What Is Appended Table 2 of the Export Trade Control Order? Items Requiring Export Approval, from Primary Sources [2026 Edition]

Hello, this is Ryuta Hamamoto from TIMEWELL. When I take export control questions, one thing goes missing far more often than you would expect: Appended Table 2 of the Export Trade Control Order. Most companies pour real attention into the classification of Appended Table 1 — the so-called list controls. And then, reassured, they ship. Only to be tripped up by a leather product that touches CITES, by hazardous waste, or by a rough diamond. Even goods that appear nowhere in Appended Table 1 cannot be exported without the approval of the Minister of Economy, Trade and Industry if they are listed in Appended Table 2. And the penalties for exporting without that approval are anything but light.

In this article, I lay out what Appended Table 2 is, which items require approval, and why approval is demanded — all built on the statutory text from e-Gov and primary sources from METI and Japan Customs. By the time you finish, you should have a firm, gut-level sense of why an Appended Table 1 classification alone never completes export control.

What Appended Table 2 Is, and How "Approval" Differs from "License"

The Export Trade Control Order (Cabinet Order No. 378 of 1949) contains two important tables: Appended Table 1 and Appended Table 2. Because the names are so similar, the two are easily confused — yet their governing provisions and their purposes are completely different. Mistake one for the other and the very design of your export control breaks down.

Appended Table 1 is the list of items requiring an export license. Its basis is Article 48(1) of the Foreign Exchange and Foreign Trade Act (Act No. 228 of 1949, hereinafter "FEFTA") and Article 1 of the Export Order¹. It regulates sensitive goods that could be diverted to weapons or weapons of mass destruction, from the standpoint of maintaining international peace and security. The judgment is made on specifications — the numerical values of performance and configuration — which is why this is the main battleground of what is called classification. For the full picture of Appended Table 1, our complete guide to Appended Table 1 of the Export Order goes into detail, and reading both together gives you a more three-dimensional grasp.

Appended Table 2, in contrast, is the list of items requiring export approval. Its basis is FEFTA Article 48(3) and Article 2(1) of the Export Order²¹. Article 48(3) provides that an approval obligation may be imposed in order to faithfully implement treaties and other international agreements Japan has concluded, to maintain the balance of international payments, to secure the sound development of foreign trade and the national economy, and to contribute as a nation to international efforts for peace. The aim is fundamentally different from the security-based list controls. If you want to settle, once and for all, the difference between the words "license" and "approval" themselves, reading how export "license" and "approval" differ first will make everything that follows far easier.

The difference between the two, distilled onto a single page, looks like this.

Comparison item	Export Order Appended Table 1 (export license)	Export Order Appended Table 2 (export approval)
Required procedure	Export license (METI)	Export approval (METI)
FEFTA basis	Article 48(1)	Article 48(3)
Export Order basis	Article 1	Article 2(1)
Purpose of control	Maintaining international peace and security (security / list controls)	Faithful implementation of treaties, sound development of the national economy, balance of international payments, contribution to international peace
Main targets	Weapons, WMD-related goods, sensitive dual-use goods	CITES processed animal/plant products, rough diamonds, hazardous waste, ozone-depleting substances, fishing vessels, consignment processing trade, etc.
Basis of judgment	Classification by specification	Item, destination, treaty applicability
Penalty for no license / approval	FEFTA Article 69-7 (license) and others (up to 7 years' imprisonment, etc.)	FEFTA Article 69-8(1)(iv) (up to 5 years' imprisonment or a fine of up to 10 million yen, or five times the value)

The crucial point is that these two operate independently. The fact that an item is non-controlled under Appended Table 1 does not mean you are free to export it. Whether it is subject to approval under Appended Table 2 must be checked against a separate yardstick. If you are unsure whether your own export control framework can handle this two-tier structure, I recommend first measuring where you stand with our free export-control readiness check.

Why Approval Is Required: A System to Protect Treaties, the Environment, Hygiene, and Industry

The shortest path to understanding the Appended Table 2 approval regime is to accept one thing outright: this is not a security control. Security is the job of Appended Table 1. What Appended Table 2 seeks to protect is a different set of interests — faithful implementation of treaties, the global environment, domestic industry and public health and quarantine, and contribution to international peace. That is precisely why endangered species, fluorocarbon gases, and hazardous waste all coexist in the single table that is Appended Table 2. If the group of items looks disconnected at first glance, it is because the thread that binds them at the root is "social requirements other than security."

The current Appended Table 2 can be confirmed on e-Gov in the edition effective June 5, 2026 (as amended by Cabinet Order No. 194 of 2026)². Below are the main approval-target items, arranged by character. You will notice some unfamiliar numbering along the way — I will explain that shortly.

Item No.	Main approval target (character)	Examples
1	International framework (Kimberley Process)	Diamonds (as specified by notification)
19	Hygiene / health	Blood products
20 / 21 / 21-2	Nuclear-related / radioactive materials	Nuclear source material and nuclear fuel material (including spent fuel), radioactive waste, radioisotopes
21-3	Drug control	Chemicals such as narcotic and psychotropic precursors
25	Domestic industry / resource management	Fishing vessels equipped with fishing gear, etc.
30	Agriculture, forestry, and fisheries (consent required)	Shiitake spawn
34	Hygiene / resources	Frozen clams, hard clams, and mussels
35	Environment (Montreal Protocol)	Ozone-depleting substances (Annexes A, B, C, E)
35-2 to 35-5	Environmental treaties	Specified hazardous waste, etc. (Basel Convention), Rotterdam Convention items, mercury under the Minamata Convention, carbon dioxide for ocean disposal
36 / 37	Biodiversity	CITES animals, plants, and derivatives; endangered species under the Act on Conservation of Endangered Species
38	Biodiversity	Mist nets
39 / 40 / 41	Public order / morals	Counterfeit currency and the like, publications inciting rebellion, publications likely to harm public morals
43	Cultural property protection	National treasures, important cultural properties, important art objects, etc.
44 / 45	Intellectual property / customs	Goods infringing intellectual property rights of the destination country, goods subject to certification procedures under the Customs Act

Here is where beginners are invariably thrown off: the gaps in the numbering. Many entries — Items 2 through 18, 22 through 24, 26 through 29, 31 through 33, and 42 in Appended Table 2 — currently read "deleted." These are the traces of items once regulated but since removed as treaties lapsed or policy shifted. That is why the assumption "an old explainer listed it in Appended Table 2, so approval must still be required" leads straight to error. If you come across information that still describes items like rice or whales as belonging to Appended Table 2, do not take it on faith: always confirm the current listing against the latest text on e-Gov and METI's list of goods subject to export approval³. The statute is a living thing. It is not unusual for the same number to have been swapped out, or emptied entirely, from what it once contained.

Note, too, that some items require not only the Minister of Economy, Trade and Industry's approval but also the consent of the Minister of Agriculture, Forestry and Fisheries — shiitake spawn is one such case (Article 2(2) of the Export Order) — while others, such as national treasures, require a license or confirmation under another law as a precondition for approval (Article 2(3) of the same Order)². Keeping in mind that some items are not handled by METI alone will spare you a scramble in practice.

Common Approval Cases in the Field: Diamonds, CITES, Hazardous Waste, Consignment Processing

Staring at the item list alone rarely makes it click, so let me pin down the specifics with four cases I am asked about most. Each is a pattern that catches out companies convinced that "we don't handle weapons, so export control has nothing to do with us."

First, rough diamonds. These fall under Item 1 of Appended Table 2, and export requires a Kimberley Process certificate in addition to the approval document⁴. The Kimberley Process is an international certification scheme designed to keep so-called conflict diamonds — those mined in conflict zones and funding armed groups — out of legitimate circulation. Even for polishing or industrial uses rather than jewelry, this framework kicks in as long as the stones are rough.

Next, the Washington Convention (CITES). This is Item 36 of Appended Table 2: animals and plants of species listed in Appendix I or Appendix II, parts of individual specimens, eggs and seeds, taxidermy, processed products, and other derivatives — among these, the ones designated by notification of the Minister of Economy, Trade and Industry are covered²⁵. The trap here is assuming that only live animals and plants are regulated. CITES is administered on a three-tier basis: Appendix I is in principle prohibited for commercial trade, Appendix II requires an export permit from the exporting country, and Appendix III requires an export permit or a certificate of origin⁶⁷. A leather handbag or belt, an ivory product, or an accessory made from reptile skin can become subject to approval depending on the origin of the material. Consider that merely shipping your own brand's leather goods to an overseas customer can touch the regulation, and the relevance hits close to home. Incidentally, endangered species under the domestic Act on Conservation of Endangered Species of Wild Fauna and Flora (Act No. 75 of 1992) are provided for separately from Item 36, as Item 37 of Appended Table 2. It is a structure in which an international treaty and a domestic law take effect in a doubled-up way through separate item numbers.

Third, hazardous waste. This is Item 35-2 of Appended Table 2, linked to the Basel Convention and the Act on the Control of Export, Import and Others of Specified Hazardous Wastes and Other Wastes (Act No. 108 of 1992)². Transactions that send used electronic boards, metal scrap, or spent batteries abroad as resources are on the rise, but depending on the hazard assessment, approval can be required. It is a textbook case of a recycling effort turning into a regulatory violation, and it is an area you can also verify against Japan Customs' list of other laws and regulations related to export⁸.

Fourth is consignment processing trade. This one is a little different in flavor from the item tables — its basis is Article 2(1)(ii) of the Export Order². Among consignment processing trade contracts that outsource processing abroad, those falling under the designated processing specified by the Minister of Economy, Trade and Industry require approval at the point when the raw materials for processing are exported. The typical example is sending raw materials such as leather, fur, and leather goods to overseas factories to be processed into shoes, bags, or leather clothing, and then re-importing them⁹. From the standpoint of protecting domestic industry, the target raw materials are defined in fine detail for each category of designated processing. It takes a shift in thinking — approval is required not on the side that imports the product but on the side that exports the raw materials — which is exactly where first-timers tend to stumble.

Approval Decided by Destination, Not Item: Sanctions Deserve Special Attention

Everything so far has been about item-based criteria, where the need for approval turns on "what you ship." But Appended Table 2 also contains entries that impose approval broadly on a destination basis — "where you ship it." This is the area with the most movement in recent years, and the one where oversights are least forgivable in practice.

Controls on exports to North Korea sit in Appended Table 2, item 2, with Article 2(1)(i)-2 of the Export Order as the basis². As part of sanctions, an approval obligation is imposed on exports of specified goods to North Korea. Further, controls on exports to Russia, Belarus, and Ukraine (parts of Donetsk and Luhansk provinces) sit in Appended Table 2, items 3 and 4, corresponding to Article 2(1)(i)-3 through (i)-8 of the Export Order². The specific goods covered here are defined by instruments such as the Ministerial Ordinance Specifying Goods under Appended Table 2-3 of the Export Trade Control Order¹⁰, and amendments continue in step with the international situation.

The danger of these destination-based criteria is that the scope of covered goods expands as sanctions progress. An item that required no approval yesterday can, by tomorrow, become subject to approval through a ministerial ordinance amendment — and that really happens. Rather than checking the item list once and feeling safe, you need an operating practice of cross-referencing the destination against the latest ordinance in force at that moment. Because the specific scope of Russia-related sanctioned goods is amended frequently, confirm the latest version as of the date of publication each time you transact. In this article I have verified the structure down to the statutory text from primary sources, and I will be honest that I have not tracked the individual item lists at the notification and ordinance level.

The Approval Procedure, and the Penalties for Exporting Without Approval

The procedure for applying for export approval is set out in the Export Trade Control Regulations (Ministry of International Trade and Industry Ordinance No. 64 of December 1, 1949)¹¹. In practice, there is a distinction between individual approval, applied for on a per-transaction basis, and comprehensive (blanket) approval, obtained under certain conditions. Which one you should use varies with the item, the destination, and the frequency of transactions, so you choose according to the reality of your own dealings. I will not exhaust every detail of the regime here, but do keep one thing in mind: approval has a validity period, and if the content of the transaction changes, you will need to obtain it again.

And now the heart of the matter — the penalties. Some people carry the sense that approval is lighter than a license, so being a little loose about it is fine. That is a dangerous misunderstanding. If you export goods falling under Appended Table 2 without approval, Article 69-8(1)(iv) of FEFTA imposes up to five years' imprisonment, a fine of up to 10 million yen, or both¹. When five times the value of the goods exceeds 10 million yen, the fine jumps up to as much as five times that value. For high-value goods, that means the fine alone can reach a level that threatens the survival of the business.

It is not only criminal penalties. Under Article 53(2) of FEFTA, an administrative sanction of up to three years' prohibition on exporting and importing may be imposed for violations of the approval obligation and the like¹. If exporting and importing themselves are halted, that is a blow tantamount to a de facto suspension of business for the exporting company. For reference, export without a license — a violation of the Appended Table 1 list controls — is set even heavier under FEFTA Article 69-7, at up to seven years' imprisonment, but it is fair to understand approval violations as coming right behind it in gravity. However different the entry procedures for a license and an approval may be, in my experience there is no great difference in the compliance weight they carry.

Don't Stop at the Appended Table 1 Classification: The Practical Verification Flow and TRAFEED

If you have read this far, I hope it has come across just how precarious it is to finish export control with the Appended Table 1 classification alone. In practice, you want to build the habit of checking in at least the following order. First, does it fall under the Appended Table 1 list controls? If non-controlled, check catch-all controls (the concern of diversion to weapons of mass destruction or conventional weapons). On top of that, is it subject to approval under Appended Table 2? Further, is the destination a sanctions target? And in addition, does it touch other laws such as the Washington Convention, the Act on Protection of Cultural Properties, or the Customs Act? Only after passing through all five of these are you in a position to say the goods may be exported. Stop at Appended Table 1 and you overlook the remaining four wholesale.

That said, running all of these checks by hand — while keeping up with the latest edition every time there is an amendment — is, realistically, a considerable burden. This is where our export control AI agent, TRAFEED (formerly ZEROCK ExCHECK), earns its keep. Built around classification aligned with METI's standards, TRAFEED also covers transaction-partner screening and the reflection of each country's laws and regulations. In a joint proof-of-concept with Okayama University, it confirmed AI classification accuracy of 95% or higher based on roughly 30,000 records of past review data (internal study). Because it is operated to reflect changes in each country's laws and regulations on the same day, even in areas that are amended frequently — like the sanctions-related controls above — it is easier to check against the latest state. It is the world's first AI agent in the field of Japan's security export control (as of March 2026, internal study). Of course, the final classification and the decision on whether approval is required should be made by your company's export control officer. Think of TRAFEED as a tool to support that decision — faster, and with no gaps. The detailed features of the product are set out on the TRAFEED service page.

Appended Table 2 is one of the quieter corners of export control, and for that very reason one of the easiest to miss. Because ordinary leather goods or used equipment — nothing like weapons or advanced technology — can become subject to approval, not knowing about it leads to accidents. Start by taking stock of the items you handle and their destinations, and building the existence of Appended Table 2, which lives behind Appended Table 1, into your management flow. Begin there. If you are unsure whether your own case falls subject to approval, or you would like to talk through building a framework from scratch, reach out through our individual export control consultation (TRAFEED) and we will organize things together to fit your specific situation.

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References and Primary Sources

Footnotes

1. Foreign Exchange and Foreign Trade Act (e-Gov Law Search, Act No. 228 of 1949; Articles 48, 53, and 69-8) https://laws.e-gov.go.jp/law/324AC0000000228/ ↩ ↩² ↩³ ↩⁴

2. Export Trade Control Order (e-Gov Law Search, Cabinet Order No. 378 of 1949; edition effective June 5, 2026 / as amended by Cabinet Order No. 194 of 2026) https://laws.e-gov.go.jp/law/324CO0000000378/ ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸

3. List of Goods Subject to Export Approval (METI) https://www.meti.go.jp/policy/external_economy/trade_control/04_kamotsu/01_export/export_kamotsu.html ↩

4. Export of Rough Diamonds (Kimberley Process) (METI) https://www.meti.go.jp/policy/external_economy/trade_control/02_exandim/05_diamond/kimberley_ex.html ↩

5. About the Washington Convention (METI) https://www.meti.go.jp/policy/external_economy/trade_control/02_exandim/06_washington/cites_about.html ↩

6. Washington Convention (Japan Customs) https://www.customs.go.jp/tetsuzuki/washington/topcontents_jr.htm ↩

7. Import and Export Regulations under the Washington Convention: Japan (JETRO Trade and Investment Q&A) https://www.jetro.go.jp/world/qa/04A-010911.html ↩

8. List of Other Laws and Regulations Related to Export (Japan Customs) https://www.customs.go.jp/yusyutu/2021_1/data/export.htm ↩

9. Consignment Processing Trade (leather, fur, leather goods, etc.) (METI) https://www.meti.go.jp/policy/external_economy/trade_control/02_export/16_itaku/index.html ↩

10. Ministerial Ordinance Specifying Goods under Appended Table 2-3 of the Export Trade Control Order (e-Gov Law Search) https://laws.e-gov.go.jp/document?lawid=504M60000400015 ↩

11. Export Trade Control Regulations (Ministry of International Trade and Industry Ordinance No. 64 of December 1, 1949 / Japanese Law Index, National Diet Library) https://hourei.ndl.go.jp/simple/detail?lawId=0000041858&current=-1 ↩