Japan's Export Control Public Comment: Every Change in the Comparison Tables, Explained

Hello, this is Ryuta Hamamoto from TIMEWELL.

On October 19, 2026, Japan's Ministry of Economy, Trade and Industry (METI) opened a public comment on "draft cabinet order and related amendments to the Foreign Exchange Order and the Export Trade Control Order." Comments are due by Wednesday, November 18, which is 12 days from today¹. News coverage and industry mailings call it "the FEFTA public comment," but strictly speaking the draft does not rewrite the Foreign Exchange and Foreign Trade Act (FEFTA) itself. It revises four kinds of rules that sit beneath the Act: cabinet orders, ministerial ordinances, a notice and circulars.

When I opened the materials, the old-and-new comparison tables alone ran to about 110 pages: 7 pages for the cabinet orders, 60 for the ministerial ordinance, 6 for the notice and 36 for the circulars. The ordinance and the notice are in vertical Japanese text, with the "amended" version stacked above the "current" one and underlines marking only the words that change. Even a seasoned export control officer will struggle to read all of it in one sitting.

So I read the comparison tables to the end and sorted out what differs from the rules that took effect on February 14, 2026, which I call the "February rules" in this article. I start from the basic structure, so readers who are new to Japanese export control can follow along. One premise matters more than any other: these are drafts. The content may change after the comments are reviewed, and neither the promulgation date nor the effective date has been set.

I covered the background since February and the likely timeline to enforcement in an earlier article. This time I go through the ordinance and circular comparison tables that the earlier piece could not cover in full.

Key points

• The drafts amend cabinet orders, ministerial ordinances, a notice and circulars, not FEFTA itself. The comparison tables run to about 110 pages, and the actual changes go well beyond the four items listed in the summary of the announcement.
• For goods, the threshold for nucleic acid synthesizers drops from 1.5 kilobases to 0.5 kilobases. A new category is added for processors aimed at data centers. Additive manufacturing equipment for making explosives and similar items also becomes controlled.
• Some things drop out of control: underwater lighting equipment and underwater observation equipment, and certain performance tiers of analog-to-digital converters. Coverage widens in some places and narrows in others.
• Controlled technology (the Foreign Exchange Order appended table) also gains new categories for communications, marine, propulsion and explosive countermeasure items.
• On procedures, calibration and inspection join repair under the re-export exemption, and the performance reporting for general bulk licenses is revised.
• Comments can be submitted until November 18. The draft ministerial ordinance would take effect on the day two months after promulgation.

Background you need first

How FEFTA, cabinet orders, ministerial ordinances, notices and circulars fit together

FEFTA is the statute that sets the basic rule: to export controlled goods, or to provide controlled technology to a party abroad, you need permission from the Minister of Economy, Trade and Industry. Which goods and technologies are controlled is not written in the Act. It is written in the rules beneath it.

Those lower-level rules are what the drafts amend. Here is the hierarchy.

Type	What it decides	Main amendments in these drafts
Act (FEFTA)	The basic rule that permission is required	Not amended by these drafts
Cabinet orders (Export Trade Control Order, Foreign Exchange Order)	The controlled items (appended tables) and the skeleton of procedures	Additions and deletions of items, prohibition on settlement before approval, definition of goods temporarily landed for foreign destinations
Ministerial ordinance (METI Ordinance on Goods and Technologies, the Goods Ordinance)	Concrete numbers and specifications for each item	Threshold changes, rewritten definitions, new categories
Notice	Matters the Minister designates individually	Eligible goods under the re-export exemption
Circulars	The ministry's operating practice, interpretation of terms, application forms	Interpretations of terms, handling of general bulk licenses, region classification table

The Export Trade Control Order is shortened to the "Export Order," and the Foreign Exchange Order to the "Exchange Order." Goods are listed in Appended Table 1 of the Export Order, and technology in the appended table of the Exchange Order, both under item numbers 1 through 16. If you want the full list of items, I have a separate walk-through of Appended Table 1 of the Export Order.

The item numbers used in this article

Here are the item numbers that appear below, with a rough description of each field.

Item	Rough field
Item 2	Nuclear-related
Item 3	Chemical weapons-related
Item 3-2	Biological weapons-related
Item 5	Advanced materials
Item 6	Materials processing
Item 7	Electronics (components, semiconductors)
Item 10	Sensors and lasers
Item 12	Marine-related
Item 13	Propulsion
Item 16	Catch-all (the broad control over goods not on the list)

Checking whether a product is controlled is generally called classification (gaihi hantei in Japanese, literally "does it fall under the list or not"). You compare your product with the numbers and specifications in the ministerial ordinance and decide which item number, if any, it matches. When numbers or definitions move, as they do in these drafts, the result of that classification can change for some products.

What a public comment is

When a Japanese government body amends a cabinet order or a ministerial ordinance, it publishes the draft and asks the public for opinions. That is the public comment procedure. The ministry then decides the final content in light of what it received and promulgates it. A public comment is one of the last steps before a draft is finalized. Individuals and companies alike may submit. The ministry does not answer each comment individually, and the guidelines say comments are used "as reference in making the final decision"².

A map of what was published

The four documents

The public comment covers four kinds of documents together¹.

The cabinet order amends the Foreign Exchange Order and the Export Order. The ministerial ordinance amends the Goods Ordinance. The notice amends the notice on gratuitous re-exports and related matters. The circulars are four documents: the circular on operating the Export Order, the circular on technology provision, the circular on documents to be submitted, and the general bulk license handling guidelines.

The comment guidelines summarize the purpose of the amendments in three points².

The first is to reflect agreements reached in the international export control regimes, and Japan's position as a responsible technology holder in the international context. Items are added to and deleted from Appended Table 1 of the Export Order and the appended table of the Exchange Order. The guidelines give these examples: adding nucleic acid synthesizers and deleting equipment that only joins nucleic acids; adding additive manufacturing equipment for producing explosive devices; changing "sampling oscilloscopes" to "real-time oscilloscopes"; and deleting underwater lighting equipment. On the technology side, technologies for molded articles that use inorganic fibers, transmission communications equipment, submarines, soundproofing equipment for ships, air cushion vessels and equipment that jams improvised explosive devices are added.

The second is to add items to the list excluded from the prohibition on settlement before approval. The third is to revise the definition of goods temporarily landed for foreign destinations.

One important point here. The summary in the guidelines gives only the main examples under those three purposes. When I read the comparison tables to the end, the ministerial ordinance alone had dozens of changes, and the circulars contained many amendments that the summary never mentions. In this article I write from the comparison tables, covering items that appear in the summary and items that do not.

The effective date can be read from the supplementary provisions

The announcement does not state an effective date. The supplementary provisions of the draft ministerial ordinance, however, say it takes effect on the day two months after promulgation. They also contain a preparatory provision: even before the effective date, you may apply for permission for goods and technology defined under the amended appended tables. The draft notice takes effect on the day of promulgation³⁴.

The promulgation date has not been published. As I covered in another article, the previous regular amendment took about six weeks from the end of the comment period to promulgation. This time may not match that, so I cannot give a timeline. What can be said is that, once promulgated, the draft ordinance would leave roughly two months before it takes effect.

How controls on goods change, item by item

This is the main part. I go through the goods-side amendments in item-number order, and I label each change as widening, narrowing or rewording. Those labels are my own reading of the comparison tables. Whether a given product is actually affected depends on the full text of the provisions and on your own product's specifications.

Item 2: turboexpanders (narrower in one way, wider in another)

A turboexpander cools a very cold gas by expanding it, and is used with hydrogen and similar gases. The current text covers units "designed to operate at temperatures of minus 238 degrees Celsius or below, with a hydrogen discharge of 1,000 kilograms per hour or more." The draft adds a lower bound, so the temperature range becomes "minus 258 degrees or above and minus 238 degrees or below." The gas changes from hydrogen to "hydrogen or helium." The temperature band is narrower and the gas coverage is wider, so this one moves in both directions³.

Item 3: chemical weapons-related

"Tetraethylguanidine" is added to the list of precursor materials for military chemical agents³.

Item 3-2: biological weapons-related (wider)

Item 3-2 contains a cluster of changes⁵³.

The biggest is for nucleic acid synthesizers. Nucleic acids are DNA and RNA, the molecules that carry genetic information. The current text covers automated equipment designed to produce, in a single run, nucleic acid of continuous length exceeding 1.5 kilobases with an error rate under 5 percent, whether by synthesis or by joining nucleic acids. A kilobase is a unit equal to 1,000 bases, a measure of the "number of letters" in DNA.

The draft lowers the length to continuous nucleic acid exceeding "0.5 kilobases." It also removes the conditions "in a single run" and "with an error rate under 5 percent" from the text. The threshold falls to one third and there are fewer conditions, so more equipment is likely to be caught. The wording of the equipment also changes to "equipment that performs nucleic acid synthesis" and "equipment that performs nucleic acid synthesis together with joining," and equipment that only joins is no longer described.

Other changes in this item: fermenters are narrowed by adding a purpose, so that only those "that can be used to culture microorganisms or living cells for producing viruses or toxins without aerosol dispersion" are covered. Cross-flow filtration equipment is likewise described as "usable for separating microorganisms, viruses, toxins or cell cultures," and the wording of the excluded blood-related equipment changes to "designed for medical blood filtration." The circulars add an interpretation that this medical blood filtration means hemodialysis and plasma exchange⁶.

Items 5 and 6: advanced materials and additive manufacturing (wider)

Item 5 gains a new entry for additive manufacturing equipment used to make explosive devices, pyrotechnics, propellant devices, or molded articles of explosives, pyrotechnics or propellants. Additive manufacturing is what is commonly called 3D printing. The draft ordinance is specific: it covers additive manufacturing equipment designed or modified to make explosive devices and similar items from energetic materials, and that has at least one ultrasonic extruder or ultrasonic nozzle. The circulars add a definition of "energetic materials" as substances or mixtures that undergo a chemical reaction to release the energy needed for a given use. Additive manufacturing equipment in Item 6 now carries the wording "excluding those listed in the middle column of Item 5," which sorts out the overlap⁵³⁶.

Item 5 contains other changes too. Equipment for producing silicon carbide fibers was described as one type: equipment that chemically vapor-deposits elements or compounds onto a heated filament-form substrate. The draft rewrites this as "equipment for chemical vapor deposition," and adds a second category, "equipment for producing multiple parallel fibers by laser-driven chemical vapor deposition."

In the definitions of filament winding equipment and similar machines, the phrase "primary axis (limited to those operated by servo control)" is replaced by "primary servo positioning axis." The counts (3 or more, 5 or more, 2 or more) do not change, so this is a tidying of terminology. The circular's interpretation of "servo positioning" is rewritten alongside it.

The definition of fibers used to reinforce ceramic-matrix composite materials is also rewritten. The current text defined them by "excluding" fibers that fall short of certain performance. The draft states the conditions in the affirmative, as "meeting all of the following": tensile strength of 700 megapascals or more, and creep strain of 1 percent or less after 100 hours under a given load. The numbers themselves are the same. Mullite is now named explicitly as an aluminum oxide-based material.

Item 7: electronics (wider in places, narrower in places, rewording)

Item 7 has the largest number of changes in this draft³⁶.

The most closely watched is a new category for digital processor units. The current text covers units with a total processing performance (TPP) of 6,000 or more. TPP is a measure of a processor's computing capability. In the draft, that 6,000-or-more tier stays as (1), and a new (2) is added: "TPP of 1,600 or more and less than 6,000, with a performance density of 5.92 or more." Units not designed for use in a data center are excluded.

The circulars add two definitions. Performance density is TPP divided by "applicable die area" (in square millimeters). A data center is a structure that houses, interconnects and operates information technology and network communications equipment in one place, with power distribution and environmental control. In plain terms, the new category catches processors for data centers that have somewhat lower TPP but pack high performance into a small area.

For primary cells, the continuous power density threshold rises from "more than 350 watts per kilogram" to "more than 500 watts per kilogram." The energy density condition does not change. The coverage narrows.

Rotary-input absolute encoders are components that detect the angle of a rotating shaft with high precision. The current text covers units with "an absolute value of angular conversion error of 1 second or less." The draft splits this into two tiers: (a) inductive type, with digital output, an outer diameter of 40 millimeters or less and a resolution of 16 bits or more, and (b) accuracy of 1.0 arc-second or less. Tier (a) is new, and small digital-output units become newly controlled. The circulars also add a definition of "accuracy."

Power semiconductors are devices that control and rectify electric power. The current text required a product to meet all three conditions, such as "a maximum operating junction temperature above 215 degrees" and "a repetitive peak off-state voltage above 300 volts." The draft divides products by whether the rated maximum operating junction temperature is above or at or below 215 degrees, and attaches voltage, current and bandgap conditions to each. The tier above 215 degrees requires more than 300 volts and a continuous current above 1 ampere. The tier at or below 215 degrees requires three conditions: more than 5,000 volts, a continuous current above 1 ampere, and a bandgap above 2.0 electron volts, and it includes devices made of silicon carbide, gallium nitride and gallium oxide. The consumer-use exclusion also widens, from the current "automobiles, railway vehicles and aircraft" to equipment used for "power transmission and distribution or energy conversion." Because the conditions are rearranged, some products move in one direction and some in the other.

For analog-to-digital converters (circuits that turn an analog signal into a digital one), the performance tier of "resolution of 8 bits or more and less than 10 bits, with a sample rate above 1.3 gigasamples per second" is deleted in three places. The coverage narrows.

For oscilloscopes, "sampling oscilloscope (using a real-time sampling technique)" becomes "real-time oscilloscope." The circular's interpretation is changed in the same way. I see no change in numbers, so I read it as terminology cleanup.

Organometallic compounds are compounds of aluminum, gallium, indium and similar elements. The current text covered only those "with a purity exceeding 99.999 percent." The draft states that the purity is on a "metal basis" and adds a condition that the element must be directly bonded to a carbon atom in the organic part of the molecule. Organic compounds of phosphorus, arsenic and antimony are treated the same way, with purity stated on an "inorganic element basis" and the same direct carbon bond condition. Since the conditions increase, coverage tends to narrow. The same definition that was in the circulars moves into the ordinance and is deleted from the circulars.

Item 10: sensors and lasers (many moving numbers)

Optical fibers for sensing were described in the current text as "for measuring sound, temperature, acceleration, electromagnetic fields or radiation." The draft rewrites this as fibers "specially made, by composition or structure, or modified by coating, to be sensitive to sound, temperature, acceleration, electromagnetic fields or radiation," and excludes fiber Bragg gratings designed to sense temperature that have a maximum sensing temperature below 150 degrees and a minimum sensing temperature above minus 100 degrees³.

Two categories of electronic cameras gain the exclusion "excluding those that fall under item (4)," which sorts out overlap.

Lasers have several numerical changes. For single transverse mode continuous-wave lasers designed for the wavelength range above 975 nanometers and up to 1,150 nanometers, the rated output threshold rises from "above 1,000 watts" to "above 2 kilowatts." In the same range, a new category is added: rated output above 1.5 kilowatts with a spectral bandwidth of 40 gigahertz or more and less than 100 gigahertz. For multiple transverse mode lasers, the category "wall-plug efficiency above 18 percent and rated output above 1,000 watts" is deleted, and "rated output above 2 kilowatts" becomes "rated output above 3 kilowatts." For some lasers with wavelengths above 1,400 nanometers, a new exclusion covers units with average or continuous-wave rated output above 1 watt and up to 10 watts, power consumption of 250 watts or more, and total weight above 50 kilograms.

The circulars also reorganize the tiers used to exclude industrial laser oscillators. The current text split rated outputs from above 1.0 kilowatt to 10.0 kilowatts or less into six tiers, each with a beam parameter product condition. The draft deletes three of these tiers, covering above 1.0 kilowatt up to 3.3 kilowatts, and consolidates into three: above 3 kilowatts up to 12 kilowatts (beam parameter product above 3.2), above 12 kilowatts up to 20 kilowatts (above 3.9), and above 20 kilowatts up to 40 kilowatts (above 5). You have to read the numbers in the ordinance and the circulars together. Companies that make or sell lasers should check again which output band and beam quality their products fall in.

Item 12: marine-related (narrower)

Underwater lighting equipment is deleted from control. Two categories disappear entirely: units that use a strobe method, and units that use an argon arc and can be used at depths exceeding 1,000 meters. "Underwater observation equipment," which is mounted on a submersible and operated remotely and was part of the submersible parts and accessories entry, is also deleted. The deletion of lighting equipment appears in the summary in the comment guidelines. The deletion of observation equipment does not, and can be found only by reading the comparison table for the ordinance⁵³.

Item 13: propulsion (rewording)

For parts of launch vehicles and similar items, the definition of composite materials changes from "fiber or resin" to wording that reads as "composite materials made of fiber and resin." The change from "or" to "and" stands out, but whether the scope actually narrows has to be checked against the full text and the provisions it cites.

Summary of movements by item

Here is the same material grouped by direction.

Direction	Main changes
Wider	Nucleic acid synthesizers (3-2), additive manufacturing equipment for explosives and similar items (5), new category for data center processors (7), new category for small encoders (7), new laser categories (10), silicon carbide fiber production method (5)
Narrower	Underwater lighting and observation equipment (12), performance tiers for analog-to-digital converters (7), primary cell power density (7), organometallic compounds (7), turboexpander temperature range (2)
Rewording and tidying	Primary servo positioning axis (5), real-time oscilloscope (7), rewritten ceramic composite definition (5), "and" in composite materials (13)
Moves both ways	Restructured power semiconductor tiers (7), laser output thresholds (10)

How controlled technology changes in the Exchange Order table

Technology controls change too. Controlled technology has its item numbers in the appended table of the Exchange Order, and the concrete content is written in the Goods Ordinance. Typical examples are cases where technology needed for the design, manufacture or use of controlled goods is provided to someone abroad⁵³.

Item 5 adds technology for the use of molded articles made with inorganic fibers. In the ordinance provision for Item 5 technology, the clause that sets out the numbers it refers to adds the clause covering additive manufacturing equipment for explosives.

Item 9 gets a new category: technology for the "use" of transmission communications equipment, wireless transmission equipment for countering improvised explosive devices, and similar items, together with the related programs. Operation is excluded, and the provision is written as five categories: technology needed for use, programs designed for use, programs designed to provide equivalent functions, and so on.

Item 12 adds technology for the use of submarines and for the use of soundproofing equipment usable on ships. The guidelines describe technology for the design or manufacture of air cushion vessels and similar craft as an "addition." Reading the ordinance comparison table, however, the provision on the same vessels' design and manufacture technology in current Item 12(1) appears to move to a new Item 12(4). The vessel types and numbers such as speed read the same as in the current text. Whether coverage actually grows or the provision is simply relocated is, in my reading, closer to the latter, but confirming it requires checking against the Exchange Order text itself.

Item 13 gets a new category. It covers technology needed to design axial compressors for gas turbine engines that meet both of the following. (a) It is specially designed for a multi-flow fan system, or has any one of five features such as feedback control of compressor blade tip clearance. (b) It meets all four calculated values: an average substitute stage loading of 0.22 or more, a sum of the substitute stage loading multiplied by 41.6 and the polytropic efficiency of 102 or more, a stability margin of 20 percent or more, and an average stage pressure ratio above 1.2. The circulars devote several pages to how these terms are calculated and defined.

Item 14 adds a program category in addition to technology. Item 15 adds technology for the use of equipment that jams improvised explosive devices and similar items to perform their intended functions. In Item 11, the wording for the program that "deciphers" the ranging code of a satellite navigation system changes to "decodes."

Changes to procedures and operating rules

So far this has been about what is controlled. The drafts also change how procedures work.

Exceptions to the prohibition on settlement before approval

FEFTA, as a rule, prohibits paying for exports or imports of goods that need permission or approval before that permission or approval is received. This is the prohibition on settlement before approval. There is an exception for goods designated by notice, where the Minister finds that, given the parties and the nature of the goods, payment would not particularly hinder the purpose of the Act. Article 6(5) of the Exchange Order sets the frame for this exception.

The draft adds to that frame the exports described in Article 1(3) of the Export Order. Article 1(3) of the Export Order is the provision that requires permission when goods listed in Item 16 of Appended Table 1 (the catch-all) are exported to the regions in Appended Table 3 (what are often called the preferred-treatment regions)⁵⁷. Within this frame, it may become possible to settle payment for such exports before permission. In practice, only goods the Minister designates by notice would actually be exempt, so the content of that designation has to be checked in a later notice.

Definition of goods temporarily landed for foreign destinations

Temporary landing means unloading goods at a Japanese port or airport and carrying them on to a foreign destination. In the parenthetical of Article 4(1)(i) of the Export Order, which defines "goods temporarily landed for foreign destinations," the wording on the scope in which the definition is used changes, and the reference to Article 4(2)(iii) of the Export Order is removed. The comment guidelines do not explain the purpose of this revision. It looks like a clean-up of cross-references, but whether it has any practical effect should be checked against the final text.

Calibration and inspection join the re-export exemption

The changes to the notice and circulars are especially close to day-to-day operations. Article 4 of the Export Order sets up exemptions from the permission requirement for certain gratuitous exports of goods, and the eligible goods are set by notice. Among them, "goods exported from Japan, repaired in Japan, and then re-exported" covered only "repair" in the current text. The draft widens this to goods re-exported after "repair, calibration or inspection"⁴.

Likewise, the entry on importing and exporting goods used to carry other goods (transport goods such as containers) adds goods imported or exported for the "repair, calibration, inspection or cleaning" of those goods. A new entry covers weapons-related goods that foreign government officials import for use in protection duties and then export once the duties end. The interpretation in the circulars changes in the same direction, with an explanation that it does not matter whether the repair or similar work is free of charge or paid⁶.

If your company ships measuring or inspection instruments from overseas customers to Japan for calibration and sends them back, this is a change that touches day-to-day work.

Handling of general bulk licenses

A general bulk license is a system under which you receive permission for a set of transactions under defined conditions, rather than applying transaction by transaction. The general bulk license handling guidelines in the circulars contain the following changes⁶.

First, the edition of the "foreign end user list" referred to in the conditions for exclusion from the special general bulk license is updated from the version dated January 31, 2025 (Reiwa 7) to the version dated September 29, 2025. Second, for the annual performance report on the provision of design and manufacturing technology under a special general bulk license, the text now says "report even if there was no performance." A note is also added to the report form: if there was none, state so.

In addition, a new condition is added to the special general bulk service transaction license: where a certain notification has been made, you must not conduct the transaction under this license for 14 days from the date the notification is accepted (except where METI has informed you that it has no objection). The item numbers for which transaction records must be kept widen from "Items 2 to 4" to "Items 1 to 4." Other changes include the wording on when a license lapses, revisions to the forms and wording fixes in the notification of a change of the chief responsible officer.

Region classification table

In the table that classifies countries and regions in the attachment to the circulars (the "Nu" region column), Canada and Bangladesh are added. The comparison table of country and region classification in the circular on submitted documents changes in the same way. The materials for this public comment do not show what the "Nu" region category means, so I could not confirm it. If it applies to you, check the current definition of the category in the attachment to the circulars.

More interpretations of terms in the circulars

Much of the circulars' comparison table consists of new or reorganized interpretations of terms used in the ordinance. They include a change to the definition of "contents," terms related to additive manufacturing, the definitions of TPP performance density and data center, the definition of accuracy for absolute encoders, and many calculation parameters for aircraft engine compressors. Even where no numbers move, a change in interpretation can change a classification result. That is why you should read the circulars' comparison tables and not just the ordinance.

How to submit a comment

Comments are due by Wednesday, November 18, 2026. You can submit in one of three ways: the e-Gov comment form, post or email. By post, address it to the Public Comment Officer, Security Export Control Policy Division, Trade and Economic Security Bureau, METI, 1-3-1 Kasumigaseki, Chiyoda-ku, Tokyo 100-8901. By email, use the subject line "Comments on the draft cabinet order amending the Foreign Exchange Order and the Export Trade Control Order" (in Japanese) and attach the comment form. Phone submissions are not accepted².

The comment form has fields for "relevant provision," "comment" and "reasons." If I were writing one, here is what I would keep in mind. Say exactly which item number and which clause you mean. Describe, as fact, how the draft would affect your products and operations. Where possible, attach the sources your argument rests on. Phrase requests in a form the ministry can act on, such as "please show the basis for this number" or "please provide a transition period."

Submitted comments may be made public, except for names (the name of a company or organization), addresses, telephone numbers and email addresses. Passages that could identify an individual or harm a company's property rights are withheld when comments are published².

What your company can do now

Even before the drafts are final, there is useful work to do.

First, identify the products that sit near the item numbers in this draft. Companies that deal with semiconductors, power semiconductors, encoders, lasers, fiber optic sensors, equipment for synthesizing or culturing nucleic acids, additive manufacturing equipment, underwater equipment or gas turbine technology should check with particular care. Look up the current row in METI's Matrix Table and compare it with the comparison tables to see how the draft changes it⁸.

Second, make a list of products you have already classified as non-controlled that sit close to the amended item numbers. If thresholds move, a product that was not controlled can become controlled. In the other direction, some products drop out of control, so the list also helps you prepare to update the explanations you give business partners.

Third, if you handle re-exports or calibration work, check whether the changes to the notice and circulars bear on your transactions.

And keep in mind the sense of timing: "effective two months after promulgation." Once promulgation is announced, the countdown to preparation begins that day.

Closing thoughts

What I felt most strongly after reading these comparison tables was the gap between "a few lines in the summary" and "the actual amendments." The announcement listed four items, but inside the comparison tables there were dozens of changes: moving numbers, new categories, interpretations of terms and procedural changes. In export control, the conclusion is set by an accumulation of precisely these small numbers and definitions.

Another point that practitioners should not miss is that widening and narrowing coexist in the same draft. If you lump it together as "an amendment that tightens controls," you will overlook the narrowing parts that bear on your business, and checks will slip.

The comment deadline is November 18. The more concretely a company understands the effect on its own products, the more useful the opinion it can give the ministry. I hope this article serves as a map as you work through the comparison tables.

If you do not have the capacity to go through the comparison tables or to sort out your classifications, TRAFEED is one option. It is designed to reflect legal changes in each country on the same day, and it helps export control officers organize the grounds for a classification. The final classification remains the responsibility of your company's export control officer. To talk it over, use book a consultation. For the basics of list controls, see the catch-all control explainer, and for the background, my article on the key changes in 2026.

References

Footnotes

1. Public comment on the draft cabinet order amending the Foreign Exchange Order and the Export Trade Control Order — e-Gov Public Comment (case number 595320041) — Security Export Control Policy Division, Trade and Economic Security Bureau, METI; drafts announced October 19, 2026, comments due November 18, 2026 at 17:00; legal basis: FEFTA Article 16(5), Article 25(1) and Article 48(1) (Japanese) ↩ ↩²

2. Public comment guidelines: draft cabinet order amending the Foreign Exchange Order and the Export Trade Control Order — METI — October 19, 2026 (Japanese) ↩ ↩² ↩³ ↩⁴

3. Ministerial ordinance comparison table — draft ordinance amending the ministerial ordinance that sets goods and technologies under the appended tables of the Export Trade Control Order and the Foreign Exchange Order (including supplementary provisions) — METI — October 19, 2026 (Japanese) ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸ ↩⁹

4. Notice comparison table — draft notice amending the goods designated by the Minister of Economy, Trade and Industry under Article 4(1)(ii)(e) and (f) and Article 4(2)(ii)(e) and (f) of the Export Trade Control Order — METI — October 19, 2026 (Japanese) ↩ ↩²

5. Cabinet order comparison table — draft cabinet order amending the Foreign Exchange Order and the Export Trade Control Order — METI — October 19, 2026 (Japanese) ↩ ↩² ↩³ ↩⁴ ↩⁵

6. Circulars comparison table — draft circulars amending the circular on operating the Export Trade Control Order, the circular on technology provision, the circular on documents to be submitted and the general bulk license handling guidelines — METI — October 19, 2026 (Japanese) ↩ ↩² ↩³ ↩⁴ ↩⁵

7. Export Trade Control Order (Cabinet Order No. 378 of 1949), Articles 1, 2 and 4 — e-Gov Legal Database (Digital Agency) — checked November 6, 2026 (Japanese) ↩

8. On classification and the Matrix Table of goods and technologies — METI (Japanese) ↩