Hello, this is Ryuta Hamamoto from TIMEWELL. When I take export-control questions, a surprising number of people are stuck right at the entrance. "Which law, and which table, am I even supposed to be looking at?" No matter how carefully you explain the classification procedure, if the overall picture of the underlying cabinet order isn't in your head, each individual task ends up floating in mid-air.
That foundation is the Export Trade Control Order — the Export Order for short. Japanese export control starts moving the moment you check whether your goods appear in the lists, called appended tables, that this cabinet order provides. But there are appended tables from the first through the seventh, and because tables with similar numbers sit side by side, newcomers almost always get lost.
I wrote this article so you can hold the whole Export Order in your head as a single map. I won't dig into detailed spec values. First, grasp the two pillars: "Appended Table 1 for licenses" and "Appended Table 2 for approvals." Once you have those, the rest of the practical work becomes remarkably clear.
The Export Trade Control Order is the cabinet order that operates the Foreign Exchange Act
The Export Trade Control Order was promulgated on December 1, 1949, as Cabinet Order No. 378 of 1949. Its official abbreviation is the Export Order, which you can confirm as a formal attribute in the statute database as well. It is not a standalone law but a subordinate set of rules positioned to actually operate the Foreign Exchange and Foreign Trade Act — the Foreign Exchange Act (Act No. 228 of 1949).
The Foreign Exchange Act is something like the constitution of export control; it sets only the broad framework. Its Article 48 is the provision that grounds export licenses and approvals. But the text of the law does not contain a concrete list of which goods are covered and which countries are targeted. That gap is filled by the Export Order, and by the appended tables attached to it. The law declares "we regulate," and the cabinet order specifies "these and these items, for destinations like this." This two-tier structure is the skeleton of Japanese export control.
So when you read the Export Order, make a habit of always thinking of it together with Article 48 of the Foreign Exchange Act. Trace the provisions and you see three entrances: license, inform, and approval. Sorting out the differences among these three is the first step toward understanding export control. If you want to first check whether your own framework can even handle these entrances, our free export-control readiness check can map your current gaps in about three minutes.
Article 48 of the Foreign Exchange Act consists of three paragraphs. Paragraph 1 is the basis for the license, received by Article 1 of the Export Order and Appended Table 1. Paragraph 2 is the so-called inform requirement — a provision that lets the government impose a license obligation on those who export specific goods to destinations other than specific regions, in order to ensure regulations are reliably enforced. Paragraph 3 is the basis for approval, established to implement international commitments and the like, and received by Article 2 of the Export Order and Appended Table 2. Different paragraphs mean different purposes. Confuse them here and your later judgment goes off course.
The full map: how Appended Table 1 (license) and Appended Table 2 (approval) divide the work
The Export Order has twelve appended tables in total. Just hearing the number can make you brace yourself, but in practice the first two you face are Appended Table 1 and Appended Table 2. You can safely treat the rest as auxiliary tables that define region categories and exceptions.
The most important point is this: Appended Table 1 and Appended Table 2 are not similar lists that merely differ by number. These two are entirely different regimes with different governing provisions and different purposes, and even the names of the required procedures differ. Because their numbers are adjacent, they look like members of the same family — and that is exactly the first stumbling block. Take in the difference between the two at a glance with the table below.
| Aspect | Appended Table 1 (license) | Appended Table 2 (approval) |
|---|---|---|
| In one line | A national-security list (goods that could be diverted to military use) | A list for honoring international commitments and the like |
| Governing provision | Article 1 of the Export Order + Article 48(1) of the Foreign Exchange Act (item 16 also uses 48(2)) | Article 2 of the Export Order + Article 48(3) of the Foreign Exchange Act |
| Type of procedure | The Minister of Economy, Trade and Industry's "license" | The Minister of Economy, Trade and Industry's "approval" |
| Substance of the regulation | Items 1–15 = list controls, item 16 = catch-all control | Domestic implementation of CITES, the Montreal Protocol, the Basel Convention, the Minamata Convention, UN sanctions, and more |
| Examples of covered goods | High-performance machine tools, semiconductor manufacturing equipment, carbon fiber, lasers, frequency converters, and so on | Diamonds, nuclear source materials, narcotics precursors, endangered species, cultural properties, IP-infringing goods, counterfeit currency, and so on |
| Treatment of destinations | In principle almost all regions (item 16 covers all regions except Group A = Appended Table 3) | Specified in each item's lower column (sanctioned regions such as North Korea and Russia are tightened in Appended Tables 2-2 through 2-4) |
| Starting point in practice | Classification (matching item number × specs in the Goods and Technology Ordinance) | Confirm whether the item is subject to approval, and whether a treaty or other-law permit is required |
Keep this table in the upper-right corner of your mind at all times and you won't get lost no matter which provision of the Export Order you are reading. If you're looking at Appended Table 1, it's a national-security license story; if you're looking at Appended Table 2, it's an international-commitment approval story. Just sorting information onto these two axes cuts the confusion in half.
For good measure, here is how all twelve appended tables divide the work. Appended Table 1 relates to Articles 1 and 4 of the Export Order, and Appended Table 2 relates to Articles 2, 4, and 12. From Appended Table 3 onward, everything relates to Article 4 — that is, to exceptions to licenses and approvals.
| Appended Table | Related provisions | Rough role |
|---|---|---|
| Appended Table 1 | Articles 1 and 4 | Goods subject to license (list controls, items 1–15 + catch-all item 16) |
| Appended Table 2 | Articles 2, 4, and 12 | Goods subject to approval (implementing international commitments and sanctions) |
| Appended Tables 2-2 through 2-4 | Article 2 and others | Goods subject to sanctions-related approval for North Korea, Russia, etc.; region categories for circumvention concerns |
| Appended Table 3 | Article 4 | Group A regions (former "white countries," 27 nations) |
| Appended Tables 3-2 and 3-3 | Article 4 | Region categories such as countries under UN arms embargoes |
| Appended Table 4 | Article 4 | Regions given especially strict treatment |
| Appended Tables 5 through 7 | Article 4 | Exceptions requiring no license/approval, exceptions for accompanied baggage, and the monetary thresholds for the small-value exception |
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Appended Table 1: national-security list controls (items 1–15) and the catch-all (item 16)
Appended Table 1 is the table pointed to by Article 1(1) of the Export Order, which receives Article 48(1) of the Foreign Exchange Act. When you export the goods listed here to a destination in a region shown in the lower column, you need the Minister of Economy, Trade and Industry's license. This is the entrance to security export control — that is, list controls.
Appended Table 1 divides broadly into two zones. Items 1 through 15 are list controls. Weapons, of course, but also nuclear, chemical, biological, and missile-related items, plus dual-use goods that could be diverted to military use — high-performance machine tools, semiconductor manufacturing equipment, carbon fiber, lasers, frequency converters — are defined item by item. The criterion for judgment is not the product name but the specification. Even a product with the same name can reach a different conclusion depending on whether its performance meets the regulatory value. This line-by-line matching is classification; for how to actually carry it out, see What is export classification? The procedure explained on one page.
One thing to watch here: list controls apply regardless of destination. Even for Group A — the former "white countries" — the list-control classification itself is required. For Group A destinations, procedures are merely simplified through exceptions such as comprehensive licenses; it does not mean you may skip the classification. "The other party is a trustworthy country, so nothing is needed" is one of the most dangerous misconceptions in export control.
Item 16 is the catch-all control, which is different in character from the list controls. Article 1(3) of the Export Order provides that when you export the goods listed in the middle column of item 16 of Appended Table 1 to a destination in a region listed in Appended Table 3, a license based on Article 48(2) of the Foreign Exchange Act is required. The lower column of this item 16 reads, in the original text of the cabinet order, "all regions (excluding the regions listed in Appended Table 3)." In other words, the catch-all in principle does not apply to Group A (the 27 nations of Appended Table 3). This geographic line is written into the very text of the cabinet order.
That said, the actual application of the catch-all involves an operational dimension where an individual inform notice from the Minister of Economy, Trade and Industry comes into play. Avoid oversimplifying it as "a catch-all license is always required for anything other than Group A." As a broad framework, it is safest to understand list controls as being about specifications, and the catch-all as a separate net that looks at end use, end user, and destination.
Appended Table 2: export approval to honor international commitments
Appended Table 2 is the table pointed to by Article 2(1) of the Export Order, which receives Article 48(3) of the Foreign Exchange Act. Item 1 provides that when you export goods in the middle column of Appended Table 2 to a region in the lower column, you need the Minister of Economy, Trade and Industry's approval. Whereas the license was for national security, the approval is a regime established so Japan can faithfully implement international commitments it has entered into and contribute to international peace. Both its governing provisions and its purpose are separate from Appended Table 1.
Looking at what is subject to approval makes the character of Appended Table 2 clear. Rough diamonds in item 1 back up the Kimberley Process, an international framework; ozone-depleting substances in item 35 correspond to the Montreal Protocol; specified hazardous waste in item 35-2 to the Basel Act; mercury in item 35-4 to the Minamata Convention; and endangered wild fauna and flora in item 36 to CITES. Appended Table 2 is the list for upholding international commitments domestically.
Even so, it is a mistake to dismiss Appended Table 2 as "an export list for agricultural products and living creatures, unrelated to national security." Items with a strong national-security tint also line up as subject to approval — nuclear source materials and nuclear fuel materials in item 20, narcotics and psychotropic precursors in item 21-3, and so on. Turn to the cultural-property side and you find, in item 43, national treasures, important cultural properties, and natural monuments; in item 44, goods infringing intellectual property rights and goods that misrepresent their origin; and in item 45, goods for which the recognition procedure under Article 69-12 of the Customs Act has been taken. Blood products, shiitake spawn, frozen clams and hard clams, mist nets, and even counterfeit and altered currency — the range of covered items is genuinely broad.
Approval also has mechanisms that involve other ministries and other laws. Article 2(2) of the Export Order provides that to approve item 30 of Appended Table 2 — shiitake spawn — the prior consent of the Minister of Agriculture, Forestry and Fisheries is required. Article 2(3) provides that for the specified hazardous waste subject to the Basel Act in item 35-2(2), and for the national treasures, important cultural properties, and the like in item 43, approval is granted only when a permit or confirmation of export under another law has been obtained. Remember: approval does not always conclude within the Ministry of Economy, Trade and Industry alone.
Chasing whether each of these items applies, and whether another law's permit is required, one case at a time by hand is more grueling than you might imagine. TRAFEED, the export-control AI agent we provide, is a service we built to support exactly this kind of appended-table matching and reflection of each country's laws and regulations. The final classification decision is meant to rest with your company's export-control manager, but it does help speed up the initial legwork of looking things up. You can see how it works on the TRAFEED page.
Appended Table 2-2 through Table 7: a quick read of sanctions, region categories, and exceptions
Behind Appended Table 2 come tables that handle sanctions, region categories, and exceptions. First, the sanctions-related ones. Beyond item 1, Article 2(1) of the Export Order holds many items aimed at sanctions. Item 1-2 covers Appended Table 2-2 for North Korea, item 1-3 covers Appended Table 2-3 for Belarus, item 1-4 covers Russia, and item 1-5 covers the notice-designated areas in the Donetsk and Luhansk regions of Ukraine — a structure in which an approval obligation applies per destination.
Appended Table 2-2 is subject to approval for North Korea, and it lists so-called luxury goods such as beef, caviar, alcoholic beverages, tobacco, perfume, cosmetics, and high-end bags. This exists to give domestic backing in Japan to sanctions based on UN Security Council resolutions. Appended Table 2-4 is a table listing regions such as the United Arab Emirates, Armenia, China, India, Kazakhstan, Kyrgyzstan, Syria, Thailand, Turkey, and Uzbekistan, and it functions as a destination category addressing concerns about circumvention of Russia-related export controls.
The flagship of the region categories is Appended Table 3 — the Group A regions. It is the category long known as the former "white countries," and in the text of the cabinet order as of writing it comprises 27 nations: Argentina, Australia, Austria, Belgium, Bulgaria, Canada, the Czech Republic, Denmark, Finland, France, Germany, Greece, Hungary, Ireland, Italy, the Republic of Korea, Luxembourg, the Netherlands, New Zealand, Norway, Poland, Portugal, Spain, Sweden, Switzerland, the United Kingdom, and the United States. The Republic of Korea returned to Group A in 2023, and the roster of countries shifts through public-notice amendments. Always confirm the country names and count against the latest Appended Table 3. On the stricter side, Appended Table 3-2 defines countries under UN arms embargoes and the like (Afghanistan, the Central African Republic, the Democratic Republic of the Congo, Iraq, Lebanon, Libya, North Korea, Somalia, South Sudan, and Sudan), and Appended Table 4 defines especially strict regions (Iran, Iraq, and North Korea). Because these categories are updated from time to time through public notices and circulars, only the broad framework is shown here. Please treat the details as something to confirm against the latest public notices.
At the same time, not every export carries a heavy procedure. Appended Table 5 covers exceptions where no license or approval is required, including free-of-charge relief supplies, free-of-charge commercial samples and promotional materials totaling 2 million yen or less, and personal effects sent by international mail. Appended Table 6 covers exceptions for accompanied baggage, tools of one's trade, moving household goods, and the like. Appended Table 7 sets the monetary thresholds for the small-value exception, with lines drawn such as 300,000 yen for narcotics and psychotropic precursors, 50,000 yen for blood products, and 30,000 yen for shiitake spawn and frozen clams. It is precisely because these exceptions exist that everyday small-lot exports can realistically keep moving.
What changed with the cabinet-order amendment that took effect on February 14, 2026 (Cabinet Order No. 376 of 2025)
The appended tables are not fixed stone tablets. They are revised nearly every year in response to international export-control regime agreements and treaty amendments. A recent flagship example is Cabinet Order No. 376 of 2025. It was promulgated on November 14, 2025, and took effect on the day after three months had passed from promulgation — that is, February 14, 2026.
Three points of the amendment stand out. First, it added equipment for synthesizing peptides and the like to the goods subject to a license — a move addressing bio-related concerns. Second, it removed juvenile eel (glass eel) from the goods subject to approval. Third, it added certain goods designated by public notice, among those exported without charge on the premise of a planned duty-free re-import, to the exceptions requiring no license. You can see that the direction of adding regulation and the direction of removing it to match reality coexist within the same amendment.
One practical note here. The main effective date of this amendment is February 14, 2026, but there is information that some provisions have a different effective date. Confirm the exact effective date of individual provisions in the Official Gazette or the original text of the cabinet order. As a representative effective date, February 14, 2026, is used here. For transactions that straddle the effective date, the principle is not to ship on the old version's classification but to re-classify under the new, in-force version.
For the record, at the time of writing I could not directly retrieve the Ministry of Economy, Trade and Industry's amendment-summary page or its list of goods subject to approval. The cabinet-order number, promulgation date, effective date, and main content are corroborated against the text in the statute database and similar sources, but please make the final check of the detailed item lists against METI's original sources after this article is published. In export control, sparing no effort on this one step — "reconfirm against the latest version" — is the best insurance of all.
How to check whether your goods apply, and how to start the practical work
Let me bring this map down to actual movement. When you face the Export Order, the first thing to do is look at your goods from both the Appended Table 1 and Appended Table 2 sides. Looking at only one side and feeling reassured is a common beginner's mistake.
For Appended Table 1, you classify by specification, not by product name. Get a sense of the item number, compare the regulatory values in the Goods and Technology Ordinance against your own specs line by line, and record the result and rationale in a classification record. For how to keep the evidence of your judgment, What is a non-applicability certificate? How to write a classification record shows concrete examples. In parallel, confirm whether the goods fall under Appended Table 2 approval and whether a treaty or other-law permit or confirmation is required — the Act on Protection of Cultural Properties for cultural properties, CITES-related laws for fauna and flora, and so on.
Nor is it enough to look only at the Export Order. Customs — that is, the Ministry of Finance — publishes a "List of Laws and Regulations Related to Export" that organizes, in addition to the Export Trade Control Order, many other laws that come into play at export: the Act on Protection of Cultural Properties, the Forest Act, CITES-related environmental laws, the Food Sanitation Act, the Plant Protection Act, the Act on Pharmaceuticals and Medical Devices, the Narcotics Control Act, and more. If you keep in mind that the Export Order is one part of this system, you'll leave fewer gaps in your checks. Because it is also a separate regime from the "goods prohibited from export" that Article 69-11 of the Customs Act stops at the border, don't forget that both can apply at once.
Let me also state plainly how heavy the consequences are for non-compliance. Article 69-6 of the Foreign Exchange Act provides for imprisonment of up to 7 years or a fine of up to 20 million yen, or both, for unlicensed exports of Appended Table 1 goods (violations of Article 48, paragraph 1); when five times the value of the goods exceeds 20 million yen, the fine may be up to five times the value. For unlicensed exports or provision of goods and technology that could contribute to the development of nuclear weapons and the like, the same article imposes a heavier penalty of up to 10 years' imprisonment or a fine of up to 30 million yen. Unapproved exports of Appended Table 2 goods (violations of Article 48, paragraph 3) carry a separate, generally lighter statutory penalty, so confirm the exact term and amount in the penalty provisions on e-Gov. Export control is not a world where "I didn't know" gets you off. That is exactly why, when in doubt, you should not conclude on your own that goods are non-controlled; instead, seek a judgment from your superior, your export-control department, METI's consultation desk, or CISTEC. I regard that one step as the best risk-avoidance measure for a beginner.
Once you have the Export Order map in hand, the next thing to do is actually try to see which item of which appended table your flagship product is closest to. If you want to support appended-table matching — which tends to rely on a single expert — with a system, our individual consultation on TRAFEED can help you organize your current framework in about 30 minutes. Once you can read the map, export control is no longer "that scary thing I don't really understand."
Frequently asked questions
What is the Export Trade Control Order (the Export Order)? It is a cabinet order (Cabinet Order No. 378 of 1949) that implements the Foreign Exchange Act. Through lists called appended tables, it specifies concretely which goods require the Minister of Economy, Trade and Industry's license or approval when exported to which destinations. It rests on two pillars: list controls and catch-all controls for national security (Appended Table 1, license), and export approval to honor international commitments and sanctions (Appended Table 2, approval).
What is the difference between Appended Table 1 and Appended Table 2? Appended Table 1 covers items subject to a license under Article 48(1) of the Foreign Exchange Act, regulating goods that could be diverted to military use from a national-security standpoint. Appended Table 2 covers items subject to an approval under Article 48(3), established so Japan can faithfully implement international commitments it has entered into, such as CITES and UN sanctions. The numbers are merely adjacent; the underlying provisions and purposes are separate regimes.
Are the Export Order and the Customs Act's "goods prohibited from export" the same? They are separate regimes. The Export Order is a license/approval scheme based on the Foreign Exchange Act and administered by METI, whereas the prohibited exports under Article 69-11 of the Customs Act, which Customs stops at the border, differ in both governing law and jurisdiction. Because both can apply at once in practice, you must check other laws too, not only the Export Order.
When did the latest amendment take effect, and what changed? Cabinet Order No. 376 of 2025 (promulgated November 14, 2025) took effect on February 14, 2026. Its main points are adding equipment for synthesizing peptides to the goods subject to a license, removing juvenile eel (glass eel) from the goods subject to approval, and adding certain goods designated by public notice among those exported without charge on the premise of a planned duty-free re-import to the exceptions requiring no license. Always perform classification against the latest version of the orders.
Take the map and take the first step
We've read the Export Trade Control Order through its two pillars: the license of Appended Table 1 and the approval of Appended Table 2. Let me emphasize just one thing at the end. The appended tables of the Export Order are living things, updated nearly every year in response to regime agreements and treaty amendments. There is no guarantee that what you memorized once stays correct forever.
That is precisely why learning how to read the map matters. The detailed values and each year's amendments change, but the skeleton — "license is national security, approval is international commitments, and beyond them lie exceptions and region categories" — does not change. Once that skeleton is in your body, you'll be able to follow each year's amendment news calmly.
As a first step from today, why not start by confirming two things: which item of Appended Table 1 your flagship product is closest to, and who inside your company is the export-control manager. From the moment you hold the map, export control gradually stops being scary.
Related articles
- What is export classification? The procedure explained on one page
- What is a non-applicability certificate? How to write a classification record and parameter sheet
- Export-control AI agent TRAFEED
References and footnotes
[1] e-Gov Law Search, "Export Trade Control Order (Cabinet Order No. 378 of 1949)" text (Articles 1 and 2, Appended Tables 1–7). https://laws.e-gov.go.jp/law/324CO0000000378/ [2] e-Gov Law Search, "Foreign Exchange and Foreign Trade Act (Act No. 228 of 1949)," Article 48 and Article 69-6. https://laws.e-gov.go.jp/law/324AC0000000228 [3] Ministry of Economy, Trade and Industry, "Security Export Control," related laws and amendment information. https://www.meti.go.jp/policy/anpo/law00.html [4] Ministry of Economy, Trade and Industry, "List of Goods Subject to Export Approval (relating to Appended Table 2)." https://www.meti.go.jp/policy/external_economy/trade_control/04_kamotsu/01_export/export_kamotsu.html [5] Ministry of Economy, Trade and Industry, "The Cabinet Decided on a Cabinet Order Partially Amending the Export Trade Control Order" (November 2025). https://www.meti.go.jp/press/2025/11/20251111001/20251111001.html [6] Customs (Ministry of Finance), "List of Laws and Regulations Related to Export." https://www.customs.go.jp/yusyutu/2021_1/data/export.htm