middle columns of Items 2 through 15 open with the phrasing "the following goods, meeting specifications prescribed by ordinance of the Ministry of Economy, Trade and Industry"[^4]. In other words, the cabinet order — Appended Table 1 itself — contains only category names such as "integrated circuits" or "machine tools." The specification thresholds that determine what performance level actually triggers control are delegated wholesale to a ministerial ordinance[^5].

That delegation lands in what practitioners informally call the Goods and Technologies Ministerial Ordinance (kamotsu-to shorei). Its formal name is the "Ministerial Ordinance Specifying Goods or Technologies Pursuant to the Provisions of Appended Table 1 of the Export Trade Control Order and the Appended Table of the Foreign Exchange Order" (Ordinance of the Ministry of International Trade and Industry No. 49 of 1991). As the name says, it sets out the concrete specifications of the goods and technologies that each item of Appended Table 1 and each item of the Foreign Exchange Order's appended table points to[^10]. Classification in practice is therefore a two-stage exercise: identify candidate item numbers in Appended Table 1, then go to the corresponding provisions of the Goods and Technologies Ministerial Ordinance and compare your product's specifications against the controlled parameters.

That said, shuttling between the cabinet order, the ministerial ordinance, and the circulars in their original text every single time is exhausting. This is where the tool used throughout the industry comes in: the Matrix Table, published through the Ministry of Economy, Trade and Industry (METI). It is an Excel file that consolidates the control content of the cabinet order, ministerial ordinance, and circulars into a single view, organized by item number (Items 1-15) across Appended Table 1 and the Foreign Exchange Order's table, and practitioners use it to match specifications[^12]. One caution: a single product can be controlled under more than one item number. To use METI's own example, machine tools are controlled under both Item 2 (nuclear) and Item 6 (conventional arms-related). This is why you should never scan the Matrix Table by eye alone — use the search function and check exhaustively[^12].

There is one more thing that keeps practitioners up at night: the frequency of amendments. Appended Table 1 and the Goods and Technologies Ministerial Ordinance are amended almost every year to track international developments and technology trends. Most recently, the amendment covering critical and emerging items (Cabinet Order No. 102 of 2025, promulgated March 28, 2025, in force May 28, 2025) added advanced-semiconductor-related items such as nanoimprint lithography equipment and mask writing equipment[^14]. On top of that, the fiscal 2025 regular list amendment (Cabinet Order No. 376 of 2025, promulgated November 14, 2025) followed an unusual schedule, with the list-amendment portion entering into force three months after promulgation, on February 14, 2026[^14]. The practical upshot, here in 2026, is that you must always question whether the classification materials on your desk reflect the latest amendments. For a detailed look at how the semiconductor-related controls have accumulated over time, see my companion piece on the items covered by Japan's semiconductor export controls.

List Controls and Catch-All Controls: Why Item 16 Is the Odd One Out

METI describes Japan's export controls as a two-pillar system: "list controls" and "catch-all controls" (also called complementary export controls)[^11]. Within Appended Table 1, these two pillars live side by side, in the form of Items 1-15 on the one hand and Item 16 on the other.

List controls are the world of Items 1 through 15 that we have been looking at. Sensitive goods and technologies are placed on a list in advance, and if an item falls under the list, a license from the Minister of Economy, Trade and Industry is in principle required regardless of the destination[^11]. As the name suggests, in this world everything turns on whether you are on the list or not.

Catch-all controls work from the opposite direction. Even for goods not on the list, a license is required if there is a risk they will be used in the development of weapons of mass destruction or similar programs. Item 16 is the legal basis for this "net that catches what slipped through" mechanism. The middle column of Item 16 has a two-story structure: part (i) lists specific items — machine tools, radar, integrated circuits, aircraft, and so on — with ministerial-ordinance designations, while part (ii) broadly covers goods falling under Chapters 25 through 40, 54 through 59, 63, 68 through 93, and 95 of the appended table of the Customs Tariff Act (excluding goods that fall under Items 1-15 and certain others)[^6]. Because the coverage is specified by chapter numbers, it is hard to picture — but in plain terms, a very large share of the industrial products around you fall inside it. This is precisely why a company cannot say, "Our product is not on the control list, so export controls have nothing to do with us."

Item 16 does not demand a license at all times, however. There are two triggers: when the exporter comes to know of a risk that the goods will be used for the development of weapons of mass destruction or of conventional weapons (the objective requirement), and when the exporter receives a so-called "inform" notification from the Minister of Economy, Trade and Industry[^11]. "Weapons of mass destruction and related items" here is defined to include nuclear weapons, military chemical agents, military bacterial agents, devices for dispersing them, and rockets and unmanned aerial vehicles capable of delivering payloads 300 km or more (in each case including parts and components); "conventional weapons" is defined as the goods listed in the middle column of Item 1 of Appended Table 1 (excluding those that qualify as weapons of mass destruction and related items)[^11].

Item 16 is also unusual in its destination coverage. Its lower column reads "all regions (excluding the regions listed in Appended Table 3)"[^6]. Appended Table 3 is what is known as Group A — formerly called the "White Countries" — a list of 27 countries including the United States, the United Kingdom, Germany, France, and South Korea[^8]. The design principle is that the catch-all objective requirement is not imposed on exports to countries with robust export control systems of their own. As for the legal basis, both the list controls and the Item 16 catch-all rest on the same provision — Article 48, Paragraph 1 of the Foreign Exchange and Foreign Trade Act, given effect through Article 1 of the Export Trade Control Order. The difference lies in how the license obligation is triggered: for Items 1 through 15 a license is required whenever the goods fall under the item, whereas for Item 16 the obligation arises only when the requirements described above are met[^2].

And Item 16 underwent a major overhaul that took effect on October 9, 2025. The item was split into "Item 16(1) = specified items" and "Item 16(2) = everything else." Item 16(1) enumerates specified items — machine tools; radar, radio navigation equipment, and radio remote-control apparatus; integrated circuits; aircraft and spacecraft together with their parts; navigation instruments; and inspection equipment — identified by their customs classification (HS) codes. The reform strengthened the conventional-weapons catch-all by requiring end-user checks even for exports to general destinations outside Group A. The legal basis is Cabinet Order No. 175 of 2025 (promulgated April 9, 2025, in force October 9, 2025)[^13]. If you want to dig deeper into how list controls and catch-all controls fit together, I have laid that out in the complete picture of list controls and catch-all controls.

Four Points Beginners Commonly Confuse

Appended Table 1 is surrounded by tables and regimes with confusingly similar names. Drawing on the questions I have fielded over the years, here are four points of confusion, in descending order of how often they come up.

The first is the difference between Appended Table 1 and Appended Table 2. They are tables within the same Export Order, but their characters are completely different. Appended Table 1 defines the scope of export "licenses" (the Article 48 framework of the Foreign Exchange and Foreign Trade Act), whereas Appended Table 2 defines the scope of export "approvals." Article 2 of the Export Order provides that exporting the goods in the middle column of Appended Table 2 to the regions in its lower column requires the approval of the Minister of Economy, Trade and Industry. What Appended Table 2 covers are controls with policy objectives different from the security list controls — items subject to the Washington Convention (CITES), and controlled items destined for North Korea, Russia, and Belarus, for example[^7]. When practitioners casually say betsu-1 and betsu-2, understand that they are talking about two different worlds.

The second is the difference between Appended Table 1 and the appended table of the Foreign Exchange Order. What Appended Table 1 controls is strictly "goods" — the export of physical things. The provision of "technology" — drawings, software, technical guidance — is controlled under the Article 25 framework of the Foreign Exchange and Foreign Trade Act by the appended table of the Foreign Exchange Order (gaitame-rei, Cabinet Order No. 260 of 1980). What is interesting is how that table is drafted: each of its items takes the form "technology pertaining to the design, manufacture, or use of the goods listed in the middle column of Item X of Appended Table 1 of the Export Trade Control Order," so the items correspond one-to-one with the goods-side item numbers all the way through Item 16[^9]. When you export a product, check Appended Table 1; when you hand that product's manufacturing know-how to an overseas subsidiary, check the Foreign Exchange Order's table. Goods and technology enter through different doors — remember that, and you will be fine.

The third is confusing "not falling under the list controls" with "having nothing to do with the regulations." As we saw in the previous section, even goods that do not fall under Items 1-15 are, in a great many cases, within the coverage of Item 16. When a business partner asks you for a non-applicability certificate (a document stating the result of your classification), there is a large difference in credibility between simply writing "not applicable" and being able to set out against which items the goods are not applicable, and how they relate to Item 16. I explain how to write these documents concretely in the guide to writing non-applicability certificates.

The fourth is how to count the item numbers. As the table at the top of this article showed, Appended Table 1 contains Item 3-2 — so if you hear "Items 1 through 16" and assume 16 rows, you will miss the biological weapons item entirely[^1]. It may sound like a pedantic detail, but this is a real omission that occurs when companies build their own internal reference sheets and classification checklists. A small aside: the first time I read this table end to end, I did not notice Item 3-2 either, and I remember scratching my head because my count would not add up. Sub-numbered items are routine in the world of Japanese statutes, but they catch you off guard the first time.

Classification in Practice: How to Look Up Appended Table 1 and Make the Call

Finally, let me translate everything so far into a working procedure. Checking whether your product falls under Appended Table 1 breaks down into roughly four stages.

Stage one is organizing the product's specifications. Gather the model numbers, performance figures, materials, and intended uses of the goods to be classified from your engineering teams. In truth, the accuracy of the classification is largely decided at this stage — if you start with vague specifications, everything downstream becomes guesswork. In stage two, you scan Items 1-15 of Appended Table 1 for candidate item numbers; the reference table in this article should serve as your entry point. Stage three is the heart of the exercise: using the Matrix Table and the provisions of the Goods and Technologies Ministerial Ordinance, you compare the controlled specifications against your product's specifications at the level of actual numbers. As the machine-tool example showed, some items are controlled under multiple item numbers, so even if one item comes back "not applicable," do not relax — run searches and check across the table[^12]. In stage four, you record the result and its basis in the form of a classification report. Only then is the classification of a single product complete.

It sounds straightforward written out like this, but doing it is far more labor-intensive than you would imagine. Companies with large product portfolios face hundreds or thousands of items to classify, and as noted above, the regulations move every year. Amendments like the regular list amendment that entered into force on February 14, 2026 can force a review of past classification results with every effective date[^14]. There is also the deep-rooted problem of institutional knowledge: when the person responsible for classification transfers, the reasoning behind past determinations walks out the door with them. In my experience advising companies on export controls, most of the organizational pain traces back to the absence of exactly this — a mechanism for keeping the process running continuously.

To address that burden, we offer TRAFEED, an AI agent for export control. Built around classification support aligned with METI's standards, it delivers AI classification accuracy above 95% (based on a joint study with Okayama University using roughly 30,000 past screening records, our own analysis), reflects regulatory amendments across jurisdictions on the day they take effect, and visualizes the level of concern in five seconds; the classification logic is protected by patent (Japanese Patent No. 7862062). More than 20 organizations use it today. But there is one principle we state consistently: AI is a tool that accelerates the groundwork and the organization of supporting evidence, while the final classification decision is made by your company's export control officer. TRAFEED's role, as we see it, is to cut the time and the key-person risk out of classification without ever crossing that line.

Appended Table 1 is not a frightening table once you grasp its structure. The middle column and the lower column; the 17 item rows; the division of labor between the cabinet order and the ministerial ordinance; and the different face that Item 16 alone wears as the catch-all. With those four points in hand, my recommended next action is to pick one of your flagship products and actually run it against the Matrix Table. Working through it by hand will make everything in this article click into three dimensions. If you run into questions about building or operating a classification process, we also take those through Book a consultation. The statutory text is dry, but what lies behind it is the practical work of protecting your company's technology while continuing to trade with the world. Start with the map of 17 rows.

References

[^1]: Export Trade Control Order, Appended Table 1 (re: Articles 1 and 2) — middle column, lower column, and item structure — e-Gov Legal Database (Digital Agency) — version in force June 5, 2026 (Japanese) [^2]: Export Trade Control Order (Cabinet Order No. 378 of 1949), Article 1 (Export Licenses) — e-Gov Legal Database (Digital Agency) — version in force June 5, 2026 (Japanese) [^3]: Export Trade Control Order, Appended Table 1, Item 1 (Arms) — e-Gov Legal Database (Digital Agency) — version in force June 5, 2026 (Japanese) [^4]: Export Trade Control Order, Appended Table 1, Items 2-4 (Nuclear, Chemical Weapons, Biological Weapons, Missiles) — e-Gov Legal Database (Digital Agency) — version in force June 5, 2026 (Japanese) [^5]: Export Trade Control Order, Appended Table 1, Items 5-15 (Advanced Materials through Sensitive Items) — e-Gov Legal Database (Digital Agency) — version in force June 5, 2026 (Japanese) [^6]: Export Trade Control Order, Appended Table 1, Item 16 (Goods Subject to Catch-All Controls) — e-Gov Legal Database (Digital Agency) — version in force June 5, 2026 (Japanese) [^7]: Export Trade Control Order, Article 2 (Export Approvals) and Appended Table 2 — e-Gov Legal Database (Digital Agency) — version in force June 5, 2026 (Japanese) [^8]: Export Trade Control Order, Appended Table 3 (re: Article 4) — the 27 listed countries — e-Gov Legal Database (Digital Agency) — version in force June 5, 2026 (Japanese) [^9]: Foreign Exchange Order (Cabinet Order No. 260 of 1980), Appended Table (re: Articles 17 and 18) — e-Gov Legal Database (Digital Agency) (Japanese) [^10]: Ministerial Ordinance Specifying Goods or Technologies Pursuant to the Provisions of Appended Table 1 of the Export Trade Control Order and the Appended Table of the Foreign Exchange Order (MITI Ordinance No. 49 of 1991; the "Goods and Technologies Ministerial Ordinance") — e-Gov Legal Database (Digital Agency) (Japanese) [^11]: Complementary Export Controls (Catch-All Controls) — Ministry of Economy, Trade and Industry — accessed May 20, 2026 (Japanese) [^12]: About Classification and the Goods/Technologies Matrix Table — Ministry of Economy, Trade and Industry — accessed February 18, 2026 (Japanese) [^13]: On the Revision of the Complementary Export Controls (Cabinet Order No. 175 of 2025, in force October 9, 2025) — METI Trade and Economic Security Bureau — October 9, 2025 (Japanese) [^14]: Commentary on the FY2025 Regular List Amendments — CISTEC Secretariat — November 18, 2025 (Japanese)

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