How to Complete Japan's Item-Specific Comparison Table (February 2026 Edition) with Sample Entries

Hello, this is Ryuta Hamamoto from TIMEWELL.

Three questions show up almost every time we help with Japan export classification. A counterparty asked for an item-specific comparison table and nobody on the team knows how to fill it in. Which edition is current, and where do you buy it? Can you download the Excel form for free?

The place people always get stuck is the determination column: four kinds of brackets, each with a different job. Circle, cross, and dash do not mean the same thing in every box. Online explainers often compress that into “circle means controlled, cross means not controlled.” That shorthand is wrong often enough to produce reverse classifications.

On top of the form itself, amendments to the Export Trade Control Order and related ordinances took effect on February 14, 2026 and newly brought equipment incorporating FPGAs and similar items under control¹. CISTEC revised the comparison table to match and released a February 2026 edition². If you keep classifying on an old edition, the rows for the new entries simply are not on the form. That is a structural miss, not a staffing miss.

This guide covers when the comparison table is the right tool, how to obtain the current edition, what it costs, the determination-symbol rules from CISTEC’s official completion guide, and a worked sample. Multinational teams that already know U.S. ECCN worksheets still need this if Japan is the export jurisdiction. The form is Japan-specific. The accountability logic, however, should feel familiar: the exporter owns the classification, and the worksheet has to let a third party reconstruct the reasoning.

Key points

• The item-specific comparison table is a CISTEC-format checklist covering every entry in Appended Table 1 of the Export Trade Control Order and the Foreign Exchange Order table. It is supporting evidence behind classification reports and non-applicability certificates.
• In the determination column, the final box is the only place where circle means controlled and cross means not controlled. Partial boxes, exclusion boxes, and intermediate marks have different jobs.
• The current edition is the February 2026 edition, updated for the ordinance amendments effective February 14, 2026. Listed prices as of July 2026 are 4,400 yen for supporting members and 8,800 yen for general and university members, tax included.
• You cannot download a blank Excel version for free. CISTEC holds the copyright. The electronic file is sold through its classification section.

If you want a quick read on your broader export control posture before diving into the form, try the free export compliance check. It takes about three minutes.

Comparison table, parameter sheet, or classification report

Three documents get mixed up constantly. Here is the practical map.

Aspect	Item-specific comparison table	Parameter sheet	Classification report
What it is	Checklist covering every entry in Appended Table 1 and the Foreign Exchange Order table (CISTEC format)	Spec-entry checklist specialized for a product field	The document that records and presents the classification conclusion
Coverage	Every entry, Items 1 through 15	By field, such as machine tools, computers, or telecom	One per item of goods or technology assessed
Role	Supporting evidence for the determination	Supporting evidence for the determination	Conclusion document built on the table or sheet
Best suited for	Items with no parameter sheet, or first-time classifications	Products in a field that has a sheet	Submission to customs or counterparties, internal sign-off
Where to obtain it	CISTEC (paid)	CISTEC and JMC (paid)	No statutory format; prepared in-house

The comparison table and the parameter sheet are investigation tools. The classification report and the non-applicability certificate are communication documents. You check the control lists with the table or sheet, summarize the result in a classification report, and, if the product is not controlled, present a non-applicability certificate to a counterparty or customs. That is the standard flow. For the certificate side, including a completion checklist, see our complete guide to classification reports and non-applicability certificates.

Choosing between table and sheet is simple in principle. A parameter sheet places regulatory thresholds and product specifications side by side, so machine tools, computers, and other sheeted fields go faster there. For an item with no parameter sheet, or a new product where you cannot yet guess which entries might apply, use the comprehensive comparison table across Items 1 through 15. The two are not competitors. Think breadth versus speed.

A pattern we see often: first classification on the full comparison table, later model changes managed with a parameter sheet for the delta only. Validity of the result does not depend on which form you used. Validity does depend on using a current edition. An old form means an old control list.

One more premise. Whichever form you use, the party responsible for classification is the exporter. METI will explain how to interpret the regulations. It will not classify your specific product for you. The comparison table is not a service that classifies on your behalf. It is a tool for preserving, in a form a third party can verify, the process by which the exporter classified under its own responsibility. Once that sinks in, the detail in the completion rules stops looking pedantic.

Current CISTEC edition, how to buy it, and the Excel question

As of July 2026, the current edition CISTEC distributes is the “Item-Specific Comparison Table, February 2026 edition, for Appended Table 1 of the Export Trade Control Order and the Foreign Exchange Order table.” The sales page states that it reflects the partial-amendment order and related ordinance amendments that took effect on February 14, 2026².

Purchase category	Price (tax included)	Before tax
Supporting members	4,400 yen	4,000 yen
General and university members	8,800 yen	8,000 yen
Via Amazon	8,800 yen	8,000 yen

These are listed prices as of July 2026. Confirm current price and formats on the CISTEC site before you buy. Revisions can change both.

Search traffic loves “comparison table Excel free download.” That path is a dead end. You cannot download a blank Excel version for free. CISTEC holds the copyright. A purchaser may photocopy the pages they need, fill them in, and use them for customs clearance or license applications. Reproducing the table electronically into Word, Excel, or PDF without CISTEC’s permission infringes copyright law³. Copied forms floating around online are risky on that count, and they are often old editions that miss amendments.

The legitimate electronic route is the paid file offered through the “classification section” on CISTEC’s official site⁴. If your company wants digital workflows rather than paper photocopies, that is the correct entry point.

Materials for learning the form are free. On the same sales page you will find “Explanation of the Comparison Table and Completion Guide (PDF)” and “Sample Comparison Table Entries (PDF)”³. The completion guide is the primary source for every symbol rule below. Acquisition usually follows five steps.

1. Open the item-specific comparison table page in CISTEC’s publications section.
2. Confirm whether your company is a supporting member.
3. Order the paper form through CISTEC’s book purchase process, or via Amazon if you need speed.
4. If you need the Excel electronic file, buy it through the classification section of CISTEC’s integrated database.
5. Download the free completion guide and sample-entry PDFs and read them before anyone fills a box.

Edition lag is the quiet failure mode. The comparison table was revised in October 2025 for catch-all control amendments⁵ and again in February 2026 for the ordinance amendments. Two revisions in roughly six months. Every legislative change moves entry numbers and ordinance provisions around. An old form lacks rows for new controlled items. A missing row cannot be checked, no matter how careful the staffer is. Any company with ongoing classification work needs a version-management rule: who confirms the current edition, when, and who swaps internal forms.

For CISTEC as an organization and what supporting membership buys you, see our guide to CISTEC and its membership benefits. If you run several classifications a year, membership often costs less overall than repeated general-price purchases.

Determination-symbol rules from CISTEC’s guide

This is the section I most want classification staff to read carefully. Many explainers stop at “circle means controlled, cross means not controlled, dash means out of scope.” That is incomplete. CISTEC’s completion guide assigns different roles to different brackets, and the same circle can mean different things depending on where it sits³.

Bracket	Name	Role
Final determination box	Closed double brackets	Filled last after weighing partial and exclusion determinations. Circle here means controlled. Cross means not controlled.
Partial determination box	Square brackets	Step-by-step determination on the way to the final call
Exclusion determination box	Double angle brackets	Judgment on an “except for …” exclusion. When this box is a circle, the partial determination in the same section normally becomes a cross
Exclusion partial box	Single angle brackets	Step-by-step determination leading to the exclusion call

Enter a circle when the product meets what the regulation specifies, but a circle anywhere other than the final determination box does not immediately mean “controlled.” It is an interim mark: this stage’s condition was met. A cross goes where the product does not meet the specified figure or function. A dash goes where the product is plainly different from what is specified and could never be in scope.

The difference between cross and dash trips people up. CISTEC’s guide uses a measuring-instrument example. If the item being classified is not a measuring instrument at all, enter a dash. If it is a measuring instrument but its figures fall short of the control threshold, enter a cross. Same visual neighborhood, different legal posture. One case never entered the ring. The other entered and failed the bar.

Exclusion reading is the other place outcomes reverse. Where the text says “provided that … is excluded,” use the exclusion box to judge whether the exclusion applies. When it applies and the exclusion box becomes a circle, the partial determination under the same section marker normally becomes a cross³. The product drops off that branch of control. If the exclusion conditions are not met, keep judging under the main conditions. Get this backwards and you will classify as controlled a product that should be excluded, or the reverse.

The word “except” in the text comes in three patterns in the guide. “Except for other goods” means the item is judged under a different entry, so not here. “Except (iii)” means it is judged under sub-item (iii) of the same entry number. “Except Article 5, item (x)” means refer to that ordinance provision. Do not short-circuit to “excluded, therefore not controlled.” Follow through to where the item is classified instead.

How conditions connect also follows symbol rules. Section markers that stand for “and” are AND conditions. You advance toward controlled only when every condition in that section is met. Markers that stand for “or” are OR conditions. You advance if even one applies. Reading “meets all of the following” versus “meets any of the following” maps to those markers.

And the principle the completion guide repeats: do not stop at the symbol. In each entry box, write the reasoning or figures that let any ordinary reader judge the classification. For a numerical control, answer with a number. Where you mark something not controlled or out of scope, state the reason unless it is already obvious from other entries. Customs or METI officers should be able to reconstruct “why this determination was reached” from the form alone. A table that is only a row of circles and crosses invites the question “did you really check?” even when the conclusion is right. It also fails accountability in an audit.

Six-step completion workflow and a filled-in sample

1. Identify what you are classifying. Distinguish goods from technology first. Pin down product name, model number, and revision. Design drawings, software, and manuals that travel with the hardware need separate technology classifications.
2. Confirm the edition of the form. Check for the February 2026 edition. Swap older forms before anyone starts classifying.
3. Narrow candidate entries. Before scanning Items 1 through 15 in order, use METI’s goods and technology matrix to keyword-search likely entries⁶. See our guide to using the METI matrix.
4. Compare ordinance provisions against your parameters. Match control thresholds in the goods ordinance against product specifications one by one⁷. Watch “not more than” versus “less than,” and unit conversions.
5. Enter determination symbols. Fill partial and exclusion determinations first, final determination last. Always write reasoning and figures next to the symbol.
6. Overall determination, approval, and recording. If every entry is non-applicable, record “not controlled” for the product as a whole, note classification date and responsible classifier, obtain internal approval, and store the form with supporting evidence.

What does a completed table look like in practice? Take an industrial image-processing module carrying two FPGAs. The real CISTEC form breaks rows to individual ordinance wording, so treat the table below as a simplified structural image.

Entry (Appended Table 1)	Goods covered	Ordinance provision	Classification criteria	Product specification	Determination
Item 7 (1)	Integrated circuits	Article 6, item 1 of the goods ordinance	Specified characteristics such as radiation hardening	Commercial-grade FPGA; does not meet specified characteristics	Cross
Item 7 (10-2)	Modules, assemblies, or equipment incorporating FPLDs	Article 6, item 10-2 of the goods ordinance	One or more user-configurable FPLDs, aggregate LUT input count of 1,800,000 or more	Two FPGAs; aggregate 1,440,000, below threshold	Cross
Item 8 (1)	Computers and the like	Article 7 of the goods ordinance	Criteria such as adjusted peak performance	Contains no computer meeting the criteria	Dash
Item 10	Sensors and the like	Article 9 of the goods ordinance	Criteria such as specified photodetectors	Contains no covered photodetector	Dash
Overall determination					Not controlled

Open the Item 7 (10-2) branch to the determination-box level and the bracket rules become visible.

Determination box	Type	What the text requires	Determination	Entry box (reasoning and figures)
Partial	Partial determination	Being a module, electronic assembly, or piece of equipment	Circle	Qualifies as an industrial image-processing module
Partial	Partial determination	Incorporating one or more user-configurable FPLDs	Circle	Carries two commercial-grade FPGAs
Partial	Partial determination	Aggregate LUT input count of 1,800,000 or more	Cross	120,000 LUTs × 6 inputs × 2 devices = 1,440,000, below threshold
Exclusion	Exclusion determination	Except those fixed to a specific function and not rewritable	Cross	Users can still rewrite the logic after shipment, so exclusion does not apply
Final	Final determination	Overall for Item 7 (10-2)	Cross	Aggregate LUT input count below 1,800,000, so not controlled

Partial circles for “is equipment” and “incorporates an FPLD” do not make the product controlled. The numerical partial determination was a cross, so the final determination is a cross. The exclusion box is also a cross because this product is not fixed and unrewritable. Non-applicability here is driven by the numerical threshold, not by exclusion rescue. The entry box keeps the concrete figure 1,440,000. That is what the completion guide means by reasoning any reader can check.

The calculation is the sum of number of FPLDs × LUTs per device × inputs per LUT. In this example, 2 × 120,000 × 6 = 1,440,000, short of 1,800,000. METI’s explanatory material shows a worked case where 2 × 150,000 × 6 lands exactly on 1,800,000⁸. Pull LUT and input counts from the FPGA vendor’s datasheets before you classify.

The form covers technology as well as goods. If you provide design drawings, control software, or maintenance manuals overseas with the equipment, finish the corresponding technology entries on the Foreign Exchange Order side. Goods non-applicable and technology controlled is a combination we see routinely. On the technology side, CISTEC’s guide has you write technical content and a control number in the item-name box, for example “design drawings for the XYZ pump, No. T00012.”

This cross-referencing is slow, careful work. Hundreds of control entries against product specs, symbol and reason for each bracket. TRAFEED, the export control AI agent we build, supports candidate-entry extraction from product specifications and drafting of threshold comparisons. What the system produces is a cited draft. Your export control officer still makes the final determination. That line is fixed under the law, and it should stay fixed. Whitepapers in our resource library are useful if you are redesigning the classification workflow itself.

What the 2026 amendment changed in the table

On November 11, 2025, the Cabinet approved an order partially amending the Export Trade Control Order. It was promulgated on November 14, and the portions implementing international regime agreements took effect on February 14, 2026¹. The February 2026 comparison table is that amendment reflected in the form. METI’s overview of the amendment highlights three added items that matter for table work⁹.

Added goods	New or added entry	Summary
Equipment for synthesizing peptides	Item 3-2 (2) 10	Equipment usable in pharmaceutical research and also divertible to biological weapons production pathways
High-entropy alloy powders and refractory metal powders	Item 5 (20)	Multi-element alloy powders for advanced uses such as jet-engine components
Modules, assemblies, or equipment incorporating FPLDs	Item 7 (10-2)	Aggregate LUT input count of 1,800,000 or more and user-configurable

The largest practical impact is FPGA-embedded equipment. Standalone FPGAs as integrated circuits were already controlled under Item 7. This amendment extends control to the equipment level for products that carry an FPGA. Article 6, item 10-2 of the goods ordinance requires three things: being a module, electronic assembly, or piece of equipment; incorporating one or more user-configurable FPLDs; and having an aggregate LUT input count of 1,800,000 or more⁸. Devices whose embedded FPLD is fixed to a specific function are excluded. Whether the design lets the user rewrite the logic is the practical dividing line. In the sample above, the exclusion box was a cross because the design remained rewritable.

From the comparison table’s standpoint the change is blunt. Old editions have no row for Item 7 (10-2). Keep classifying on an old edition and this control never enters the field of view. FPGAs sit in industrial machinery, measurement instruments, and communications gear. Electronics companies should swap in the February 2026 edition and inventory FPGA-bearing products at the bill-of-materials level for reclassification.

• Does your product line include any module or equipment carrying an FPGA or FPLD?
• Checking datasheet LUT and input counts, does any product’s aggregate reach 1,800,000 or more?
• Do you ship any product in a state where the user can rewrite the logic circuit?
• Do you handle peptide synthesizers, high-entropy alloy powders, or refractory metal powders?
• Are any past classification reports based on a form or regulation predating February 14, 2026?

For the full amendment picture, including FPGA control requirements, exclusions, and transitional arrangements, see our complete guide to the partial amendment of the Export Trade Control Order (effective February 2026).

One more freshness note. 2026 amendments are not limited to February 14. CISTEC’s list of ordinance amendments records a June 16, 2026 partial amendment on reporting items for transactions that provide critical managed technology under Article 10, paragraph 3 of the Ministerial Ordinance on Trade-Related Invisible Transactions¹⁰. That change concerns reporting around so-called deemed exports. It does not rewrite the comparison table rows, but companies running technology-transfer management in parallel should treat it as the most recent 2026 amendment on that track. “Table is current, therefore we are safe” is the wrong mental model. List controls and technology management are both moving.

These revisions will not stop. Japan’s list controls domesticate agreements from international regimes such as the Wassenaar Arrangement. When regimes add agreements, the order, the ordinances, and the comparison table revise in lockstep. Buying a comparison table once and using it for years is structurally impossible in this domain.

Common failures, reclassification checklist, and close

Four failure patterns show up repeatedly in classification consultations.

First, misreading brackets. A circle outside the final box does not mean controlled. An exclusion circle normally flips the partial determination in the same section to a cross. Confusing “meets all of the following” with “meets any of the following” is the same root mistake. On numerical criteria, “not more than” and “less than” treat the boundary differently. Unit-conversion slips between micrometers and millimeters sound trivial until they appear in a real audit file.

Second, writing only the symbol. Skip the reason and you cannot explain yourself at customs or in an audit, even if the conclusion is right. Half the value of the table is the trail.

Third, checking too narrow a range. “We make telecom gear, so Item 9 is enough” is a dangerous assumption. Telecom products can also fall under Item 7 (electronics), Item 8 (computers), and Item 15 (encryption). Finishing only the goods determination and forgetting technology that travels with it is just as common.

Fourth, over-relying on someone else’s determination. A component maker’s non-applicability certificate is important input. Final classification responsibility still sits with the exporter. Verify the content under your own responsibility. An unlicensed export triggered by a wrong determination is a Foreign Exchange and Foreign Trade Act violation, with penalties and public disclosure risk. METI’s analysis attributes the majority of Act violations to classification failures. Details are in our analysis of violation cases and our guide to penalties under the Act.

If you want to reduce person-dependent mistakes, AI drafting is a realistic option for candidate extraction and threshold comparison. TRAFEED is built for that workflow and holds a patent for its classification technology (Japanese Patent No. 7862062). It is used by universities and companies that need structured drafts with cited grounds. The human export control officer remains the final decision-maker. If you also need U.S. EAR cross-checks, start with EAR99: How to Confirm Whether an Item Qualifies.

To summarize the operating points:

• The item-specific comparison table is supporting evidence for classification. Classification reports and non-applicability certificates are the conclusion documents.
• Read each bracket type on its own terms. Write reasoning and figures beside every symbol, not just the mark.
• Use the February 2026 edition. Confirm price and format on CISTEC before purchase.
• Do not use unauthorized free Excel blanks. Buy the electronic file through CISTEC’s classification section if you need digital forms.
• Reclassify FPGA-bearing products after the February 14, 2026 amendment, and track parallel technology-management amendments such as the June 16 deemed-export reporting change.

Running the comparison table is unglamorous work. It is also the work that protects the company. For concrete questions about restructuring your classification flow, starting FPGA reclassification, or standardizing bracket reading across sites, tell us in a 30-minute TRAFEED consultation. The feature overview is in the TRAFEED product catalog (PDF), and other whitepapers are in the resource library.

References (primary sources)

Footnotes

1. METI, Cabinet Decision on the Order Partially Amending the Export Trade Control Order (November 11, 2025) — https://www.meti.go.jp/press/2025/11/20251111001/20251111001.html ↩ ↩²

2. CISTEC, sales page for the Item-Specific Comparison Table, February 2026 edition — https://www.cistec.or.jp/publication/shoseki/b01_taihihyou.html ↩ ↩²

3. CISTEC, Explanation of the Comparison Table and Completion Guide — https://www.cistec.or.jp/publication/shoseki/sample/b-01koumoku_kinyurei/3-taihihyou_kinyuyouryou.pdf ↩ ↩² ↩³ ↩⁴

4. CISTEC, Classification Section (paid provision of the electronic file) — https://www.cistec.or.jp/about/sdintro/koumokuIndex.html ↩

5. CISTEC, Item-Specific Comparison Table, 2025 revised edition, accompanying the partial amendment of catch-all controls — https://www.cistec.or.jp/publication/251010kaisei_taihihyo.html ↩

6. METI, introduction page for the goods and technology matrix — https://www.meti.go.jp/policy/anpo/matrix_intro.html ↩

7. Ministerial ordinance specifying goods or technologies under Appended Table 1 of the Export Trade Control Order and the Foreign Exchange Order table (e-Gov Law Search) — https://laws.e-gov.go.jp/law/403M50000400049/ ↩

8. METI, explanatory material on the security export control amendments under the Foreign Exchange and Foreign Trade Act (December 2025) — https://www.meti.go.jp/policy/anpo/20251114koufu_setsumeishiryou.pdf ↩ ↩²

9. METI, Overview of the Amendments to the Export Trade Control Order and Related Ordinances (November 2025) — https://www.meti.go.jp/policy/anpo/law_document/seirei/20251114_gaiyo01.pdf ↩

10. CISTEC, List of Ordinance Amendments (partial amendment to reporting items for critical managed technology, effective June 16, 2026) — https://www.cistec.or.jp/export/express/index1.html ↩