[June 2026 Update] China's Export Restrictions Targeting Japan: Complete Guide to the 80-Entity Restriction List and the Practical Response to Dual-Use Controls

Hello, this is Hamamoto from TIMEWELL. On June 29, 2026, China's Ministry of Commerce added 40 more Japanese companies and organizations to its export restriction lists. Combined with the first wave of 40 entities announced on February 24, that means a cumulative 80 entities have been named on China's restriction lists in under half a year.

This second wave changed in character significantly. It reached into the cluster of research institutes under the Ministry of Defense, the defense subsidiaries of Mitsubishi Electric and Mitsubishi Heavy Industries, nuclear fuel, and unmanned aircraft makers. Let me organize this move, which could destabilize manufacturing supply chains, based on primary sources from MOFCOM (China's Ministry of Commerce).

The June 29, 2026 Escalation of China's Export Restrictions on Japan

On June 29, the Ministry of Commerce issued two notices simultaneously. One was Notice 2026 No. 28[^1], which added 20 Japanese companies to the Watch List; the other added 20 Japanese entities to the Export Control List[^2]. Both cite the Export Control Law of the People's Republic of China and the Regulations on the Export Control of Dual-Use Items as their legal basis, and both took effect on the date of promulgation, June 29, 2026.

The two lists have similar names, but the weight of the measures they impose is completely different. Let me walk through the substance of each.

The 20 Companies Added to the Watch List

The Watch List does not ban exports outright, but it makes the procedures considerably heavier. To export dual-use items to a designated company, you can no longer obtain export documentation through the simplified routes that were available until now, namely the general license and registration-based filing. For every transaction, you must apply for an individual license and, each time, submit a "risk assessment report on the Watch-Listed entity" and a written pledge that the dual-use items "will not be used in any way that contributes to enhancing Japan's military capabilities"[^1]. The stated reason for designation is that these are Japanese entities for which the end user and end use of the dual-use items cannot be confirmed.

The 20 companies added to the Watch List under Notice No. 28 are as follows.

No.	Company or Organization
1	Mitsui E&S (三井E&S)
2	Mitsui Bussan Aerospace Maintenance Center (三井物産エアロスペース メンテナンスセンター)
3	Terra Drone
4	ACSL
5	Mitsubishi Nuclear Fuel (三菱原子燃料)
6	Japan Nuclear Fuel Limited (日本原燃)
7	Fujitsu Network Solutions (富士通ネットワークソリューションズ)
8	Hitachi Advanced Systems (日立アドバンストシステムズ)
9	Komatsu Industries (コマツ産機)
10	Komatsu NTC (コマツNTC)
11	Oki Electric Industry (沖電気工業)
12	OKI Com Echoes (OKIコムエコーズ)
13	OKI Circuit Technology (OKIサーキットテクノロジー)
14	OKI Nextech (OKIネクステック)
15	OKI Engineering (OKIエンジニアリング)
16	YDK Technologies (YDKテクノロジーズ)
17	Nippon Denji Sokki (日本電磁測器)
18	Howa Machinery (豊和工業)
19	Hosoya Pyro-Engineering (細谷火工)
20	Fujikura Parachute (藤倉航装)

What stands out is the presence of the drone makers Terra Drone and ACSL, the nuclear-fuel companies Mitsubishi Nuclear Fuel and Japan Nuclear Fuel, and the pyrotechnics makers Howa Machinery and Hosoya Pyro-Engineering. You can see a clear awareness of fields that are readily diverted to military use: unmanned aircraft, nuclear power, and explosives.

The 20 Entities Added to the Export Control List

The other list, the Control List, is far stricter than the Watch List. The Ministry of Commerce explains that it placed 20 Japanese entities that "participate in enhancing Japan's military capabilities," starting with the National Institute for Defense Studies, on the list[^2]. The measures imposed are heavy, and roughly fall into four points. First, exports of dual-use items to the designated entities are prohibited. Second, the notice spells out an extraterritorial reach that also bars organizations and individuals outside China from transferring or supplying Chinese-origin dual-use items to these entities. Third, ongoing related transactions must be suspended immediately. Only where there are special circumstances that make an export unavoidable may the export operator apply individually to the Ministry of Commerce.

This Control List is promulgated in the body of the Ministry of Commerce notice as "Notice 2026 No. 27"[^2][^6]. It carries the same June 29 date as Notice No. 28 for the Watch List, and both the contents of the list and the substance of the measures can be confirmed in primary sources. The 20 designated entities are as follows.

No.	Organization
1	National Institute for Defense Studies (防衛研究所)
2	Ground Systems Research Center (陸上装備研究所)
3	Naval Systems Research Center (艦艇装備研究所)
4	Air Systems Research Center (航空装備研究所)
5	Nikko Tokki (日鋼特機)
6	Nikko YPK Trading (日鋼YPK商事)
7	Mitsubishi Electric Defense and Space Technologies (三菱電機ディフェンス＆スペーステクノロジーズ)
8	Mitsubishi Electric Software (三菱電機ソフトウエア)
9	Mitsubishi Electric Engineering (三菱電機エンジニアリング)
10	Mitsubishi Precision (三菱プレシジョン)
11	Mitsubishi Heavy Industries Oceanics (三菱重工オーシャニクス)
12	Mitsubishi Heavy Industries Sagami High-Tech (三菱重工相模ハイテック)
13	Mitsubishi Heavy Industries Logitec (三菱重工ロジテック)
14	Kowa Kogyo (光和興業)
15	Ryoju Special Vehicle Service (菱重特殊車両サービス)
16	Mitsubishi Heavy Industries Maritech (三菱重工マリテック)
17	KGM
18	Nippi Corporation (日本飛行機)
19	Fortunio (フォルトゥニオ)
20	Aoki Precision Industries (青木精密工業)

Four research institutes under the Ministry of Defense are lined up here, and defense subsidiaries of Mitsubishi Electric and Mitsubishi Heavy Industries make up the majority. In the original Chinese text, Mitsubishi Heavy Industries Oceanics is written as 三菱重工海洋技术, so the name is rendered inconsistently. When matching against your own counterparties, you need to check against both the Japanese and the English name.

How the Two Lists Differ

Because it is easy to confuse the two lists when you first encounter them, the differences in the measures are summarized in a single table below.

Aspect	Export Control List (No. 27)	Watch List (No. 28)
Severity	More severe	Relatively lighter
Whether exports are allowed	Dual-use items prohibited in principle	Not prohibited, but procedures tightened
General license and registration filing	Cannot be used (exports prohibited outright)	Cannot be used (individual license only)
Extraterritorial reach	Yes (supply of Chinese-origin goods via a third country also prohibited)	Not specified
Ongoing transactions	Immediate suspension	No provision
Additional documents required	Individual application only	Risk assessment report and written pledge of non-diversion to military use
Reason for designation	Involvement in enhancing military capabilities	End user and end use cannot be confirmed

Put simply, the Control List says "do not ship," while the Watch List says "if you ship, take on considerable burden and accountability." Depending on which list your counterparty falls under, the response required is entirely different.

The Rationale China Put Forward

On June 29, the Ministry of Commerce spokesperson also issued a statement. The argument was that the measure is intended to curb Japan's ambition for "remilitarization" and its intent toward nuclear development, and to firmly stop "the reckless moves of new-type militarism"[^3]. Referring to the February measure, the spokesperson criticized Japan for, far from reflecting, instead pressing ahead down the wrong path and accelerating new-type militarism and remilitarization. At the same time, the statement stressed that Japanese entities that sincerely abide by the law have no need for concern, that normal economic and trade exchange between China and Japan is unaffected, and that the targets are limited to a small number of Japanese entities and dual-use items. Xinhua also reported the measure the same day[^4].

This line of argument has been consistent since the first wave. In the February 24 spokesperson Q&A as well, the explanation was that the measure aims to stop Japan's remilitarization and its intent to acquire nuclear weapons, and that it covers any use that contributes to enhancing military capabilities[^16]. There is no need to take China's claims at face value, but you can read in them that the restrictions are being built up as a continuing policy rather than a one-off act of retaliation.

When the first wave was announced in February, the prevailing view was that it had been triggered by Prime Minister Sanae Takaichi's Diet remarks regarding a Taiwan contingency. By contrast, what came to the fore in the June 29 spokesperson statement was a more generalized line of argument about Japan's defense policy as a whole and "remilitarization," rather than any specific remark.

The Detention of Japanese Nationals in Dalian in the Background

Behind this measure lies friction over rare earths. According to reports, two Japanese employees of the Fuji Electric group were detained in Dalian. One was taken into custody on May 18 and the other on May 25, each on suspicion of smuggling goods banned for import and export, and it is reported that taking products containing rare earths out of China was deemed problematic[^8][^9]. Chief Cabinet Secretary Kihara also referred to this case.

China put its Regulations on the Export Control of Dual-Use Items into effect in December 2024, and in January 2026 it further tightened export controls on dual-use items destined for Japan, including rare earths[^11]. It becomes much easier to see the picture if you view this list-building at the scale of 80 entities as an institutional extension of that sequence. For the overall picture of the rare-earth controls themselves, our China Rare Earth Export Control Map lays them out chronologically, and reading the two together gives you a more three-dimensional grasp.

If you want to check whether any of these 80 entities or their affiliates have slipped into your own supply chain, the AI export control agent TRAFEED helps with cross-matching your counterparty list. In addition to sanctions lists and risk information from around the world, it checks against China's Control List and Watch List, returning whether a risk exists and the basis for it in seconds.

Recap: The First Wave of February 24, 2026

To understand the second wave, it helps to grasp the shape of the first wave. On February 24, 2026, China added 20 companies to the Control List under Notice No. 11, followed by a notice adding 20 companies to the Watch List[^5]. The structure of the measures was almost identical to that of June 29: a two-tier setup in which the Control List was effectively an export ban and the Watch List was a strict, case-by-case review.

The first wave Control List included companies in the Mitsubishi Shipbuilding and Mitsubishi Heavy Industries groups, Kawasaki Heavy Industries, IHI-affiliated companies, NEC-affiliated companies, Japan Marine United, the National Defense Academy of Japan, and the Japan Aerospace Exploration Agency (JAXA). The Watch List included a broader range of industries, such as SUBARU, ENEOS, TDK, Mitsubishi Materials, and Sumitomo Heavy Industries. Looking at the first and second waves together, you can see the scope steadily widening, from shipbuilding, aviation, and aerospace to unmanned aircraft, nuclear power, pyrotechnics, and defense research institutions.

The Core of the Regulations: How the Control List and the Watch List Work

Here, let me again organize the legal character of the two lists. China's export controls rest on the Export Control Law and the Regulations on the Export Control of Dual-Use Items, and the overall picture is explained in detail in Understanding China's Export Control Law System: Complete Guide.

Companies and organizations placed on the Control List are, in effect, blacklisted. For these entities, exports of dual-use items that can be diverted to military use are prohibited in principle across the board. What cannot be overlooked is that the measure also prohibits organizations and individuals outside China from supplying Chinese-origin dual-use items, and this should be read as China's regulation stepping into de facto extraterritorial application. An exceptional licensing mechanism exists, but the realistic posture is to assume the door is extremely narrow.

The Watch List is also called the watch-monitoring list. Exports of dual-use items to it are not banned, but they are subject to extremely strict case-by-case review. General licenses and registration-based filing cannot be used, and for every transaction a risk assessment report and a written pledge that the deal does not contribute to enhancing Japan's military capabilities must be submitted. The review process is also expected to be lengthy, which will reliably blunt business velocity.

The Full List of All 40 Companies and Organizations in the First Wave

This regulation is not only a problem for the companies on the list. You need to thoroughly verify whether your own supply chain, meaning your component sourcing and your product delivery destinations, includes any of these companies. The 40 entities of the second wave are shown in the tables above, so here I re-present the 40 companies and organizations of the first wave.

First Wave Export Control List (Subject to Export Ban)

No.	Company or Organization
1	Mitsubishi Shipbuilding Co., Ltd.
2	Mitsubishi Heavy Industries Aero Engines, Ltd.
3	Mitsubishi Heavy Industries Marine Machinery and Engine Co., Ltd.
4	Mitsubishi Heavy Industries Engine and Turbocharger, Ltd.
5	Mitsubishi Heavy Industries Maritime Systems Co., Ltd.
6	Kawasaki Heavy Industries, Aerospace Systems Company
7	Kawaju Gifu Engineering Co., Ltd.
8	Fujitsu Defense and National Security Limited
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)

First Wave Watch List (Subject to Individual License Application)

No.	Company or Organization
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	Tokyo University of Science
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	Suntechno Co., Ltd.
18	Nitto Denko Corporation
19	NOF Corporation
20	Nacalai Tesque, Inc.

Adding the first and second waves gives a cumulative 80 entities. Once you include naming variations and subsidiaries and affiliates, the number of names you need to match against expands even further.

Three Risks on the Horizon

The impact of this measure on Japanese companies is not the simple matter of a single transaction being suspended. Deeper, more structural risks lie underneath.

The first is supply chain disruption. If you source critical components or materials from a designated entity, continuing your business may become difficult. If a substitute supplier can be found quickly, that helps, but if the item is a specialty product available only in Japan or made only by a specific company, production line stoppages or delays in product development become unavoidable. With nuclear fuel and pyrotechnics makers added in the second wave, the range of industries affected has widened further.

The second is unintentional regulatory violation. What is frightening is the risk of indirect export. Even if your direct counterparty is fine, if a product you exported ultimately reaches a designated entity by passing through a downstream distribution channel, you yourself may become subject to sanctions. Because the Control List in particular spells out extraterritorial reach, overseas bases that handle Chinese-origin goods are also within range. Avoiding this kind of risk requires the mind-numbing work of verifying, all the way to the very end of the supply chain, that no counterparty appears on the list.

The third is the domino effect of expanding regulation. The Chinese government has commented that honest companies that comply with the law have nothing to worry about, but taking this at face value is too optimistic. The fact that the scope doubled in just four months between the first and second waves tells you the regulation may well keep expanding. Just as the US Export Administration Regulations (EAR) introduced an Affiliates Rule that automatically extends restrictions to subsidiaries in which a listed company holds 50 percent or more of the shares, there is ample room for China's regulations to cascade into affiliated companies as well.

The "Symmetry" with the April 21, 2026 Amendment of the Three Principles on Defense Equipment Transfer

When discussing China's restrictions targeting Japan, treating them in isolation from Japan's amendment of the Three Principles on Defense Equipment Transfer is, in my view, seeing only half of reality.

On April 21, 2026, following decisions by the National Security Council (NSC) and the Cabinet, METI and the Ministry of Defense amended the Three Principles on Defense Equipment Transfer and parts of the operational guidelines[^10][^14]. There are four key changes. The five categories of rescue, transport, alert, surveillance, and minesweeping were abolished. The transfer of lethal weapons was made possible in principle. Recipients were limited to countries that have signed a defense equipment transfer agreement with Japan. And transfers to combatant parties remain prohibited in principle, with exceptions allowed only under particular circumstances. The countries with signed agreements are currently 17, including the United States, Australia, and the Philippines.

Japan's step toward becoming a country that can export weapons and China's listing of Japanese companies are happening in parallel at almost the same time. Each side, Japan and China, is exchanging blows on the same table with regulations aimed at the other side's supply chain and defense industry. For export control practitioners, the era when it was enough to watch only the regulations of your counterparty country is over. China's sanctions list and Japan's licensing regime now have to be viewed in the same screening flow. For the Three Principles themselves, see Three Principles on Defense Equipment Transfer: Complete Guide for a detailed overview.

Five Practical Actions Every Corporate Export Control Practitioner Should Take Now

With the situation laid out, what should frontline export control practitioners do starting tomorrow? Here are five actions in order of priority.

The first is a full re-screening of your counterparty database. Match every entry in your customer master and supplier master against all 80 entities. Ideally, include not only direct trade but also delivery destinations through subcontractors and distributors. You also need to watch for naming variations. If your system cannot recognize that Mitsubishi Heavy Industries Oceanics and the Chinese-text rendering 三菱重工海洋技术 are the same company, misses will occur.

The second is an inventory of the flow of Chinese-origin goods. The crucial point of the Control List measure is that it also prohibits operators outside China from supplying Chinese-origin dual-use items. Inventory the materials, components, and equipment you have sourced from China to check whether there is any path through which they ultimately flow to a Control List entity. You need to lock down both the inlet where Chinese-origin goods enter and the outlet where they leave.

The third is a review of how you run classification. If transactions with Watch List entities remain, you will be required to provide a written pledge that the deal does not contribute to enhancing Japan's military capabilities, along with a risk assessment report. It is worth revisiting the format of your classification documentation and your approval flow once more. If you are uncertain about classification itself, see Non-Applicable Certificate: Complete Guide.

The fourth is updating internal rules and training. My impression is that many companies revise their export control rules and training materials only about once every six months. Both China's measure this time and Japan's amendment of the Three Principles on Defense Equipment Transfer are matters that should be written into the rules. Make sure each function, sales, procurement, and logistics, gets a short but clear update on what changed and how their day-to-day actions need to change.

The fifth is considering the adoption of automation and AI screening. A company that screens only a few dozen times a month can manage by hand, but a global manufacturer running tens of thousands of transactions a year would take weeks just to reflect the 80 added entities into its master data. Given the speed at which the scope doubled in half a year, keeping up by hand is close to its limit.

Note that in December 2025, METI released its analysis of FEFTA violation cases for FY2024[^15]. Of all violations, 52 percent originated in classification decisions and 36 percent stemmed from gaps in the management framework. Even before China's restrictions targeting Japan expanded, Japanese export controls had already passed the breaking point of brute-force, labor-intensive operations. That is the reality on the ground.

Brute Force Is No Longer Enough

The sanctions lists of countries around the world that keep growing by the day, the intricately tangled ownership structures of companies, and the latest regulatory information released in Chinese. Chasing all of this by hand while maintaining a flawless compliance posture is not realistic.

The AI export control agent TRAFEED (formerly ZEROCK ExCHECK), developed by TIMEWELL, was created to solve exactly these challenges. Simply upload your counterparty list, and the AI instantly cross-references it against sanctions lists and risk information from around the world, as well as China's Control List and Watch List, returning whether a risk exists in seconds. Because it clearly presents the information sources behind each determination, it supports the judgment of your practitioners and leaves records that can withstand an audit.

The AI monitors foreign news and corporate databases that humans cannot keep up with, catching signs of risk. It automatically traces ownership chains, not only across counterparties but through parents and subsidiaries, surfacing hidden risks. Even when there is a legal amendment or a new list, it is reflected in the system immediately, so checks are always based on the latest regulatory environment.

If you want to check whether your supply chain carries any risk, or to review your export control framework, please reach out through our individual consultation. From checking your counterparty list for matches to designing your response to the 80-entity restrictions, we will organize the work to fit your current situation.

Related Articles

• China Rare Earth Export Control Map
• Understanding China's Export Control Law System: Complete Guide
• Three Principles on Defense Equipment Transfer: What Changed in the April 21, 2026 Amendment and Five Practical Points for Export Control Practitioners
• Non-Applicable Certificate: Classification Procedures, Parameter Sheets, and the Latest Catch-All Practice
• 52% of FY2024 FEFTA Violations Originated in Classification: The Five Fatal Patterns in Japanese Export Controls from METI Statistics and How to Prevent Them
• Impact of a Strait of Hormuz Blockade on the Japanese Economy

China's export restrictions targeting Japan are not a one-off. The trajectory of doubling from 40 to 80 entities in half a year marks the beginning of a new reality that Japanese companies will face again and again. The fact that Japan's amendment of the Three Principles on Defense Equipment Transfer and China's restrictions targeting Japan are running side by side at the same time is a symbol of it. Updating your supply chain and your risk management framework into something more robust and more agile is becoming a precondition for navigating an uncertain era.

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References

• Ministry of Commerce of the People's Republic of China, Notice 2026 No. 28 (adding 20 Japanese companies to the Watch List, June 29, 2026)
• 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)
• Reuters (distributed by Newsweek Japan), "China adds 20 Japanese companies and organizations including the National Institute for Defense Studies to its dual-use export control lists" (June 29, 2026)
• Ministry of Commerce spokesperson, Q&A on export control measures related to Japan (February 24, 2026, background to the first wave)
• Xinhua, "China places 20 Japanese entities on its export control list" (June 29, 2026)
• Ministry of Commerce of the People's Republic of China, Notice 2026 No. 11 (first wave Control List, February 24, 2026)
• Anli Partners Law Firm, "MOFCOM places 40 Japanese entities on the Export Control List and the Watch List respectively"
• Nikkei, "Two Japanese employees of Fuji Electric detained in China" (June 2026)
• KAB, "Two Japanese nationals detained in Dalian, China, possibly over rare-earth export controls"
• METI, "Partial Amendment of the 'Three Principles on Defense Equipment Transfer'" (April 21, 2026)
• CISTEC, "Tightening of China's Export Controls on Dual-Use Items Destined for Japan" (January 6, 2026)

[^1]: Ministry of Commerce of the People's Republic of China, Notice 2026 No. 28, "Adding 20 Japanese Entities to the Watch List" (Bureau of Security and Control, June 29, 2026) https://www.mofcom.gov.cn/zwgk/zcfb/art/2026/art_c2ab731429dc4bc3ba8696cd0e6ad857.html [^2]: 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/zcfb/blgg/gg/2026/art/2026/art_6607ea694b704da8ac5e863a5568e47c.html [^3]: Reuters (distributed by Newsweek Japan), "China adds 20 Japanese companies and organizations including the National Institute for Defense Studies to its dual-use export control lists" (June 29, 2026) https://www.newsweekjapan.jp/articles/-/326846 [^4]: Xinhua, "China places 20 Japanese entities on its export control list" (June 29, 2026) https://www.news.cn/world/20260629/67f1f5e04a564abb826a5eb1ad98b34f/c.html [^5]: Ministry of Commerce of the People's Republic of China, Notice 2026 No. 11 (first wave Control List, 20 companies, February 24, 2026) https://www.mofcom.gov.cn/zwgk/zcfb/art/2026/art_b5159a773124428a9813884015d1b8b3.html [^6]: Ministry of Commerce of the People's Republic of China, index of 2026 MOFCOM notices (location of No. 27 and No. 28) https://www.mofcom.gov.cn/zcfb/blgg/gg/2026/index.html [^7]: Anli Partners Law Firm, "MOFCOM places 40 Japanese entities on the Export Control List and the Watch List respectively" https://www.anlilaw.com/100031/3423 [^8]: Nikkei, "Two Japanese employees of Fuji Electric detained in China, suspected rare-earth control violation" (June 2026) https://www.nikkei.com/article/DGXZQOCB240XD0U6A620C2000000/ [^9]: KAB, "Two Japanese nationals detained in Dalian, China, possibly over rare-earth export controls" (Chief Cabinet Secretary Kihara) https://www.kab.co.jp/news/article/16669190 [^10]: 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 [^11]: 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 [^12]: Anderson Mori and Tomotsune, "Promulgation of the 'Export Control List' and 'Watch List' (February 24, 2026)," China Legal Update (March 2, 2026) https://www.amt-law.com/asset/pdf/bulletins7_pdf/CPG_260302.pdf [^13]: JETRO, "Information on China's Economic Security System" (April 2026) https://www.jetro.go.jp/ext_images/_Reports/01/0c5708e0b901ba0b/20260004_01.pdf [^14]: METI, "Cabinet Order Partially Amending the Export Trade Control Order" (November 11, 2025) https://www.meti.go.jp/press/2025/11/20251111001/20251111001.html [^15]: METI, "Analysis of FEFTA Violation Cases (Security Trade Control) (FY2024)" (December 2025) https://www.meti.go.jp/policy/anpo/gaitameho_document/ihanjireigaitamehou6.pdf [^16]: Ministry of Commerce of the People's Republic of China, "Spokesperson Responds to Questions 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