What Is Appended Table 1 of Japan's Export Trade Control Order? Items 1–16 Explained

Hello, this is Ryuta Hamamoto from TIMEWELL.

If you work on a global trade compliance team and your Japanese supplier or subsidiary keeps saying "Appended Table 1" or beppyo dai-1, this is the map. In almost every export control conversation I have with companies that touch Japan, the term shows up within ten minutes. Which item of Appended Table 1 covers this SKU? What is Appended Table 1 in the first place? If those answers are fuzzy, Japanese export control work does not start.

Japan's security export controls begin with one question: does the good you plan to ship sit somewhere in Appended Table 1 of the Export Trade Control Order? That check is classification, gaihi hantei in Japanese, and everything else hangs off it. For this update I went back through the e-Gov text line by line as of October 4, 2026, so a non-Japanese compliance officer can work from it. This explains the law as it stands on that date; it is not legal advice.

The 30-second version. Appended Table 1 is attached to Japan's Export Trade Control Order (Cabinet Order No. 378 of 1949). It lists goods (middle column) and destinations (lower column) that need a license from METI before export. Items run from 1 to 16, but Item 3-2 adds a row, so there are 17. Items 1–15 are list controls for all destinations. Item 16 is the catch-all, and its triggers depend on where the goods are going. The actual thresholds live in a ministerial ordinance, and the contents current in October 2026 reflect the amendment that took effect on February 14, 2026.

What Appended Table 1 is and where it sits in Japanese law

Japan's export rules rest on the Foreign Exchange and Foreign Trade Act (FEFTA). Article 48(1) says that exporting certain goods to certain destinations requires a license from the Minister of Economy, Trade and Industry¹. The statute does not list the goods. The cabinet order does: the Export Trade Control Order, usually shortened to the Export Order. Article 1(1) of that order defines license-required exports as goods listed in the middle column of Appended Table 1, destined for regions listed in its lower column².

So Appended Table 1 is the catalog of goods whose export needs a METI license. Middle column, goods. Lower column, regions³. Whether you need a license depends on the combination of the two.

Classification (gaihi hantei) is the process of deciding whether the goods or technology you will move fall on the control list⁴. If yes, you head toward a license. If no, you still run the catch-all checks before shipping. METI states plainly that it does not classify products for exporters⁵. The exporter owns that call. The full process METI describes is laid out in Japan export classification (gaihi hantei) in five steps.

One structural fact saves months of confusion. Appended Table 1 is a middle layer. From the top down, the stack is FEFTA (statute); Appended Table 1 of the Export Order and the Foreign Exchange Order table (cabinet orders that set categories and regions); the Goods and Technologies Ministerial Ordinance (concrete specifications); operational and service circulars (interpretation); and the Matrix Table, the Excel tool everyone actually works in⁶. Appended Table 1 decides only which categories belong to which item numbers. Millimeters, watts, and other thresholds live in the ordinance. Staring at Appended Table 1 alone will not finish a classification, and I come back to that in the third section. For how the cabinet order itself is organized, including the split between Appended Tables 1 and 2, see What is Japan's Export Trade Control Order? A one-page map.

If you are not sure how mature your Japan-facing program is, take the free export control readiness check first. Knowing your starting point makes the rest of this piece concrete.

Items 1–16 at a glance: 17 rows and the regimes behind them

Item numbers run from 1 to 16, but the table does not have 16 rows. Item 3-2 sits between Items 3 and 4 as its own row, so there are 17³. First-time readers miss this almost every time. The right-hand column shows which international arrangement each item broadly reflects⁷.

Item	Field	Examples in the middle column	Framework behind it
1	Arms	Firearms and ammunition, explosives, propellants, military vehicles and aircraft and their parts8	Japan's Three Principles on Transfer of Defense Equipment and Technology
2	Nuclear	Nuclear fuel and source materials, reactors and their auxiliary equipment9	Nuclear Suppliers Group (NSG)
3	Chemical weapons	Precursors for military chemical agents and equipment used to make them9	Australia Group (AG)
3-2	Biological weapons	Organisms and toxins usable for military bacterial agents, fermenters, centrifuges, peptide synthesizers9	Australia Group (AG)
4	Missiles	Rockets, UAVs, multistage rocket stages9	Missile Technology Control Regime (MTCR)
5	Advanced materials	Fluorinated compound products, aromatic polyimide products, alloy and refractory metal powders10	Wassenaar Arrangement (WA)
6	Materials processing	Bearings, numerically controlled machine tools, additive manufacturing equipment10	WA
7	Electronics	Integrated circuits, cryogenic coolers, modules with embedded FPGAs10	WA
8	Computers	Computers and peripherals meeting ordinance specifications10	WA
9	Telecommunications	Transmission equipment, optical fiber for communications, phased array antennas10	WA
10	Sensors and lasers	Underwater acoustic detection equipment, optical detectors10	WA
11	Navigation	Accelerometers, gyroscopes, inertial navigation equipment10	WA
12	Marine	Submersibles, underwater recovery equipment10	WA
13	Propulsion	Gas turbine engines, satellites and their parts10	WA
14	Other	Powdered metal fuels, explosive precursors10	WA
15	Sensitive items	Formed products using inorganic fibers, radar and infrared absorbing materials10	WA
16	Catch-all	A wide range of industrial goods not covered by Items 1–15 (see below)11	Japan's complementary (catch-all) controls

Once you have candidate item numbers, record the comparison. Our item check sheet for Appended Table 1 and the Foreign Exchange Order table is an Excel workbook (Japanese-language) built for pasting rows from METI's Matrix Table, comparing each control parameter with your own specs, and keeping the reasoning. Any of Items 1–15 with no rows checked shows up as "not yet checked" on the summary tab, so a blank never passes for "not controlled." It reflects the amendments effective February 14, 2026, and it is our own original format, separate from the comparison forms CISTEC publishes. Download the item check sheet (free; company name and work email required).

Four blocks make the table easier to hold in your head. Item 1 is arms, military materiel as such⁸. Items 2–4, including 3-2, are the weapons of mass destruction cluster: nuclear, chemical, biological, missiles⁹. Items 5–15 are dual-use goods, ordinary commercial products that could support weapons programs depending on performance¹⁰. Item 16 alone is the catch-all receptacle¹¹.

If you know the EU dual-use list or the U.S. Commerce Control List, Items 5–15 will look familiar, because all of them trace back to the same multilateral lists. The numbering and some of the drafting differ, though. My advice is never to map a Japanese item number to a U.S. or EU entry by assumption; check the Japanese text.

Some rows are new. The amendment effective May 28, 2025 (Cabinet Order No. 102 of 2025) added additive manufacturing equipment to Item 6, and cryogenic coolers plus certain silicon and germanium compounds and substrates to Item 7. The amendment effective February 14, 2026 (Cabinet Order No. 376 of 2025) added alloy powders to Item 5, modules and equipment with embedded FPGAs to Item 7, and peptide synthesizers to Item 3-2¹². In fast-moving areas such as semiconductors, quantum, and additive manufacturing, a classification file from a few years ago will miss rows.

Item 1 is also drafted differently. Most items from 2 onward describe goods "meeting specifications prescribed by ordinance," but Item 1 lists its goods directly, with no delegation to the ordinance⁸. My read: weapons are controlled regardless of performance band.

Why the cabinet order alone cannot finish a classification, and how to find the current text

Suppose your hunch is "Item 7, electronics." Can you finish classification from Item 7 of Appended Table 1? No. That is the table's main quirk for teams used to a self-contained control list entry.

The middle columns of Items 2, 4 through 13, and 15 describe goods "meeting specifications prescribed by ordinance of the Ministry of Economy, Trade and Industry." Items 3, 3-2, and 14 delegate to the ordinance sub-item by sub-item⁹¹⁰. The cabinet order names categories such as "integrated circuits" or "machine tools," and the thresholds sit in the Goods and Technologies Ministerial Ordinance (MITI Ordinance No. 49 of 1991)⁶. Classification is two-stage: pick candidate item numbers in Appended Table 1, then match your product's specs to the ordinance parameters.

Moving between order, ordinance, and circulars in raw Japanese every time is painful, so industry uses METI's Matrix Table. It splits controlled goods and technology by item number (Items 1–15) across Appended Table 1 and the Foreign Exchange Order table, and lists the relevant provisions of the order, ordinance, and circulars in one Excel file⁴. METI lists five cautions for using it. Three matter most in my experience.

First, one product can sit under more than one item. METI's own example is machine tools, controlled under Item 2 (nuclear) and Item 6 (conventional). Search the whole table instead of scanning by eye⁴. Second, parts and accessories can be controlled too. The law says things like "pumps or parts thereof," so identify what a part belongs to and search on that parent product⁴. Third, legal names differ from everyday names. GPS appears as "equipment that receives radio waves from satellite navigation systems"⁴. A miss on the catalog name does not mean "not controlled."

Finally, where to read the current text. The authoritative version is the Japanese original on e-Gov, which shows the effective date of the version you are reading. As of October 4, 2026, the current version took effect on June 5, 2026. That June change (Cabinet Order No. 194 of 2026) only fixed cross-references after FEFTA's penalty articles were renumbered; the contents of Appended Table 1 last changed on February 14, 2026³¹². The Matrix Table on METI's site is the version for February 14, 2026⁴. One trap for non-Japanese teams: the official English translation, published as the "Cabinet Order on Export Trade Control" in the Ministry of Justice's Japanese Law Translation database, reflects amendments only through Cabinet Order No. 164 of 2023¹³. It predates the October 2025 catch-all overhaul and both list amendments described above. Use it to understand the structure, never to classify. For a walkthrough of actually searching the Matrix Table, see how to use METI's Matrix Table.

Item 16 catch-all: the triggers change with the destination

METI describes Japan's system as two pillars: list controls and catch-all (complementary) controls¹⁴. Inside Appended Table 1, that means Items 1–15 versus Item 16.

List controls are Items 1–15. Sensitive goods are listed in advance, and if your item is on the list you need a license in principle regardless of destination. The lower column for every one of Items 1–15 reads "all regions"³.

The catch-all works the other way around. Even goods that are not on the list need a license if there is a risk they will be used to develop weapons of mass destruction or conventional weapons. Item 16 is that net, and its middle column has two parts. Part (1) names specific product groups: machine tools, radar and radio navigation equipment, integrated circuits, aircraft and spacecraft with parts, navigation instruments, and analytical and measuring instruments. Part (2) sweeps in goods under Customs Tariff Act chapters 25–40, 54–59, 63, 68–93, and 95, excluding Part (1) and Items 1–15¹¹. METI's own plain-language summary is "all goods except food, wood, and the like"¹⁴. "We are not on the control list, so export control does not apply" is almost never a safe line for a company.

When Item 16 actually requires a license depends on the destination and on whether the goods fall in Part (1) or Part (2). The overhaul effective October 9, 2025 (Cabinet Order No. 175 of 2025) split Item 16 this way, with Part (1) items identified by HS codes under Article 14-2 of the ordinance¹⁴¹⁵. Reading Article 4 of the Export Order, the result looks like this¹⁶:

Destination group	Item 16(1) specified items	Item 16(2) everything else
Group A (27 countries in Appended Table 3)	No objective requirement. A license is needed only after an inform notice citing diversion risk	Same
UN arms embargo destinations (10 in Appended Table 3-2)	Objective and inform requirements for both WMD and conventional weapons	Same
All other destinations	Objective and inform requirements for both WMD and conventional weapons	WMD: objective and inform requirements. Conventional weapons: inform requirement only

The objective requirement means the exporter needs a license when its own end-use and end-user checks reveal a risk of weapons use. The inform requirement means a license is needed once METI sends a written notice telling the exporter to apply¹⁴. WMD here means nuclear weapons, military chemical and biological agents, their dispersal devices, and rockets and UAVs that can carry them 300 km or more, including parts. Conventional weapons means goods in Item 1 of Appended Table 1¹⁴.

Group A is the set of 27 destinations with mature export control systems listed in Appended Table 3, including the United States, the United Kingdom, Germany, France, South Korea, Australia, Canada, and Argentina¹⁷. Item 16's lower column reads "all regions except those in Appended Table 3," so Group A sits outside Item 16 by default¹¹. Since October 9, 2025, though, Article 1(3) of the Export Order has allowed METI to require a license under FEFTA Article 48(2) for Item 16 goods bound for Group A². METI says the inform requirement for Group A applies only where there is a risk of diversion to countries of concern¹⁴. My first version of this article left that out, so I have spelled it out here. For a U.S. buyer, the practical point is simple: a shipment from Japan to the United States is usually outside the catch-all, but your Japanese supplier can still be told to apply for a license if METI sees a diversion risk in the deal. For the destination groups themselves, see Japan's Group A to D country groups; for how the two pillars fit together, see list controls and catch-all controls.

Six confusions non-Japanese teams hit first

Several tables and regimes around Appended Table 1 have similar names. These are the mix-ups I hear about most often.

1. Appended Table 1 versus Appended Table 2. Same Export Order, different worlds. Table 1 defines security-related export licenses under FEFTA Article 48(1). Table 2 defines export approvals under Article 2 of the Export Order for other policy aims, such as CITES-listed species and measures concerning North Korea, Russia, and Belarus¹⁸. When Japanese colleagues say betsu-1 and betsu-2, they are not synonyms. See Appended Table 2 and export approvals.

2. Appended Table 1 versus the Foreign Exchange Order table. Table 1 covers physical goods. Technology, meaning drawings, software, and technical instruction, falls under FEFTA Article 25 and the table attached to the Foreign Exchange Order (Cabinet Order No. 260 of 1980). Its Items 1–15 read as technology for the design, manufacture, or use of the goods in the matching item of Appended Table 1, and the numbering lines up through Item 16¹⁹. Goods and technology enter through different doors. The technology side is covered in service transactions and technology transfers.

3. "Not list-controlled" is not "unregulated." Goods outside Items 1–15 often still sit inside Item 16. When a customer asks for a non-applicability certificate, naming the items you checked and how Item 16 was treated is far more credible than a bare "N/A." See how to write non-applicability certificates.

4. Counting the rows. Item 3-2 means "Items 1–16" is not 16 rows³. Internal checklists that drop biological weapons because of a bad count are a real failure mode. Sub-numbered items are normal in Japanese legal drafting, and they still catch people out. I missed 3-2 myself the first time I read the table straight through.

5. Classifying by HS code or product name. HS codes are customs classifications. Items 1–15 are not organized by HS code, and two products under the same HS code can land on opposite sides of a threshold. HS codes do identify the specified items in Item 16(1), but that is the catch-all, not the list¹⁴.

6. Relying on the supplier's classification as is. METI asks exporters of purchased goods to check that the model matches, that the reasoning holds up, and that the latest law was used. If a manufacturer's classification is wrong and a controlled item ships as "not controlled," FEFTA liability falls on the exporter⁴. That applies to your Japanese subsidiary, too, when it exports parts it bought from local suppliers.

What changed since the first version (July 2026)

I first published this guide on July 7, 2026. About three months later, the contents of Appended Table 1 have not moved, but a few things around it have, and the first version missed one point. Here is the side-by-side.

Topic	First version (July 7, 2026)	Now (checked October 4, 2026)
Current e-Gov version	Version effective June 5, 2026	Same. The June 5 change only fixed cross-references; the contents of Appended Table 1 last changed on February 14, 202612
FEFTA amendment	Not mentioned	An amending act (Act No. 30 of 2026) was promulgated on June 5, 2026 and partly took effect that day. It changed inward investment and penalty provisions; Article 48 on export licenses is unchanged. The rest takes effect on January 4, 20271
Item 16 and Group A	Said only that the objective requirement does not apply	Since October 9, 2025, METI can require a license by inform notice where diversion is a risk (Export Order Article 1(3))214
Matrix Table	Version for February 14, 2026	Same. METI's page was last updated February 18, 20264
Penalties for unlicensed export	Not mentioned	FEFTA Articles 69-7 and 72. The June 5 amendment shifted the article number from 69-61

On the FEFTA amendment, I compared the article text before and after on e-Gov and confirmed that Article 48 (export licenses) and Article 25 (technology transfers) did not change¹. In other words, nothing since July requires you to redo an Appended Table 1 classification.

The next change will come, though. METI says list-controlled items are, in principle, amended every year⁴. The fiscal 2025 regular amendment was promulgated on November 14, 2025, and its list changes took effect three months later, on February 14, 2026²⁰¹². As of October 4, 2026, the news section of METI's security export control page did not yet show a cabinet decision on the next regular amendment. When it is promulgated, list your controlled products and anything you classified as "not controlled" near the amended items, before the effective date. For the most recent amendment, see the February 2026 Export Trade Control Order amendment; for semiconductors, Japan's semiconductor export control items.

Classification in practice, and what happens when an item is controlled

Stage 1, specs. Collect model numbers, performance figures, materials, and intended uses from engineering. Vague specs turn everything downstream into guesswork.

Stage 2, candidate items. Scan Items 1–15 of Appended Table 1. The table above is the entry map.

Stage 3, parameter match. Use the Matrix Table and the ordinance to compare control thresholds with your actual numbers. Multi-item hits are common, so search across the table even after one "not controlled" result⁴.

Stage 4, record and sign-off. Write a classification report with the result and its basis, and have the responsible officer approve it. Only then is one product done.

Templates for the paperwork. We publish a Japanese-language set of classification and non-applicability certificate forms with a fill-in Q&A (Word), plus Excel sheets such as a catch-all check sheet and a classification log. It reflects the amendments effective February 14, 2026. Download the classification template pack (free; company name and work email required).

If the answer is "controlled," the exporter needs a METI license before shipping. Japan offers individual licenses for each deal and bulk (comprehensive) licenses that cover a defined range; individual versus bulk licenses explains the choice. There is also a small-value exception. Goods under Items 5–13 and 15 with a total value of JPY 1 million or less (JPY 50,000 for goods listed in Appended Table 3-3) need no license when they are not going to Iran, Iraq, or North Korea and no catch-all condition applies. It does not cover Items 1–4 or 14¹⁶. The details are in Japan's small-value and free-of-charge exceptions.

The penalties are serious. Under FEFTA Article 69-7, an individual who exports controlled goods without a license faces up to 7 years' imprisonment, a fine of up to JPY 20 million (or up to five times the value of the goods if that is higher), or both. For goods with a particularly high risk of WMD use, the ceiling rises to 10 years or JPY 30 million. Under Article 72, a company faces fines of up to JPY 700 million, or JPY 1 billion for those higher-risk goods, again with the five-times-value rule. Article 53 also lets METI ban the violator from exporting for up to three years¹.

It sounds clean on paper. In practice, portfolios with hundreds or thousands of SKUs, plus annual amendments, turn classification into a continuous program rather than a project. When the person who did the classifications rotates out, undocumented reasoning walks out with them. Most of the organizational pain I see comes back to that missing continuous mechanism.

That is the problem we built TRAFEED for. It is an AI agent for export control that does first-pass Japan export classification against Appended Table 1 and the Foreign Exchange Order table and keeps the evidence on file. The classification logic is covered by Japan Patent No. 7862062, and more than 20 organizations use the product today. One line we do not blur: the AI speeds up research and evidence gathering, and your export control officer makes the final call.

Appended Table 1 is manageable once you hold four ideas: the middle and lower columns, 17 rows, the split between cabinet order and ordinance, and an Item 16 that behaves differently by destination. If I had to pick one next step for a non-Japanese team, it would be this: take one flagship product that is made in Japan or ships through Japan, sit down with a bilingual colleague, and run it against the Matrix Table. Doing it by hand makes the map three-dimensional. For an overview of the product, download the TRAFEED product catalog (PDF). For questions about designing the process, book a consultation.

References

Footnotes

1. Foreign Exchange and Foreign Trade Act (Act No. 228 of 1949), Articles 25, 48, 53, 69-7, and 72, and amendment history (Act No. 30 of 2026) — e-Gov — checked October 4, 2026 (Japanese) ↩ ↩² ↩³ ↩⁴ ↩⁵

2. Export Trade Control Order (Cabinet Order No. 378 of 1949), Article 1, paragraphs 1–4 — e-Gov — checked October 4, 2026 (Japanese) ↩ ↩² ↩³

3. Export Trade Control Order, Appended Table 1 (middle and lower columns, item structure) — e-Gov Legal Database (Digital Agency) — version effective June 5, 2026, checked October 4, 2026 (Japanese) ↩ ↩² ↩³ ↩⁴ ↩⁵

4. Classification and the Goods/Technologies Matrix Table — METI — page last updated February 18, 2026, checked October 4, 2026 (Japanese) ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸ ↩⁹ ↩¹⁰

5. Security Export Control (contact notes and news) — METI — page last updated July 30, 2026, checked October 4, 2026 (Japanese) ↩

6. Goods and Technologies Ministerial Ordinance (MITI Ordinance No. 49 of 1991) — e-Gov — version effective February 14, 2026 (Japanese) ↩ ↩²

7. Overview of Security Export Control (mapping of list-control items to the international regimes) — Center for Information on Security Trade Control (CISTEC) — checked October 4, 2026 (Japanese) ↩

8. Export Trade Control Order, Appended Table 1, Item 1 (arms) — e-Gov (Japanese) ↩ ↩² ↩³

9. Export Trade Control Order, Appended Table 1, Items 2–4 — e-Gov (Japanese) ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶

10. Export Trade Control Order, Appended Table 1, Items 5–15 — e-Gov (Japanese) ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸ ↩⁹ ↩¹⁰ ↩¹¹ ↩¹² ↩¹³

11. Export Trade Control Order, Appended Table 1, Item 16 — e-Gov (Japanese) ↩ ↩² ↩³ ↩⁴

12. Export Trade Control Order, amendment history and supplementary provisions (Cabinet Order No. 102 of 2025: promulgated March 28, effective May 28, 2025; No. 175 of 2025: April 9, effective October 9, 2025; No. 376 of 2025: November 14, list changes effective February 14, 2026; No. 194 of 2026: effective June 5, 2026) — e-Gov — versions compared by TIMEWELL, checked October 4, 2026 (Japanese) ↩ ↩² ↩³ ↩⁴

13. Cabinet Order on Export Trade Control (English translation; last version reflected: Cabinet Order No. 164 of 2023) — Japanese Law Translation (Ministry of Justice) — checked October 4, 2026 ↩

14. Complementary Export Controls (Catch-All) — METI — page last updated December 23, 2025, checked October 4, 2026 (Japanese) ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸

15. Revision of Complementary Export Controls (effective October 9, 2025) — METI — page last updated April 15, 2026, checked October 4, 2026 (Japanese) ↩

16. Export Trade Control Order, Article 4 (special provisions), paragraph 1, items 3–5 and paragraph 2 — e-Gov — checked October 4, 2026 (Japanese) ↩ ↩²

17. Export Trade Control Order, Appended Table 3 (27 countries), Appended Table 3-2 (10 destinations), Appended Table 4 — e-Gov — checked October 4, 2026 (Japanese) ↩

18. Export Trade Control Order, Article 2 and Appended Table 2 — e-Gov (Japanese) ↩

19. Foreign Exchange Order (Cabinet Order No. 260 of 1980), Appended Table — e-Gov — checked October 4, 2026 (Japanese) ↩

20. Commentary on the FY2025 Regular List Amendments — CISTEC Secretariat — November 18, 2025 (Japanese) ↩