This is Hamamoto from TIMEWELL.
“We received notice of a METI compliance inspection—and we have no idea what to prepare.” “We’ve never been inspected and can’t picture the questions.” “Our records are messy, and we’re worried we’ll be flagged.” I hear these concerns regularly from export-control managers.
On-site inspections rest on FEFTA Article 68. Their stated purpose is to support exporters in running appropriate controls themselves—not primarily to punish. Still, if a serious violation surfaces, outcomes can go beyond improvement guidance.
This article organizes a 30-item checklist, required documents, common findings, and day-of posture, using public METI information and operational practice.
Key takeaways
- Legal basis: FEFTA Article 68; supportive purpose, but no records ≈ indistinguishable from “not done”
- METI materials target ~100–120 companies/year; FY2024 example: 86 inspections (82 CP-registered)
- Core is evidence: classification basis, transaction screening, shipment match, training, internal audit
- Findings cluster: hollow CP, missing bases, training gaps, no internal audit
- Standardizing classification forms is one of the shortest paths to readiness
Even before a notice arrives, the free export-compliance diagnostic helps surface gaps without last-minute panic.
Standardize classification forms first: letters, parameter sheets, comparison worksheets, catch-all sheets → Classification & parameter template pack (2026)
Inspection snapshot (comparison table)
| Item | Content |
|---|---|
| Legal basis | FEFTA Article 68 |
| Character | Compliance inspection (support for self-management) |
| Volume target | About 100–120 companies/year (METI materials)[^1] |
| Example actuals | FY2024: 86 inspections (82 CP-registered)[^2] |
| Notice | Usually written notice in advance |
| Duration | Roughly 1–3 days (by company size) |
| Focus areas | CP operation, classification, screening, shipment, training, records, internal audit |
Seven areas inspectors examine
- Is the CP actually operated as written?
- Is classification sound (basis, date, approval)?
- Does transaction screening work?
- Do pre-shipment checks match classified items to shipped items?
- Is education/training conducted?
- Are records retained properly?
- Are internal audits performed?
The real question is not “Are you doing these things?” but “Do you have evidence?”
2. The 30-item preparation checklist
Use this between the notice and the inspection date.
Management framework (1–6)
| No. | Checklist item | What to verify | Priority |
|---|---|---|---|
| 1 | Most current CP exists | Reflects regulatory amendments | High |
| 2 | Org chart in CP matches reality | Updated after reorgs/personnel changes | High |
| 3 | Top responsible officer is current representative | Update after CEO change | High |
| 4 | Appointment records for officers/staff | Letters of appointment | Medium |
| 5 | Internal communication record of the CP | Notices, email distribution | Medium |
| 6 | CP revision history managed | What changed and when | Medium |
Export classification (7–12)
| No. | Checklist item | What to verify | Priority |
|---|---|---|---|
| 7 | Sample classification records available | Multiple records from the past year | High |
| 8 | Each record includes the basis | Ordinance references, technical data | High |
| 9 | Each record includes the classification date | Pre- vs post-amendment identification | High |
| 10 | Classifier and approver are separate | Dual-check structure | High |
| 11 | Re-classification after amendments | Threshold changes addressed | High |
| 12 | Non-controlled basis is specific | Technical reasoning articulable | High |
Transaction screening (13–18)
| No. | Checklist item | What to verify | Priority |
|---|---|---|---|
| 13 | Screening records retained | Sheets, approvals | High |
| 14 | Foreign User List cross-reference logs | Date/time, results | High |
| 15 | End-use verification method and records | Contract clauses, interview notes | High |
| 16 | End-user documentation | EUCs retained | Medium |
| 17 | Catch-all verification records | Objective-requirement sheets | High |
| 18 | Irregular-transaction detection | Red-flag response procedures | Medium |
Shipment management (19–22)
| No. | Checklist item | What to verify | Priority |
|---|---|---|---|
| 19 | Pre-shipment match procedures documented | Classified vs shipped items | High |
| 20 | Shipments linkable to classification records | Traceability | High |
| 21 | License conditions checked at shipment | Validity, quantity, destination | High |
| 22 | Technology transfer (deemed export) managed | Disclosure to foreign-national staff; travel carry-out | Medium |
Education and training (23–25)
| No. | Checklist item | What to verify | Priority |
|---|---|---|---|
| 23 | Training session records | Date, roster, content | High |
| 24 | Training materials retained | Texts, slides | Medium |
| 25 | Management briefings conducted | At least annually | Medium |
Record retention (26–28)
| No. | Checklist item | What to verify | Priority |
|---|---|---|---|
| 26 | Export records retained ~7+ years as principle | Location known, searchable (some categories 5 years) | High |
| 27 | Contracts, invoices, shipment docs retained | 7-year practical standard | High |
| 28 | Electronic tamper-prevention | Access logs, backups | Medium |
Audit and improvement (29–30)
| No. | Checklist item | What to verify | Priority |
|---|---|---|---|
| 29 | Internal audit at least annually | Audit reports, corrective actions | High |
| 30 | Improvement records after findings | Plans, completion checks | High |
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3. List of required documents
Management framework
| Document | Retention | Notes |
|---|---|---|
| Internal export control regulations (CP) | Always current | Including revision history |
| Organizational chart | Always current | Shows export-control function |
| Appointment records | During tenure | Letters of appointment |
Classification and screening
| Document | Retention | Notes |
|---|---|---|
| Classification records | 7+ years (principle) | Basis and date |
| Product technical specs | 7+ years (principle) | Data used in classification |
| Parameter / comparison worksheets | 7+ years (principle) | CISTEC forms, etc. |
| Transaction screening records | 7+ years (principle) | Sheets, approvals |
| Foreign User List cross-reference logs | 7+ years (principle) | Date/time, result |
| End-Use Certificates (EUCs) | 7+ years (principle) | From counterparties |
| Catch-all verification sheets | 7+ years (principle) | Objective requirements |
Transactions, shipment, training, audit
| Document | Retention | Notes |
|---|---|---|
| Pre-shipment verification records | 7+ years (principle) | Match confirmation |
| Export licenses | 7+ years (principle) | METI-issued |
| License application copies | 7+ years (principle) | Attachments included |
| Export contracts | 7+ years (principle) | End-use clauses |
| Invoices | 7+ years (principle) | |
| Training records | 3+ years recommended | Date, participants, content |
| Training materials | 3+ years recommended | Texts, slides |
| Internal audit reports | 3+ years recommended | Results, corrective plans |
| Corrective action records | 3+ years recommended | Implementation status |
If classification formats are inconsistent, standardize with the 2026 template pack.
4. Ten common findings and countermeasures
These patterns focus on record and operation gaps, not judgments about any listed company or individual case.
Finding 1: Hollow CP
Written procedures diverge from daily practice (e.g., “review committee” in the CP, only informal email in reality). Rewrite the CP to match executable operations—or change operations to match the CP.
Finding 2: Classification without a basis
“Non-controlled” with no ordinance reference or measured values. Make basis fields mandatory: article numbers, parameters, actuals.
Finding 3: No re-classification after amendments
Examples include catch-all updates and the 14 February 2026 order amendments. Put re-classification on the annual calendar.
Finding 4: Formalistic screening
List name-match only; end-use accepted solely because “it is in the contract.” Use end-use checklists and keep interview notes.
Finding 5: Training done, records missing
The most avoidable finding: work happened, evidence did not. Log date, place, roster, content, materials, and facilitator every time.
Finding 6: Internal audit never run
Even a lightweight CISTEC self-checklist cycle is better than “never.”
Finding 7: Weak pre-shipment matching
Classification exists, but shipment does not confirm model, quantity, and destination against the record/license.
Finding 8: Weak technology-transfer (deemed export) coverage
Goods controlled; technology disclosure to foreign-national staff, travel data, or joint research unmanaged. Deemed-export clarification applied from 1 May 2022.[^3] See also the drawings & technology guide.
Finding 9: Affiliates unmanaged
CP claims group oversight; practice does not. Review subsidiaries on a schedule; align group standards where possible.
Finding 10: Retention too short / unfindable
Discard before ~7 years, or storage locations unknown at inspection. Codify retention, maintain a location ledger, and digitize for searchability.
5. Day-of posture
| Posture | Concrete behavior |
|---|---|
| Be candid | Answer honestly; say “we will confirm” when unsure |
| Answer from records | Back oral statements with documents |
| Do not over-volunteer | Answer what is asked |
| Seat the right people | Engineers for classification; sales/legal for screening |
| Treat findings as improvement | Present a constructive remediation plan |
After the inspection, document findings, assign owners and deadlines, close actions, and re-check in the next internal audit. That cycle is the best preparation for the next visit.
6. Daily records are the strongest audit prep
The two most common gaps are “no record” and “record without a basis.” Last-minute document rushes have hard limits.
TRAFEED helps retain classification and screening histories. Overview: TRAFEED catalog (PDF). Judgment and accountability remain human. Contact: /contact?product=trafeed.
Conclusion
- Purpose is self-management support, not punishment by default
- Evidence is the core—without it, activity is invisible
- Findings are patterned; close high-priority checklist items first
- Post-inspection remediation records prepare the next visit
Start with “High” items and standardize classification bases. Entry points: template pack and diagnostic.
Primary sources
- METI Security Trade Control
- METI promotion of corporate self-management
- METI materials on compliance inspections (~100–120 companies/year target)[^1]
- METI FEFTA compliance inspection results (FY2024: 86 cases, etc.)[^2]
- METI deemed export (applied 1 May 2022)[^3]
- METI Security Trade Control Guidance (introductory)
- CISTEC self-management checklist materials
![[FY2024 Data] 52% of Foreign Exchange Act Violations Trace Back to Classification Errors - METI Statistics on the 5 Most Common Export Compliance Failures](/images/columns/gaitameho-violation-analysis-2024-meti-data/cover.png)