CISTEC Model CP Explained: Choosing Among the 6 Patterns (1A-3B) and What to Revise After the October 2025 Amendment

Hello, this is Hamamoto from TIMEWELL. When you start researching how to build an internal export control program (CP: Compliance Program), you will almost certainly land on the model CP published by CISTEC (the Center for Information on Security Trade Control). And then, when you actually open the page, you find six Word files labeled 1A, 1B, 2A, 2B, 3A, and 3B, and the questions start: which one applies to us, and once we download it, what exactly do we change? I hear this from companies constantly.

This article walks through the structure of the six patterns and how to choose among them, the branches into the brokerage-transaction variant and the group-company CP, exactly where to revise your CP after the amendment to Japan's supplementary export controls that took effect on October 9, 2025, how the CP relates to the Exporter Compliance Standards and the Special General Bulk License, and the places where using the model CP as-is gets companies into trouble. Everything here is grounded in primary sources from CISTEC and METI. By the end, you should have a clear picture of which pattern to pick and what work remains after the download. If you would first like to know where your export control program stands today, the three-minute free export-control readiness check will show you which parts of this article deserve your closest attention.

What the CISTEC Model CP Is

The model CP is a template for an internal export control program published by CISTEC. It translates the corporate framework required by Japan's Foreign Exchange and Foreign Trade Act (FEFTA) and the Exporter Compliance Standards beneath it into ready-made regulation text, and every pattern can be downloaded free of charge in Word format from CISTEC's model CP page¹. It is also the de facto standard starting point for the internal regulations companies file with METI under the circular "On the Filing of Internal Export Control Regulations"².

The skeleton of a CP is generally built from seven elements: basic policy, organization and structure, classification procedures, transaction screening procedures, shipment control, training, and audit. Add document management and the procedures for reporting violations and preventing recurrence, and you have more or less the chapter structure of the model CP itself. Drafting such a document from scratch takes months; starting from the model CP lets you concentrate on filling in the blanks and adapting the parts that need to reflect your own business.

One more thing worth knowing up front is how quickly the template moves. Following the amendment to the supplementary export controls that took effect on October 9, 2025, the model CP was revised, and files with the revised passages highlighted are posted alongside the clean versions. The page is dated as current as of April 1, 2026 and states that the model CP and related forms are updated on an ongoing basis¹. In other words, the model CP is not a download-once document. It assumes you will keep your own regulations in step with CISTEC's revisions, a point I will come back to later in this article.

The Six Patterns (1A-3B) and How to Choose

The six patterns are the product of two axes. The first axis is the management structure, with three types: (1) establish a dedicated export control department, (2) appoint a designated officer, or (3) have the representative director manage export control directly. The second axis is the classification profile, with two types: (A) companies with their own products (manufacturers and the like) and (B) companies without their own products (trading firms and the like)¹. Combined, they produce the following matrix.

Management structure \ Classification profile	(A) Own products (manufacturers)	(B) No own products (trading firms)
(1) Dedicated department	Pattern 1A	Pattern 1B
(2) Designated officer	Pattern 2A	Pattern 2B
(3) Direct management by the representative director	Pattern 3A	Pattern 3B

A simple way to remember it: the number encodes how heavy your management structure is, and the letter encodes the nature of your classification work. Manufacturers classify against the specifications of products they design and build themselves, so they take the (A) side; trading firms verify classification information obtained from suppliers, so they take the (B) side. The management structure should follow the reality of your staffing. If you can support a dedicated department, choose (1); if someone can own the role alongside trade operations or quality assurance, choose (2); if a small organization runs everything through the CEO, choose (3).

As a rough guide by company type, the mapping looks like this. Treat it as a starting point and make the final call against your actual org chart and workflows.

Company type (guide)	Starting pattern	Why
Large or mid-size manufacturer with a trade control department	1A	The division of roles assumes a dedicated department, which matches reality
Large or mid-size trading firm	1B	No in-house designed products; verifying purchased items is the core work
Mid-size manufacturer with a part-time officer	2A	The designated-officer structure works even with dual-hatted staff
Small trading firm or distributor	2B	Built around obtaining classification data from suppliers
Startup or small manufacturer	3A	Start with the CEO as supervisor and migrate to 2A or 1A as you grow
Small trading or export agency business	3B	Direct CEO oversight keeps accountability clear at small scale

The most important rule in pattern selection is not to overreach. If the reality is a CEO plus two staff but you file pattern 1A, which presumes a dedicated department, you end up in the worst possible position: your regulations describe departments and committees that do not exist. METI's on-site inspections test whether the written rules match actual operations, so the sound approach is to pick the pattern your current organization can actually run, and switch patterns as the organization matures.

Note that two branches sit outside the six patterns. For companies engaged in brokerage transactions (mediating the movement of goods between two foreign countries), CISTEC provides a brokerage-transaction variant based on pattern 1A. And for parent companies that manage export control across their subsidiaries as a group, a separate group-company model CP is provided on its own page¹. Manufacturers with trading arms and companies that transact through overseas subsidiaries should check both alongside the main pattern selection, to avoid bolting on provisions later.

Where to Revise Your CP After the October 9, 2025 Amendment

The overhaul of the supplementary export controls (catch-all controls), promulgated on April 9, 2025 and in force since October 9, 2025, was significant enough to require CP revisions³. It rests on three pillars. First, a new framework under which METI can issue an "informed" notice for Group A destinations (the former white countries) when diversion is suspected, where catch-all controls previously did not apply at all. Second, the split of Item 16 of Annex 1 to the Export Trade Control Order into "Item 16(1) specified goods" and "Item 16(2) other," with end-use and end-user requirements now applying to the specified goods (six categories including machine tools, integrated circuits, and aircraft-related items, designated by HS code) even for general destinations. Third, a new end-user requirement for conventional weapons for UN arms-embargoed countries and regions. Alongside these, the Foreign End User List was updated to 835 entities, an increase of 87. Here I will focus strictly on what to change in the CP; for the objective criteria used in screening for general destinations, see our guide to the catch-all "clearly" guideline.

Amendment (in force October 9, 2025)	What to revise in the CP
New informed requirement for Group A destinations	Add to the transaction screening procedure: the intake point for an informed notice, immediate shipment hold, and the escalation path to the overall supervisor and management
New Item 16(1) specified goods (designated by HS code)	Add a step to the classification and screening procedures that checks specified-goods status by HS code, separate from list-control classification, and add a corresponding field to the classification and screening forms
New end-user requirement for UN arms-embargoed destinations	Add checks for involvement in conventional-weapons development or production to the end-user verification criteria
Foreign End User List updated to 835 entities	Specify version control for the list used in screening and a procedure for re-screening existing counterparties when the list is updated

The change with the most practical bite is the HS code management for specified goods. Classification has traditionally meant checking product specifications against the technical parameters in Annex 1 and the related ministerial ordinance, but specified-goods status is determined by HS code, a customs classification. That means your CP now needs to describe how the export control function coordinates with the logistics and customs functions that own HS codes. Adding a "specified goods: applicable / not applicable" field to the classification sheet, and defining who confirms the underlying HS code and when, will make the workflow much easier to explain during an on-site inspection.

For the revision work itself, CISTEC's highlighted model CP files are the practical tool¹. Match the highlighted passages against the corresponding clauses of your own CP and you effectively get a to-do list of edits. After revising, record the effective date and the reason (for example, "response to the supplementary export control amendment under Cabinet Order No. 175") in your CP's revision history, so your explanations stay consistent through later audits and filing renewals.

How the Model CP Relates to the Exporter Compliance Standards and the Special General Bulk License

The model CP sits between a legal floor and a licensing privilege. Think of it as a three-layer structure. At the bottom is the ministerial ordinance establishing the Exporter Compliance Standards (METI Ordinance No. 60 of 2009), the legal minimum that applies to exporters⁴. The CP is the document that turns those requirements into your company's own procedures, and the model CP is the template that helps you write it. Filing the CP with METI, having it accepted, and demonstrating through an on-site inspection that it actually runs is the gateway to the Special General Bulk License, a powerful licensing privilege⁵.

Mapping the standards' requirements to the model CP and to what the bulk-license review additionally examines gives you a single reference table.

Exporter Compliance Standards requirement	Where the model CP covers it	What the Special General Bulk License review additionally examines
Appoint a classification officer (all exporters)	Organization and structure chapter	An org chart that actually exists, from overall supervisor to division officers
Appoint an overall supervisor at representative level and define the structure (list-controlled goods handlers)	Organization and structure chapter	That the involvement of the representative is more than nominal
Establish and run classification procedures	Classification chapter and classification form	Retention of classification sheets and a working re-classification rule
Establish and run end-use and end-user screening	Transaction screening chapter and screening form	Evidence of matching against the Foreign End User List
Verify identity of goods at shipment	Shipment control chapter	Resilience to sampling checks of shipment records
Audit (best-effort obligation)	Audit chapter	A track record of internal audits and corrective actions
Training (best-effort obligation)	Training chapter	Attendance records and coverage of the target population
Document retention (best-effort obligation)	Document management provisions	Defined retention periods and searchability
Report violations and prevent recurrence	Reporting and sanctions chapter	An escalation flow that demonstrably works

A persistent misconception is that "filing the CP automatically unlocks the Special General Bulk License." In reality you need the CP filing and its acknowledgement slip, the Exporter Profile and Self-Management Checklist and its acknowledgement slip, and then the on-site inspection, and only with all three in place do you qualify to apply⁶⁵. After acceptance, the checklist must be submitted every year between July 1 and July 31, so the CP is not a file-and-forget document but part of an annual maintenance cycle. From as-is analysis through inspection readiness, plan on six to twelve months of preparation.

Where Using the Model CP As-Is Gets Dangerous

The model CP is an excellent template, but templates have failure modes of their own. Here are the spots that most often turn into inspection findings, the kind of thing official guidance rarely spells out.

First, unfilled blanks and unselected options. The model CP contains many placeholders for department names, officers, and committees, and I have repeatedly seen regulations headed for filing with a literal "XX Department" still in the text, or naming departments that do not exist. When you open the Word file, the first task should be to inventory every placeholder into a checklist.

Second, divergence between the rules and reality. Copying the model CP's procedures wholesale means your regulations describe meetings and forms your company never operates. What an on-site inspection examines is not how impressive the rules look but whether you follow them. Any procedure you do not perform should either be cut from the regulations or rewritten into a form you can actually run. Keeping it "just in case we do it someday" is the most dangerous option.

Third, running two sets of forms. The model CP ships with template forms for classification sheets and screening sheets, but if your company already uses its own formats, you can end up with regulations citing the model forms while the floor keeps using the old ones. Consolidate on one set, and make sure the form numbers in the regulation text match the forms actually in use.

Fourth, re-classification triggers that are not yours. When regulations change, when a product specification changes, when a customer reports a change of end use: the model CP describes these triggers only in general terms, and a generic sentence will not move your engineers. You need to wire the triggers into your own product change management and design revision flows.

Fifth, deemed exports. A CP built around physical goods will underweight domestic technology transfers and disclosure of technology to foreign-national employees (checking applicability of the specified categories under the deemed-export rules). Companies with R&D functions or a significant number of foreign-national staff need to build out the technology-control sections well beyond the template.

Sixth, keeping up with revisions. As noted at the start, the model CP is updated with each regulatory change. Record which version of the model CP your regulations are based on, and make the diff against CISTEC's highlighted files an annual task. That turns regulation freshness from a matter of memory into a mechanism.

Making CP Operations Real with AI

Everything above is about writing the CP, but a CP proves itself in operation. Of the seven elements, classification, transaction screening, and shipment control carry by far the heaviest daily load, and once export transactions pass roughly ten per month, sustaining by-the-book operation on manpower alone becomes difficult. Even with good forms, reading the control lists, cross-checking spec sheets, and recording the rationale takes an experienced staffer thirty minutes to several hours per case.

TRAFEED, the export control AI agent developed by TIMEWELL, exists to bring that load down. It embeds workflows aligned with METI's list controls and catch-all controls, and generates draft classifications with cited legal grounds from product specs and datasheets. Its classification accuracy is 95 percent or higher (joint validation with Okayama University, in-house study), the classification method is patented (Japanese Patent No. 7862062), and it is in use at more than 20 organizations. From a CP standpoint it pays off in three places: standardizing judgments, recording the rationale, and training new staff. Because AI drafts and reviewer histories are recorded separately, the judgment log doubles as an audit trail and lightens on-site inspection preparation. Final decisions always rest with a human, so the design is consistent with the exporter's responsibility under FEFTA. Details on features and deployment are available in our resource library.

Summary

To close, the key points of this article.

• The CISTEC model CP comes in six patterns (1A-3B), combining three management structures with two classification profiles, downloadable free in Word format, plus a brokerage variant (based on 1A) and a group-company version
• Choose the pattern your organization can actually run today, and switch patterns as you grow rather than overreaching
• After the October 9, 2025 amendment, revise the CP in three places: the escalation procedure for informed notices, the HS code check for Item 16(1) specified goods, and the matching procedure for the 835-entity Foreign End User List
• The Special General Bulk License requires the CP acknowledgement slip, the checklist acknowledgement slip, and the on-site inspection, followed by a checklist submission every July
• The six traps of using the model CP as-is: unfilled placeholders, rules that diverge from reality, duplicate forms, generic re-classification triggers, missing deemed-export coverage, and falling behind revisions

A CP is not finished when it is written; it matters only if it keeps running as part of how your company works. If you need help customizing the model CP, revising for the 2025 amendment, or turning the rules into a working system, reach out through a TRAFEED consultation. As related reading, see How to Build an Export Control System and Preparing for an Export Control Audit.

References

Footnotes

1. Model CP (Internal Export Control Regulations): six patterns (1A-3B) in Word format, brokerage variant, group-company CP, and highlighted files reflecting the supplementary export control amendment; current as of April 1, 2026 and updated on an ongoing basis - CISTEC ↩ ↩² ↩³ ↩⁴ ↩⁵

2. On the Filing of Internal Export Control Regulations (Export Notice 17 No. 9) - METI ↩

3. On the Revision of the Supplementary Export Controls (in force October 9, 2025) - METI ↩

4. Ministerial Ordinance Establishing the Exporter Compliance Standards (METI Ordinance No. 60 of 2009) - e-Gov ↩

5. Special General Bulk Export/Service Transaction License Application - METI ↩ ↩²

6. Q&A on "On the Filing of Internal Export Control Regulations" (prepared May 2, 2025) - METI ↩