Preparing for METI On-Site Inspections — A 30-Item Export Control Audit Checklist

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

1. Is the CP actually operated as written?
2. Is classification sound (basis, date, approval)?
3. Does transaction screening work?
4. Do pre-shipment checks match classified items to shipped items?
5. Is education/training conducted?
6. Are records retained properly?
7. Are internal audits performed?

The real question is not “Are you doing these things?” but “Do you have evidence?”

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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.

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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.

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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.

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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.

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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.

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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

Related articles

• Five steps to streamline classification
• Ten steps to build an export-control system
• EAR compliance checklist
• Drawings and design-data export control
• Export control changes in 2026