Japan's FEFTA Revisions Explained: From the February 2026 Changes to the October Draft

Hello, this is Ryuta Hamamoto from TIMEWELL.

"Japan's export law is going to change in a few months, there's a public comment out, but what is actually changing?" If you are asking that, you are not alone. Amendments to the Foreign Exchange and Foreign Trade Act, known in Japan as FEFTA or Gaitame-ho, make headlines under the name of the statute, while the substance arrives in a string of separate documents: cabinet orders, ministerial ordinances, notices and circulars. In 2026 alone, different pieces moved on different dates in February, June, August and October.

Here is the short answer. The draft that METI opened for comment on October 19 does not rewrite the statute. It amends the rules beneath it, and it has three parts: adding or revising controlled goods and technologies, adding an exception to the ban on settling payments before an authorization is granted, and revising how goods temporarily landed in Japan for a foreign destination are defined. As for timing, the draft ministerial ordinance says it takes effect "on the day two months after promulgation." But the promulgation date has not been decided, so there is no calendar date yet.¹²³

Key points (as of October 28, 2026)

• The draft out for comment combines a cabinet order amending the Foreign Exchange Order and the Export Trade Control Order, a ministerial ordinance on goods and technologies, a METI notice, and circulars. Comments are due by Wednesday, November 18, 2026
• Three themes: adding or revising controlled goods and technologies, an exception to the ban on settling payment before authorization, and the definition of goods temporarily landed for a foreign destination
• The ministerial ordinance takes effect two months after promulgation, and the notice on promulgation. The promulgation date is unannounced. The previous ministerial ordinance, the one that took effect in February 2026, had three months
• On February 14, 2026, three items including peptide synthesizers were added. The amendment to the statute itself (inward direct investment) is a separate track run by the Ministry of Finance and has nothing to do with this comment period

For a running list of what changed after February 14, see our change log of the Export Trade Control Order. This article steps back from that and draws the whole map, so that someone meeting Japanese export law for the first time can follow it, using only what could be confirmed in the original documents.

First, a few terms: statute, cabinet order, ordinance, notice, circular

The first stumbling block is knowing which document is a change to the law and which is not. Japanese regulation is built in layers, from broad to fine.

At the top is the statute, here the Foreign Exchange and Foreign Trade Act (FEFTA). The Diet enacts it. FEFTA sets the broad frame: to maintain international peace and security, it obliges exporters to obtain a license from the Minister of Economy, Trade and Industry for controlled goods. It does not list which goods are covered.¹

Below it are cabinet orders, decided by the Cabinet. The Export Trade Control Order (the "Export Order") and the Foreign Exchange Order are here. The Export Order's Appended Table 1 is a long table that sorts goods needing a license into broad categories. Below that sit ministerial ordinances issued by the Minister. The ordinance on goods and technologies fills in each item of Appended Table 1 with specifications, which is to say the numerical thresholds. Notices make individual designations, and the most practical layer, circulars, defines how terms are interpreted and how applications are handled.

Think of a kitchen. The statute is the policy that food must be safe, the cabinet orders are the menu categories, the ordinance is the quantity for each ingredient, and the circulars are the working manual. Changing a quantity does not change the policy by one character. The current comment period works the same way: the statute stays put, and four kinds of documents beneath it change.

A public comment procedure is how an agency publishes a draft before finalizing a cabinet order or ordinance and invites views. It rests on Japan's Administrative Procedure Act, and anyone can take part. METI says it treats the comments it receives as input for the final decision and states plainly that it will not reply individually.¹ A draft may be revised in response, or promulgated as it stands.

What changed on February 14, 2026

When people say "the changes since February," they most likely mean this one: Cabinet Order No. 376 of 2025 (the order amending the Export Trade Control Order) and its companion rules, promulgated on November 14, 2025, put into force in stages, with the main body taking effect on February 14, 2026.⁴⁵

METI's explanatory material lists four pillars. They are revisions that reflect agreements of the international export control regimes, a carve-out for temporary exports of weapons that are certain to come back, additions to the technologies covered by the public-private technology control dialogue scheme, and streamlining of license requirements.⁴

The most consequential part is that three goods were added to the list that needs a license for export to any destination. In the text of the order they are equipment for synthesizing peptides (Appended Table 1, Item 3-2), "powders of alloys made of multiple elements in nearly equal proportions" (high-entropy alloy powders) or powders of refractory metals or their alloys (Item 5), and "modules, assemblies or equipment incorporating field-programmable logic devices" (Item 7).⁶ A peptide is a short chain of amino acids. An FPGA is a chip whose circuitry the buyer can rewrite after purchase. If one is built into your product, the classification (the judgment of whether the item is controlled) has to be redone.

Specifications for many existing items were revised as well, including pressure gauges (Item 2), centrifuges (Item 3-2), superconducting materials and integrated circuits (Item 5) and laser oscillators (Item 10). For spray dryers, METI changed the wording of the ordinance from "sterilization" to "disinfection" and limited the method to chemical agents, following a Tokyo High Court ruling. According to METI, the court held that "sterilization" should be read in line with the Australia Group, the international regime aimed at stopping the spread of biological and chemical weapons.⁷

Some changes loosened the rules. Temporary exports that are obviously coming back no longer need a license: firearms and ammunition carried to international sporting events, and body armor taken abroad by the National Police Agency or the Japan Coast Guard to protect dignitaries. Services under the Official Security Assistance (OSA) program, and the re-supply of the same program when a storage medium has been physically damaged, also stopped needing licenses. Accessories and parts for defense equipment exported to countries that have signed a defense equipment transfer agreement can now be covered by blanket licenses.⁴⁷

The thing to note is that this single amendment came in four blocks with different effective dates.

Effective date	What moved
November 15, 2025	Spray dryer revision, exception for temporary export of weapons to be brought back, license exemption for OSA services, re-supply of damaged program media
December 1, 2025	Deletion of Item 33 of Appended Table 2 (glass eels), among others
January 14, 2026	Four more technologies added to the advance-reporting list under the public-private dialogue scheme
February 14, 2026	Addition of three goods, revised specifications across items, wider blanket licenses

The sources are METI's explanatory documents and the text and rationale of the cabinet order.⁴⁶⁷ The supplementary provisions of the order say that it "takes effect on the day three months after the day of promulgation," which leads to the next question.⁶

What else moved between February and October

Export-law changes did not stop after February 14. Here they are in order, based on METI and Ministry of Finance publications.

Date	Event	Ministry
January 30, 2026	Corrections to omissions and typos in circulars (promulgated and effective the same day)	METI
February 14, 2026	Main body of Cabinet Order No. 376 of 2025 takes effect	METI
June 5, 2026	Act amending FEFTA promulgated (upgrading inward direct investment screening)	Ministry of Finance
June 16, 2026	Notice adding technologies to the advance-reporting scheme promulgated (effective August 16)	METI
October 9, 2026	Cabinet order and related texts for additional sanctions on Russia promulgated (implemented October 16)	METI
October 19, 2026	Public comment opens on the draft amending the Foreign Exchange Order and Export Order (through November 18)	METI

The June 16 notice adds "technologies requiring control" to the public-private dialogue scheme. The scheme asks companies to report to the Minister before a transaction that provides technology judged to carry a high risk of leakage. METI says the aim is not to stop technology transfers but to ensure proper technology management through dialogue.⁷ According to the public comment materials, the five technologies proposed for addition were solder resist, GaN substrates, permanent magnets, perovskite solar cells and scintillators.⁸ The list stood at 15 technologies in November 2025, grew to 19 with the four added on January 14, and has grown again with this addition.⁷

The October 9 amendment is part of the sanctions on Russia. It is separate from both the February amendment and the draft now out for comment. METI announced on October 6 that it would implement additional measures under FEFTA over the situation in Ukraine.⁹ Note the contrast: sanctions are implemented about a week after promulgation, while changes to controlled goods take months to come into force. That contrast helps when we think about the timing of the current draft.

What the draft published on October 19 would change

Now for the main subject. On October 19, 2026, METI opened public comment on a "draft cabinet order amending the Foreign Exchange Order and the Export Trade Control Order, and related drafts." The period runs from October 19 to November 18, and the drafts cover four kinds of documents: a cabinet order, a ministerial ordinance, a notice and circulars.¹² The comment guidelines organize the purpose into three parts.

Part 1: adding and revising goods and technologies

The guidelines describe this as "revisions reflecting agreements of the international export control regimes and Japan's position as a responsible technology holder."¹ Here is what the old-and-new comparison table for the cabinet order shows, in plainer language.

Subject (item)	Change
Export Order, Appended Table 1, Item 3-2	For nucleic acid equipment, drops equipment that only joins nucleic acids and spells out two categories: equipment that synthesizes nucleic acids, and equipment that synthesizes them together with joining
Same, Item 5	Adds equipment for manufacturing explosive devices, pyrotechnics, propulsion devices and molded forms of explosives, limited to additive manufacturing (the "3D printing" type)
Same, Item 6	States that additive manufacturing equipment excludes what falls under Item 5 (avoiding overlap)
Same, Item 7	Changes "sampling oscilloscope" to "real-time oscilloscope"
Same, Item 12	Deletes "underwater lighting equipment"
Foreign Exchange Order Appendix, Item 5	Adds technology for the use of molded products made of inorganic fibers and similar
Same, Item 9	Adds technology for the use of transmission equipment and of wireless transmitters in counter-IED equipment
Same, Item 12	Adds technology for the use of submarines, technology for the use of sound-damping equipment for ships, and technology for the design or manufacture of air-cushion vessels and similar craft
Same, Item 15	Adds technology for the use of devices that jam improvised explosive devices. Existing Item 15 (2) is deleted and a new Item 9 (2-2) is created

The sources are the comment guidelines and the old-and-new table for the cabinet order.¹¹⁰ Notice that controls on goods sit in Appended Table 1 of the Export Order, and controls on technology sit in the Appendix to the Foreign Exchange Order. The former covers shipping machines and objects; the latter covers handing over technology such as designs and engineering guidance.

The draft ministerial ordinance spells out the specifications. The new goods in Item 5, for example (numbered "6-2" in the ordinance), are additive manufacturing equipment designed or modified to make explosive devices, pyrotechnics, propulsion devices or molded forms of them from energetic materials, "having one or more ultrasonic extruders or ultrasonic nozzles."³ It is a typical example of how the ordinance defines not just a type of machine but what kind of build falls within scope.

The old-and-new table for the draft circular also contains many additions and tidy-ups of interpretive terms that these three parts do not explain. For instance, the places where the circular explains "parts" and "accessories" are rearranged across many items.¹¹ I could not confirm within the scope of this review whether the circular maps one-to-one onto the guidelines' explanation. If an item affects your product, read the old-and-new table directly.

Part 2: adding to the items excluded from the ban on settlement before approval

The name is heavy, so let me unpack it. Under FEFTA, for transactions that need a license or approval, you generally cannot pay or receive payment without first obtaining it. A cabinet order sets exceptions. Article 6, paragraph 5 of the Foreign Exchange Order exempts exports or imports "for which the Minister has recognized, by notice, that there is no particular obstacle" to the payment, among goods subject to a license or approval requirement.¹⁰

The draft adds exports specified in Article 1, paragraph 3 of the Export Order to the entry point of this exception.¹¹⁰ In other words, it appears to widen the room for payments connected with such exports to be made without waiting for the license. What actually becomes an exception, though, is only what the Minister designates by notice. The text of the order alone does not fix the scope, so you also need to read the draft notice.

Part 3: the definition of goods temporarily landed for a foreign destination

Goods temporarily landed are goods that are unloaded at a Japanese port or airport but are bound for a destination outside Japan. The text reads "among goods temporarily landed, those carried on a bill of lading (including an air waybill and similar documents) whose destination is a place other than Japan."¹⁰ Picture cargo traveling from one foreign country to another that stops over in Japan.

The draft removes Article 4, paragraph 2, item 3 of the Export Order from the scope to which the definition of "goods temporarily landed for a foreign destination" applies. In the old-and-new table, the current wording "in the next paragraph, items 1 and 3" becomes "in the next paragraph, item 1."¹⁰ The guidelines call this a "review of the definition provision."¹ Because it concerns how cargo passing through Japan is treated, anyone close to air or sea freight clearance and forwarding should read that part of the table.

The notice and the circulars

The draft notice concerns the list in Article 4 of the Export Order of "goods imported free of charge that are to be exported free of charge" and similar. In the comparison table, the entry for goods exported from Japan and "repaired in Japan and then re-exported" is widened to "repaired, calibrated or inspected." The notice says it takes effect on the day of promulgation.¹² The guidelines list four circulars to be amended: the Export Order operation circular, the services circular, the circular on documents and notes for license applications, and the blanket-license handling guidelines.¹

How many months from promulgation to entry into force?

The feeling that "it takes about two months from promulgation to entry into force" is accurate for this draft. The last page of the draft ministerial ordinance, its supplementary provisions, reads as follows.

1. This Ministerial Ordinance takes effect on the day two months after the day of promulgation.
2. (Preparatory acts) A person who intends to obtain a license under Article 25, paragraph 1 or 3, or Article 48, paragraph 1 of FEFTA for the goods or technologies specified in the Appended Tables as amended by this Ordinance may file the application for the license even before the date this Ordinance takes effect.

The source is the final page (supplementary provisions) of the draft ordinance.³ So if the draft is promulgated as it stands, the ordinance that sets specifications for goods and technologies takes effect two months after promulgation, and license applications for the amended items can be filed before that date. The notice draft says it takes effect on the day of promulgation.¹² For the cabinet order, only the old-and-new table is public and the supplementary provisions are not part of the materials.¹⁰ The effective date of the cabinet order cannot be confirmed until it is promulgated.

Still, the period differs from one amendment to the next. Here are past examples, from METI's change log and the record of the 2025 public comment.⁵¹³

Promulgated	Effective	Period	Notes
October 6, 2022	December 6, 2022	2 months	Amendments reflecting regime agreements and others (cabinet order, ordinance, circulars)
June 30, 2023	July 21, 2023	About 3 weeks	Review of export control for South Korea (cabinet order)
March 28, 2025	May 28, 2025	2 months	Amendment of the Foreign Exchange Order and Export Order
April 9, 2025	October 9, 2025	6 months	Review of the catch-all controls and more (cabinet order). Some parts took effect April 9
November 14, 2025	February 14, 2026	3 months	Cabinet Order No. 376 and the ordinance. Staged entry into force
October 9, 2026	October 16, 2026	About 1 week	Additional sanctions on Russia (cabinet order). As announced by METI

Two months is a common pattern. Urgent measures like sanctions go faster, and changes that need preparation have gone slower. The previous ordinance on goods and technologies (Ministry Ordinance No. 72 of 2025) said in its supplementary provisions that it takes effect on the day three months after promulgation.¹⁴ The current draft is a month shorter, at two months.

So when will promulgation happen? Nothing in the materials says.¹² Last time, the comment period ran from September 4 to October 3, 2025, the Cabinet approved on November 11, and promulgation came on November 14.¹³⁵ That is about six weeks from the end of comments to promulgation. If the same interval holds, promulgation would fall around the end of the year, about six weeks after the November 18 deadline, and an effective date two months later would land around February 2027. That is my own extrapolation from past cases, not a schedule METI has announced. If the draft is revised, the timing could change too. Please do not treat it as settled until there is an official announcement.

Last time, a mechanism for filing applications before the effective date was used. For the amendment that took effect on February 14, 2026, METI began accepting license applications in advance from December 15, 2025.⁵¹⁵ The current draft ordinance contains the "preparatory acts" provision quoted above, so similar handling may follow. If you have time-sensitive orders, check the start date for advance applications as soon as the effective date is set.

The statute-level amendment to FEFTA is a different track

News about "FEFTA changing" has another strand. The Act amending the Foreign Exchange and Foreign Trade Act, promulgated on June 5, 2026, falls under the Ministry of Finance, and its subject is the screening of inward direct investment.¹⁶

According to the Ministry of Finance, the main points include adding indirect acquisitions of shares through foreign entities, creating response measures for investments that were outside prior notification (investments in non-designated sectors), and making measures to reduce risk to national security a matter that must be notified. Except for certain parts, it takes effect on a date set by cabinet order within one year of promulgation.¹⁶¹⁷ What this law governs is investment from abroad into Japanese companies, not the export of goods or technology. It is separate from the October 19 comment period, and the ministries that handle it differ from the ones export control staff deal with day to day. For the investment side, see Japan's CFIUS-style regime and our guide to inward direct investment screening.

What a company should do now

Let me turn this into practice.

First, check whether the goods you export or the technology you provide touch the items in the tables above. Think additive manufacturing equipment, nucleic acid or peptide equipment, measuring instruments such as oscilloscopes, and technology related to ships and submersibles. If they do, read the old-and-new tables and the specifications in the draft ordinance. The draft ordinance is a vertically typeset document and hard to read if you are not used to it, but the numbers are only written there.³ For this review I read the main parts of its 60 pages.

Second, decide whether to comment. Questions such as "under this definition, would our product fall inside the scope?" or "will the notice make the exception for settlement before approval clear?" can be put to METI through the comment procedure. Attaching sources for your reasoning makes your input easier to use. The deadline is Wednesday, November 18, and submitting through e-Gov is more reliable than post.¹

Third, prepare internally so that you can move the moment the effective date is announced. That means deciding the order in which to revisit classification records, whether the internal compliance program needs updating, and whether to use advance applications. If the ordinance takes effect two months after promulgation, you will have less time to update classifications than the three months last time. The ideal is to finish the review before the effective date.

As one way to support this kind of review with a system, there is our export control AI agent TRAFEED. It supports classification aligned with METI's criteria and screens counterparties. The final classification decision always rests with your export control officer. If you want to know where your own export control stands first, try the free diagnostic tool.

Summary

What changes in a few months is not the statute but the Export Order, the Foreign Exchange Order, the ordinance on goods and technologies, the notice and the circulars. The content has three parts, which are revisions to controlled goods and technologies, an exception to the ban on settlement before approval, and the definition of goods temporarily landed. The effective date has not been decided.

What taught me the most while researching this was that the supplementary provisions of the February amendment said "three months" while I had walked in expecting "two." The period between promulgation and entry into force differs with every amendment. That is why the habit of checking the supplementary provisions the moment a promulgation is announced pays off.

The comment deadline is November 18. If your business touches one of these items, open the old-and-new tables now. For specific questions, please feel free to use our consultation form.

What was and was not checked against the originals

This article is based on documents I read directly: METI's public comment guidelines, the old-and-new tables for the cabinet order, ordinance, notice and circulars (for the draft ordinance, key places such as Items 5 and 7 and the supplementary provisions were checked as images), METI's explanatory material and the text of the cabinet order for the November 14, 2025 amendment, METI's change log, e-Gov's public comment records, and the Ministry of Finance's material on the amending Act.

What I could not confirm is the full set of numerical specifications in the draft ordinance, a line-by-line comparison of the full draft circulars, the text of the cabinet order promulgated on October 9, and the text of the notice promulgated on June 16. Parts of METI's site did not respond to scripted retrieval. For the October 9 amendment I have stayed with METI's announcement and the outline reported. Before using any of this in practice, please verify against the originals.

References

Footnotes

1. Draft amendment of the Foreign Exchange Order and the Export Trade Control Order: public comment guidelines (Japanese), METI, October 19, 2026 ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸ ↩⁹ ↩¹⁰ ↩¹¹

2. Public comment case details (case no. 595320041), e-Gov Public Comment (Japanese) ↩ ↩² ↩³

3. Draft ministerial ordinance on goods and technologies under Appended Table 1 of the Export Order and the Appendix to the Foreign Exchange Order, old-and-new comparison (Japanese), METI, October 19, 2026 ↩ ↩² ↩³ ↩⁴

4. Outline of the amendments to the Export Trade Control Order (Japanese), METI, November 2025 ↩ ↩² ↩³ ↩⁴

5. Change log, METI Security Export Control (Japanese) ↩ ↩² ↩³ ↩⁴

6. Cabinet Order No. 376 of 2025 amending the Export Trade Control Order: text and rationale (Japanese), METI ↩ ↩² ↩³

7. Explanatory material on the FEFTA-related system amendments, part 2 (Japanese), METI Trade and Economic Security Bureau, November 2025 ↩ ↩² ↩³ ↩⁴ ↩⁵

8. Technologies subject to advance reporting (attachment to the public comment, Japanese), METI ↩

9. Implementation of measures under FEFTA concerning the situation in Ukraine (Japanese), METI, October 6, 2026 ↩

10. Draft cabinet order amending the Foreign Exchange Order and the Export Trade Control Order, old-and-new comparison (Japanese), METI, October 19, 2026 ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶

11. Draft circular amending "Operation of the Export Trade Control Order," old-and-new comparison, and related circulars (Japanese), METI, October 19, 2026 ↩

12. Draft notice on goods imported free of charge to be exported free of charge and similar, old-and-new comparison (Japanese), METI, October 19, 2026 ↩ ↩²

13. Draft amendment of the Export Trade Control Order: public comment, announced September 4, 2025 (Japanese), e-Gov Public Comment ↩ ↩²

14. Ministry Ordinance No. 72 of 2025 on goods and technologies: text and old-and-new comparison (Japanese), METI ↩

15. Accepting license applications before the effective date (Japanese), METI Security Export Control ↩

16. On the Act amending the Foreign Exchange and Foreign Trade Act (Japanese), Ministry of Finance, June 5, 2026 ↩ ↩²

17. Outline of the bill amending the Foreign Exchange and Foreign Trade Act (Japanese), Ministry of Finance ↩