China's Dual-Use Export Control List and Watch List — Full 80 Japanese Entity Names for Counterparty Screening [June 29, 2026 Update]

Hello, this is Ryuta Hamamoto from TIMEWELL.

If you run counterparty screening for dual-use goods, China's Ministry of Commerce (MOFCOM) lists are no longer a Japan-only story. As of July 2026, 80 Japanese companies and organizations sit on MOFCOM's dual-use Export Control List (effectively a ban) and Watch List (strict individual licensing). The first wave, effective February 24, 2026, named 40 entities. The second wave, effective June 29, 2026, named 40 more.

News headlines usually stop at "Mitsubishi Electric affiliates" or "20 defense-related firms." That is useless when you need to match a purchase order, a ship-to, or a parent–subsidiary chain against your master data. This page compiles all 80 official names from the primary MOFCOM notices and the CISTEC provisional translations, then explains how the two lists differ, how the re-export (extraterritorial) rule reaches transactions outside China, and what global compliance teams—not only Japanese exporters—should do next.

Listing is a regulatory classification under Chinese law. It is not a finding that any named company engaged in improper trade or military diversion. Many listed parties are legitimate civilian manufacturers that fall inside a broadly drawn dual-use category. Treat the roster as a screening input, not a moral scorecard.

If you want a quick read on whether your export-control program can absorb list expansion at this pace, take the free export-control readiness check before you dig into the action list below.

Transaction screening sheet (fill-in): The 80 names are on this page. What practice needs next is a repeatable decision trail for each deal. Our China-Related Transactions Export-Control Screening Sheet walks through China's Export Control Law and Dual-Use Items Regulations, critical-mineral announcements, the four counterparty systems (Control List, Watch List, Unreliable Entity List, countermeasure lists), and Japan-side classification—six A4 pages, one transaction at a time. A completed sheet can attach to an internal approval or a counterparty response. → Download the China transaction screening sheet (Free. Company name and work email required.)

Why U.S. and Global Exporters Should Screen These Names

Three practical reasons, even if your company is not Japanese and never ships from Japan.

1. The control follows Chinese-origin dual-use items. Notices No. 11 and No. 27 do not only bind Chinese exporters. They bar organizations and individuals outside China from transferring or supplying Chinese-origin dual-use items to listed entities¹². A U.S. warehouse, a Singapore hub, or an EU OEM can sit in that path.

2. "Domestic" transfers still count. CISTEC has cautioned that even a transfer between two parties inside Japan can be treated as a covered "domestic transfer" when Chinese-origin dual-use items move to a listed company³. Swap Japan for any third country with Chinese-origin stock on the shelf and the same logic applies under the Chinese text.

3. Names multiply across languages and legal entities. Chinese character renderings, informal English nicknames, and formal corporate names diverge. "Mitsubishi Heavy Industries Oceanics" in a news article is officially MHI Oceanics Co., Ltd. (エムエイチアイオーシャニクス株式会社). Screening that only hits the parent brand will miss subsidiaries.

Put bluntly: if Chinese dual-use content can reach a listed end user through you, your compliance program owns the problem. For the broader legal architecture, see China's Export Control Law system: complete guide. For the rare-earth layer that sits behind many of these designations, see the China rare earth export control map.

The Big Picture: Four MOFCOM Notices at a Glance

The Japan-related dual-use measures sit in four MOFCOM notices, each effective on the date of promulgation.

Notice	Published (effective)	List	Added	Notable names
Notice 2026 No. 112	February 24, 2026	Export Control List (export ban)	20 entities	MHI Shipbuilding, Kawasaki Heavy group, IHI group, NEC group, National Defense Academy, JAXA
Notice 2026 No. 124	February 24, 2026	Watch List (strict review)	20 companies	SUBARU, ENEOS, TDK, Mitsubishi Materials, Institute of Science Tokyo
Notice 2026 No. 271	June 29, 2026	Export Control List (export ban)	20 entities	Four MOD research institutes led by the National Institute for Defense Studies; defense subsidiaries of Mitsubishi Electric and MHI
Notice 2026 No. 285	June 29, 2026	Watch List (strict review)	20 companies	MITSUI E&S, Terra Drone, ACSL, Mitsubishi Nuclear Fuel, Japan Nuclear Fuel, Komatsu Industries

The two lists sound similar. The operational weight is not.

Aspect	Export Control List	Watch List
Legal basis	Articles 28 and 29 of the Dual-Use Items Regulations6	Article 26 of the same Regulations6
Whether exports are allowed	Dual-use items prohibited in principle	Not prohibited, but procedures tightened
General license and registration filing	Cannot be used (exports banned outright)	Cannot be used (individual license only)
Re-export rule (extraterritorial reach)	Yes; supply of Chinese-origin items by parties outside China also prohibited	Not specified in the same form
Ongoing transactions	Immediate suspension	No automatic suspension provision
Additional documents	Individual application under special circumstances only	Risk assessment report and pledge of non-diversion to military use
License review deadline	Not applicable; exports banned	Exempt from the 45-day deadline in Article 17 of the Regulations
Stated reason for listing	Involvement in enhancing Japan's military capabilities	End user and end use cannot be confirmed

In plain English: the Control List says do not ship. The Watch List says if you ship, accept heavier process, documentation, and timeline risk. Before you size the matching workload, glance at the TRAFEED product catalog (PDF)—whether you automate screening changes the estimate.

Names below follow the official renderings in CISTEC's provisional translations of the notice attachments³⁷.

[Second Wave] The 40 Entities Added on June 29, 2026

The 20 Entities Added to the Export Control List (Notice 2026 No. 27)

These are subject to the export ban. Four research institutes under Japan's Ministry of Defense head the list; defense subsidiaries of Mitsubishi Electric and Mitsubishi Heavy Industries make up most of the rest¹.

No.	Entity
1	National Institute for Defense Studies
2	Ground Systems Research Center
3	Naval Systems Research Center
4	Air Systems Research Center
5	NIKKO TOKKI Co., Ltd.
6	NIKKO-YPK SHOJI Co., Ltd.
7	Mitsubishi Electric Defense and Space Technologies Corporation
8	Mitsubishi Electric Software Corporation
9	Mitsubishi Electric Engineering Company, Limited
10	Mitsubishi Precision Company, Limited
11	MHI Oceanics Co., Ltd.
12	MHI Sagami High-tech, Ltd.
13	MHI Logitec Co., Ltd.
14	KOWA KOGYO, Ltd.
15	MHI Special Vehicles Parts Supply & Technical Service Co., Ltd.
16	MHI Maritech, Co., Ltd.
17	Kawajyu Gifu Manufacturing Co., Ltd.
18	NIPPI Corporation
19	Fortunio Co., Ltd.
20	Aoki Seimitsu Kogyo Co., Ltd.

The Chinese original uses Chinese characters for these names. MHI Oceanics appears as 三菱重工海洋技术; Kawajyu Gifu Manufacturing is known in Japan as 株式会社ケージーエム. Names shift across four layers—official Japanese name, informal name, English name, Chinese rendering. A system that matches only one layer will miss hits.

The 20 Companies Added to the Watch List (Notice 2026 No. 28)

These are subject to strict case-by-case review. The stated reason is that end user and end use of dual-use items cannot be confirmed⁵.

No.	Company
1	MITSUI E&S Co., Ltd.
2	Mitsui Bussan Aerospace Co., Ltd. Maintenance Center
3	Terra Drone Corporation
4	ACSL Ltd.
5	Mitsubishi Nuclear Fuel Co., Ltd.
6	Japan Nuclear Fuel Limited
7	Fujitsu Network Solutions Limited
8	Hitachi Advanced Systems Corporation
9	Komatsu Industries Corporation
10	Komatsu NTC Ltd.
11	OKI Electric Industry Co., Ltd.
12	OKI Com-Echoes Co., Ltd.
13	OKI Circuit Technology Co., Ltd.
14	Oki Nextech Co., Ltd.
15	OKI Engineering Co., Ltd.
16	YDK Technologies Co., Ltd.
17	Nihon Denji Sokki Co., Ltd.
18	Howa Machinery, Ltd.
19	Hosoya Pyro-Engineering Co., Ltd.
20	The Fujikura Parachute Co., Ltd.

The line-up spans unmanned aircraft, nuclear fuel, pyrotechnics, and industrial electronics—fields China has treated as dual-use-relevant. OKI Electric Industry was listed at parent level with four group companies named alongside it. Again: listing is a regulatory designation, not proof of wrongdoing. For the named companies, the practical job is to pin down the category and explain it cleanly to their own customers.

[First Wave] The 40 Entities Added on February 24, 2026

The 20 Entities on the Export Control List (Notice 2026 No. 11)

The first wave of the export ban centered on shipbuilding, aero engines, naval systems, and heavy-industry defense subsidiaries²⁷.

No.	Entity
1	Mitsubishi Heavy Industries Shipbuilding Co.
2	Mitsubishi Heavy Industries Aero Engines, Ltd.
3	Mitsubishi Heavy Industries Marine Machinery & Equipment Co., Ltd.
4	Mitsubishi Heavy Industries Engine & Turbocharger, Ltd.
5	Mitsubishi Heavy Industries Maritime Systems, Ltd.
6	Kawasaki Heavy Industries Aerospace Systems Company
7	KAWAJU Gifu Engineering Co., Ltd.
8	Fujitsu Defense & National Security, Ltd.
9	IHI Power Systems Co., Ltd.
10	IHI Master Metal Co., Ltd.
11	IHI Jet Service Co., Ltd.
12	IHI Aerospace Co., Ltd.
13	IHI Aero Manufacturing Co., Ltd.
14	IHI Aerospace Engineering Co., Ltd.
15	NEC Network and Sensor Systems, Ltd.
16	NEC Aerospace Systems, Ltd.
17	Japan Marine United Corporation
18	JMU Defense Systems Co., Ltd.
19	National Defense Academy of Japan
20	Japan Aerospace Exploration Agency (JAXA)

The 20 Companies on the Watch List (Notice 2026 No. 12)

The first Watch List wave drew from a wider industrial range: materials, electronic components, even a university⁴⁷.

No.	Company
1	SUBARU Corporation
2	FUJI Aerospace Technology Co., Ltd.
3	ENEOS Corporation
4	Yusoki Co., Ltd.
5	ITOCHU Aviation Co., Ltd.
6	Leda Group Holdings Co., Ltd.
7	Institute of Science Tokyo
8	Mitsubishi Materials Corporation
9	ASPP Co., Ltd.
10	Yashima Denki Co., Ltd.
11	Sumitomo Heavy Industries, Ltd.
12	TDK Corporation
13	Mitsui Bussan Aerospace Co., Ltd.
14	Hino Motors, Ltd.
15	Tokin Corporation
16	Nissin Electric Co., Ltd.
17	Sun Tectro Co., Ltd.
18	Nitto Denko Corporation
19	NOF Corporation
20	Nacalai Tesque, Inc.

The two waves total 80 entities. Wave one hit shipbuilding, aviation, and aerospace. Wave two reached unmanned systems, nuclear fuel, pyrotechnics, and defense research institutions. Once you include naming variants and affiliates, the match set multiplies.

Legal Basis: Export Control Law and Dual-Use Items Regulations

China's dual-use export controls rest on the Export Control Law of the People's Republic of China and the Regulations on the Export Control of Dual-Use Items (in force since December 1, 2024). The full system is covered in Understanding China's Export Control Law system. For these lists, the operative articles are:

The Export Control List rests on Articles 28 and 29 of the Regulations³⁶. Article 28 allows importers and end users to be listed for violating end-user and end-use management requirements, potentially endangering national security and interests, or using dual-use items for terrorist purposes. Article 29 provides the menu: transaction bans, transaction restrictions, and export suspension orders. The notices invoke the ban and the suspension. On top of that, the notice text bars organizations and individuals outside China from transferring or supplying Chinese-origin dual-use items to listed entities—a re-export-style reach.

The Watch List rests on Article 26³⁶. Importers and end users whose end use cannot be confirmed—non-cooperation with verification within the deadline, or failure to submit supplementary materials—can be listed. Once listed, general licenses and registration-based export documentation become unavailable. An individual license application must carry a risk assessment report on the listed entity and a written pledge that the items will not be used in any way that contributes to enhancing Japan's military capabilities. One line in Notice No. 28 is easy to miss: license reviews for these applications are exempt from the deadline in Article 17, paragraph 1 of the Regulations⁵. The standard rule requires a decision within 45 days of acceptance; Watch List reviews have no such ceiling. For a business with hard delivery dates, that can function as a de facto embargo.

How China framed the policy

On June 29, the MOFCOM spokesperson described the measure as aimed at thwarting what China calls Japan's remilitarization and nuclear aspirations⁸. The February statement ran along the same lines⁹. Read that as a continuing policy track, not a one-day retaliation. The same spokesperson also said law-abiding Japanese entities have nothing to fear and that targets are limited to a small number of entities and dual-use items—language that does not change the operational duty to screen.

Japan's government rejected the first wave the day it landed. Press reports quoted Deputy Chief Cabinet Secretary Kei Sato calling the measure unacceptable and lodging a protest⁷.

Rare-earth friction sits in the background. Reports in 2026 described detentions involving Japanese nationals over products containing rare earths¹⁰¹¹. China had already tightened dual-use exports destined for Japan, including rare earths, in January 2026¹². The 80-entity build-out is an extension of that sequence. Full rare-earth chronology: China rare earth export control map.

Not on the List? The Re-Export Rule Can Still Reach You

The most common misreading is "we are not named, so this does not apply." Control List measures are not only a problem for the 80 listed entities.

Notices No. 11 and No. 27 prohibit not just Chinese exporters but organizations and individuals outside China from transferring or supplying Chinese-origin dual-use items to listed entities¹². CISTEC has cautioned that even a domestic transaction between two Japanese companies inside Japan falls within scope as a "domestic transfer" when Chinese-origin dual-use items are passed to a listed company³. Picture a trading house that imports components from China and delivers them to a listed customer. Under the Chinese framework, that purely domestic deal can constitute a violation. The same pattern applies to a U.S. distributor with Chinese-origin dual-use inventory that resells into a listed Japanese end user.

This is not theoretical. CISTEC notes a precedent under China's Unreliable Entity List regime in which a company in the same country as a listed party transferred Chinese products to it in circumvention of the restrictions; Chinese authorities issued a caution, demanded corrective measures, and warned that non-compliance would lead to listing³. Overseas subsidiaries are equally in range.

Whether your company is concretely affected can be worked out in three steps.

1. Match customer, supplier, and delivery-destination masters against the 80 entities—including naming variations and affiliates. If there are no hits, go to step 2.
2. Inventory whether the items you handle include Chinese-origin dual-use items. If not, direct impact is limited. If so, go to step 3.
3. Trace whether those Chinese-origin items could reach a listed entity, directly or indirectly, through second- and third-tier destinations. If a path exists, revise terms of trade or cut the path.

Step 3 cannot be finished inside your own four walls. You will need to query counterparties. A workable request looks like this:

[Sample confirmation request to a business partner] We are writing regarding the 80 Japanese companies and organizations designated by China's Ministry of Commerce under Notices 2026 No. 11, No. 12, No. 27, and No. 28 (list attached). Could you please confirm whether any designated entity or its affiliates appears among the suppliers of the products and materials you deliver to us, or among the onward sales destinations of our products through your company? If so, please also let us know whether the items concerned contain materials of Chinese origin.

Repeating that query for every counterparty is the work. If your counterparty count is large, this is where automation earns its keep. Load your list and counterparties into TRAFEED and it cross-checks them against major global lists—including China's Control List and Watch List—returning whether a risk exists and the basis for it. Final classification and ship/no-ship decisions remain with your export control officer.

Is There a Way Off the List?

For listed entities, and for companies that want to keep trading with them, removal rules differ by list.

The Watch List has an explicit exit. Notice No. 28 provides that an entity which fulfills its verification cooperation obligations under Article 26 of the Regulations may apply for removal, and MOFCOM may remove it after confirmation⁵. Cooperate with end-use verification, show there has been no improper alteration or transfer, and the door opens.

For the Export Control List, the notices say nothing about removal. Article 18 of the Export Control Law and Article 30 of the Regulations contain delisting provisions, but as CISTEC points out, the notices do not invoke them³. In the short term, no business plan should assume Control List removal.

Five Practical Actions for Export Control Teams

With the roster in hand, what should practitioners do? Five actions, in priority order.

First, full re-screening of the counterparty database. Match every entry in customer and supplier masters against the 80 entities. Ideally include delivery destinations through subcontractors and distributors. Names shift across four layers; official English names alone are not enough.

Second, inventory Chinese-origin dual-use item flows. The re-export rule cannot be managed without locking down both the inlet where Chinese-origin dual-use items enter and the outlet where they leave. Identify which China-sourced materials, components, and equipment qualify as dual-use, and make ultimate destinations traceable.

Third, review how you run classification and documentation. If transactions with Watch List entities remain, risk assessment reports and pledges will be required. Revisit classification document formats and approval flow now. If Japan-side classification paperwork is the bottleneck when Japanese customers ask for certificates, see the certificate of non-applicability guide.

Fourth, update internal rules and train non-export functions. This measure lands on sales, procurement, and logistics. The point that a domestic transfer can be caught if Chinese-origin items are involved is exactly what non-export teams often miss. Brief them, even briefly. On the Japanese licensing side, the Three Principles on Defense Equipment Transfer and operational guidelines were amended on April 21, 2026¹³; China's lists and Japan's licensing regime now belong in the same screening conversation. See Three Principles on Defense Equipment Transfer.

Fifth, decide whether manual matching still scales. A few dozen screenings a month can be handled by hand. A global manufacturer with tens of thousands of transactions a year will need weeks just to reflect 80 additions and re-run matching. The scope doubled in half a year. Manual operations are close to their limit.

METI's December 2025 analysis of FEFTA violations (FY2024) found that 52 percent originated in classification decisions and 36 percent in management-framework gaps¹⁴. Japanese export control operations had already passed the breaking point of brute-force methods before China's restrictions expanded. Details: FEFTA violation analysis. U.S. teams that already live with Entity List velocity will recognize the pattern.

When Spreadsheet Matching Stops Working

Sanctions and control lists grow by the month. Ownership structures tangle. Regulatory originals publish in Chinese. Chasing all of that by hand is not realistic, and the jump from 40 to 80 entities in four months suggests a third wave is entirely possible.

The AI export control agent TRAFEED (formerly ZEROCK ExCHECK), developed by TIMEWELL, was built for this workload. Upload your counterparty list and the AI cross-references it against sanctions and dual-use risk sources worldwide—including China's Control List and Watch List—returning a risk determination with source trails for audit. It also traces ownership chains through parents and subsidiaries, reducing misses from naming variations and affiliate structures. In a joint validation with Okayama University on roughly 30,000 past screening records, AI screening accuracy reached 95% or higher (company research). TRAFEED supports judgment; the final classification decision always rests with your export control officer.

If you want to check supply-chain exposure or redesign screening around the 80-entity set, book a consultation. We will organize the work around your current masters and flows.

Related Articles

• China rare earth export control map
• Understanding China's Export Control Law system: complete guide
• Three Principles on Defense Equipment Transfer: April 21, 2026 amendment
• Certificate of non-applicability: classification procedures and catch-all practice
• FY2024 FEFTA violation analysis: classification as the top failure mode
• Entity List, MEU List, and SDN List: how they differ

China's dual-use restrictions involving Japanese entities are not a one-off headline. Doubling from 40 to 80 names in half a year is a process risk for anyone who handles Chinese-origin dual-use content. Do not stop at "is my company on the list?" Build the ability to see Chinese-origin item flows and counterparties past the first tier—now.

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References

• Ministry of Commerce of the People's Republic of China, Notice 2026 No. 27 (adding 20 Japanese entities to the Export Control List, promulgated and effective June 29, 2026)
• Ministry of Commerce of the People's Republic of China, Notice 2026 No. 28 (adding 20 Japanese companies to the Watch List, promulgated and effective June 29, 2026)
• Ministry of Commerce of the People's Republic of China, Notice 2026 No. 11 (adding 20 Japanese entities to the Export Control List, promulgated and effective February 24, 2026)
• Ministry of Commerce of the People's Republic of China, Notice 2026 No. 12 (adding 20 Japanese companies to the Watch List, promulgated and effective February 24, 2026)
• MOFCOM spokesperson Q&A on export control measures related to Japan (June 29, 2026 and February 24, 2026)
• CISTEC, flash reports on the additions of Japanese entities to the Export Control List and Watch List (June 29, 2026 and February 24, 2026), including provisional translations of the notices
• Regulations of the People's Republic of China on the Export Control of Dual-Use Items (CISTEC provisional translation ver. 3, October 22, 2024)
• METI, "Partial Amendment of the 'Three Principles on Defense Equipment Transfer'" (April 21, 2026)
• METI, "Analysis of FEFTA Violation Cases (Security Trade Control) (FY2024)" (December 2025)

Footnotes

1. Ministry of Commerce of the People's Republic of China, Notice 2026 No. 27, adding 20 Japanese entities to the Export Control List (June 29, 2026) https://www.mofcom.gov.cn/zwgk/zcfb/art/2026/art_df87be1437044874a35f85cf6e076f3d.html ↩ ↩² ↩³ ↩⁴

2. Ministry of Commerce of the People's Republic of China, Notice 2026 No. 11, adding 20 Japanese entities to the Export Control List (February 24, 2026) https://www.mofcom.gov.cn/zwgk/zcfb/art/2026/art_b5159a773124428a9813884015d1b8b3.html ↩ ↩² ↩³ ↩⁴

3. CISTEC, "Chinese authorities add Japanese companies to the 'Export Control List' (20 entities) and the 'Watch List' (20 entities) (flash report)" (June 29, 2026), including provisional translations of Notices No. 27 and No. 28 and practice notes https://www.cistec.or.jp/service/keizai_anzenhosho/china/data/20260629.pdf ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷

4. Ministry of Commerce of the People's Republic of China, Notice 2026 No. 12, adding 20 Japanese entities to the Watch List (February 24, 2026) https://www.mofcom.gov.cn/zwgk/zcfb/art/2026/art_bac18400512d408a8d4c2f964e36ac11.html ↩ ↩²

5. Ministry of Commerce of the People's Republic of China, Notice 2026 No. 28, adding 20 Japanese entities to the Watch List (June 29, 2026) https://www.mofcom.gov.cn/zwgk/zcfb/art/2026/art_c2ab731429dc4bc3ba8696cd0e6ad857.html ↩ ↩² ↩³ ↩⁴

6. Regulations of the People's Republic of China on the Export Control of Dual-Use Items (CISTEC provisional translation ver. 3, October 22, 2024) https://www.cistec.or.jp/service/keizai_anzenhosho/china/data/20241021_yaku.pdf ↩ ↩² ↩³ ↩⁴

7. CISTEC, "Chinese authorities place Japanese companies and universities on the 'Export Control List' (20 entities) and the 'Watch List' (20 entities) (flash report)" (February 24, 2026), including provisional translations of Notices No. 11 and No. 12 and the legal framework https://www.cistec.or.jp/service/keizai_anzenhosho/china/data/20260225.pdf ↩ ↩² ↩³ ↩⁴

8. Ministry of Commerce of the People's Republic of China, spokesperson Q&A on export control measures related to Japan (June 29, 2026) https://www.mofcom.gov.cn/syxwfb/art/2026/art_7f7ba1aa2b1a43a480e7f5c0e6f0e618.html ↩

9. Ministry of Commerce of the People's Republic of China, spokesperson Q&A on export control measures related to Japan (February 24, 2026, background to the first wave) https://www.mofcom.gov.cn/xwfb/xwfyrth/art/2026/art_ecab07b2d57149ecbd800fe40362e8ed.html ↩

10. Nikkei, "Two Japanese employees of Fuji Electric detained in China, suspected rare-earth control violation" (June 2026) https://www.nikkei.com/article/DGXZQOCB240XD0U6A620C2000000/ ↩

11. KAB, "Two Japanese nationals detained in Dalian, China, possibly over rare-earth export controls" (remarks by Chief Cabinet Secretary Kihara) https://www.kab.co.jp/news/article/16669190 ↩

12. CISTEC, "Tightening of China's Export Controls on Dual-Use Items Destined for Japan" (January 6, 2026) https://www.cistec.or.jp/service/keizai_anzenhosho/china/data/20260106-2.pdf ↩

13. METI, "Partial Amendment of the 'Three Principles on Defense Equipment Transfer'" (April 21, 2026) https://www.meti.go.jp/press/2026/04/20260421003/20260421003.html ↩

14. METI, "Analysis of FEFTA Violation Cases (Security Trade Control) (FY2024)" (December 2025) https://www.meti.go.jp/policy/anpo/gaitameho_document/ihanjireigaitamehou6.pdf ↩