Hello, this is Hamamoto from TIMEWELL. In this article I will explain, in terms a newcomer can follow, the "partial amendment to the Export Trade Control Order effective February 14, 2026" that everyone responsible for export control must be on top of.
On November 14, 2025, the Ministry of Economy, Trade and Industry (METI) promulgated the "Cabinet Order Partially Amending the Export Trade Control Order (Cabinet Order No. 376 of 2025)." It took effect on February 14, 2026, incorporating into Japan's Appended Table 1 of the Export Order the controlled items agreed under international regimes such as the Wassenaar Arrangement. The headline change is the creation of a new entry, Appended Table 1, Item 7 (10-2), which adds modules, assemblies, and equipment incorporating FPGAs (Field-Programmable Gate Arrays) to the list of controlled items.
What you will learn from this article
- The big picture of Cabinet Order No. 376 of 2025 (promulgation date, enforcement date, transitional measures)
- The headline change, "FPGA-embedded equipment," its three control requirements, and the threshold (a total LUT input count of 1,800,000)
- The intent to extend conventional standalone-FPGA controls to the equipment level and close the loophole
- Other added items (peptide synthesis equipment, high-entropy alloy powder) and a deleted item (juvenile eels)
- Pre-enforcement license applications (accepted from December 15, 2025) and the treatment of existing contracts
- The four industries that Japanese companies will be affected through, and the five practical steps to take
Three terms to grasp first
Before getting into the substance, let me organize three terms that are essential for reading this article.
- FPGA (Field-Programmable Gate Array): an integrated circuit whose logic the user can rewrite after manufacture. It is widely used in AI inference, image processing, communications, measurement, and cryptographic processing (in contrast to the application-fixed ASIC).
- FPLD (Field Programmable Logic Device): a general term for programmable logic devices, such as FPGAs and CPLDs, whose structure can be changed after shipment. In this amendment, the scope of control is defined not by FPGA but by the broader concept of FPLD.
- Appended Table 1 (Appended Table 1 of the Export Trade Control Order): the core of Japan's list-based controls. It is classified into Items 1 through 15, and the "Item 7" of the newly created "Item 7 (10-2)" is the electronics domain.
Beyond these, this article frequently refers to the classification document (a document that technically determines whether a company's own product falls under Appended Table 1), the Goods and Technologies Ordinance (the METI ordinance that sets out the details of Appended Table 1), bulk licenses (a licensing system that authorizes a defined range at once, in three types: general bulk, special general bulk, and specific bulk), BOM (bill of materials), CP (internal compliance program for export control), and CISTEC (the Center for Information on Security Trade Control).
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The big picture of Cabinet Order No. 376 of 2025
| Item | Content |
|---|---|
| Order name | Cabinet Order Partially Amending the Export Trade Control Order |
| Order number | Cabinet Order No. 376 of 2025 |
| Cabinet decision date | November 11, 2025 |
| Promulgation date | November 14, 2025 |
| Enforcement date | February 14, 2026 |
| Start of acceptance of pre-enforcement license applications | December 15, 2025 |
| Jurisdiction | METI, Trade and Economic Security Bureau |
This amendment is the annual routine list revision, and it is made up of the following three pillars.
- Domestic legislation of agreements under the international export control regimes: reflecting into Appended Table 1 and the Goods and Technologies Ordinance the control lists agreed under the Wassenaar Arrangement (WA), the Nuclear Suppliers Group (NSG), the Missile Technology Control Regime (MTCR), and the Australia Group (AG). The additions of FPGA-embedded equipment, high-entropy alloy powder, and peptide synthesis equipment are all based on this pillar.
- Resolving overlapping controls with other laws: deleting items already covered by separate legislation (such as juvenile eels).
- Adding a special provision: creating a new exemption from the export license requirement for the temporary re-export of protective clothing used to guard visiting foreign dignitaries.
The headline change: adding FPGA-embedded equipment
The change with the largest practical impact in this amendment is the creation of Appended Table 1, Item 7 (10-2) of the Export Order. In the text of the provision it reads "modules, assemblies, or equipment incorporating a field-programmable logic device (FPLD)," and Article 6, Item 10-2 of the Goods and Technologies Ordinance was developed in parallel.
The three requirements for control
Under the new entry, items that satisfy all three of the following requirements are controlled (list control, for all destinations).
- The form is one of a module, an electronic assembly, or a piece of equipment
- It incorporates one or more user-configurable FPLDs
- The total look-up table (LUT) input count is 1,800,000 or more
The third point, "total LUT input count," is an easy place for newcomers to stumble, so I explain it concretely in the next section.
What "a total LUT input count of 1,800,000" means
A LUT (Look-Up Table) is the basic unit that builds logic circuits inside an FPGA; an N-input LUT is a small logic block that can hold a truth table of 2-to-the-N entries. The provision's "total LUT input count" refers to the sum of the independent input counts of all physical LUTs mounted in the equipment.
Calculation example: suppose a board carries two FPGAs, each with 150,000 LUTs (each LUT having 6 inputs).
Total = 2 units × 150,000 LUTs × 6 inputs = 1,800,000, which is exactly the threshold (controlled)
The important point is that even when a single FPGA does not reach the threshold, multiple devices are summed, and the case can fall under control. Such configurations are not unusual in AI inference boards and high-performance signal processing equipment.
Why control at the "equipment level": closing the loophole
Previously, a standalone FPLD (controlled as an integrated circuit under Appended Table 1, Item 7 (1)) was already subject to export control. However, if a high-performance FPGA was mounted on a board and exported as a "general-purpose image processing board," list control would not reach the equipment as a whole. This loophole existed. This amendment closes the structural weakness of "controlled as a standalone device, free once embedded in equipment" by explicitly bringing items under control at the module, assembly, and equipment level as well.
Practical points for classification and the required items in the classification document
Not all FPGA-embedded equipment is controlled uniformly; the provisions and operational notices clearly set out the following exclusion conditions.
- Out of scope if the function is fixed: equipment whose function is fixed and which the user cannot reconfigure.
- Room for non-applicability if fixed to a specific application and the technical information is non-disclosed: where the FPLD's function is fixed to a specific application and the technical information is not disclosed to anyone other than the manufacturer (including under a non-disclosure agreement).
- The "10% rule" does not apply: if the device is incorporated in a user-reconfigurable state, the exclusion based on the value ratio of components cannot be used, and the entire equipment is controlled.
In other words, the practical dividing line is whether you can prove that "the design does not allow the user to rewrite the logic circuit." A classification document based on the CISTEC "Item-by-Item Comparison Table" must, at a minimum, include the following to address the new entry Item 7 (10-2): product name, model number, and revision; the number of FPLDs mounted and the total LUT input count; whether or not it is user-configurable; applicability to the exclusion conditions and the supporting basis; and the person responsible for the classification and the classification date.
About TRAFEED (mid-article) Putting these items in order for each product is heavier work than you might expect. TRAFEED, the AI export control agent, cross-references Japan's Appended Table 1 (including the new entry Item 7 (10-2)), the U.S. CCL, EU Annex I, and China's Dual-Use Items Catalogue simply by ingesting your BOM and product specifications, and drafts a classification with supporting evidence. See the AI export control agent "TRAFEED".
Differences from the old order (FPGA-related)
| Item | Old order (through 2026/2/13) | New order (from 2026/2/14) |
|---|---|---|
| Controlled items | Standalone FPLD (as an integrated circuit under Item 7 (1)) | In addition to standalone, modules, assemblies, and equipment (new Item 7 (10-2)) |
| Concept of the threshold | Single-device specification | Total LUT input count (summed across multiple FPGAs) |
| Definition of "user-configurable" | Not stated | Stated in the provision |
| Practice of classification | Limited evaluation as a finished product | Finished-product vendor must reissue the classification document |
| Loophole | Effectively avoidable via general-purpose boards | Closed |
"Reissuing the classification document" will be the single greatest practical burden for every Japanese company involved in exporting. I will go into more detail later.
Main amendment items other than FPGA
Additions for all destinations (strengthening list control)
| Category | Added item | Underlying regime |
|---|---|---|
| Chemicals and bio | Equipment for synthesizing peptides | AG agreement (concern over diversion to biological weapons) |
| Materials | High-entropy alloy powder, refractory metal powder and its alloy powder | WA agreement (concern over diversion to extreme-environment components and defense use) |
| Electronics | FPLD-embedded modules, assemblies, and equipment | WA agreement |
Peptide synthesis equipment was agreed under the AG as capable of diversion to both pharmaceutical research and the synthesis of biological weapons; high-entropy alloy powder is a new generation of material that contains multiple elements in roughly equal proportions and is used in extreme-environment components such as jet engine parts. In addition, the Goods and Technologies Ordinance also revised specifications and thresholds for multiple entries in the chemical, materials, and electronics fields.
Deletion
Appended Table 2, Item 33: juvenile eels became controlled under legislation under the jurisdiction of the Ministry of Agriculture, Forestry and Fisheries that took effect on December 1, 2025, and is therefore deleted from the Export Order (resolving the double control).
Pre-enforcement license applications and transitional measures
Another point that is important for those handling the practical work is the treatment of pre-enforcement license applications and transitional measures.
- Acceptance of pre-enforcement license applications: acceptance began on December 15, 2025. The formal license is designed to be issued on or after the enforcement date (February 14, 2026), so companies planning to ship immediately after enforcement can prevent shipment delays by applying early.
- Reviewing bulk licenses: for some items, there are cases where the classification shifts from a general bulk license or special general bulk license to a specific bulk license. The transitional measure runs for six months counting from the enforcement date (February 14, 2026) (through August 14, 2026), and is limited to matters related to bulk licenses. It is not a period during which "you can do nothing"; it is a period for checking the scope and carrying out switch-over procedures.
- Updating the classification document: use the "version compliant with the ordinance effective 2026.2.14" of the CISTEC "Item-by-Item Comparison Table." Customs may not accept clearance procedures that use the old version.
- Treatment of existing contracts: cargo not yet shipped as of the enforcement date is subject to the new order even under an existing contract. The criterion is not the contract date but the law in force at the time of shipment.
Impact on Japanese companies: four industries
The main industries affected by this amendment are the following four.
- Semiconductor and electronic equipment manufacturers: companies exporting FPGA-equipped industrial equipment, measuring instruments, servers, AI inference accelerators, and the like. The applications are broad and the scope of impact is larger than expected.
- Board and module manufacturers (OEM/ODM): businesses that supply FPGA-equipped boards to overseas equipment makers. Requests for classification documents from finished-product makers will become more detailed.
- Cryptographic and communications equipment manufacturers: FPGAs are widely used in cryptographic implementations and high-speed packet processing, and the overlap with Appended Table 1, Item 9 makes classification more complex.
- Chemical and pharmaceutical equipment / metal powder manufacturers: companies exporting peptide synthesis equipment, high-entropy alloy powder, and refractory metal powder.
Penalty risk
Unlicensed exports on or after the enforcement date constitute a violation of the Foreign Exchange and Foreign Trade Act. Individuals face up to 10 years of imprisonment and a fine of up to 30 million yen; corporations face a fine of up to 1 billion yen or five times the transaction value, whichever is higher; and as an administrative disposition, they may be subject to an export prohibition of up to three years. The risk that customs will not accept clearance documents using an old version of the classification document is also easy to overlook.
The five practical steps to take
The five steps to be ready by the enforcement date (February 14, 2026) are as follows.
- Inventory your products: take stock of the FPGA-installation status of your products at the BOM level and list those whose total LUT input count is 1,800,000 or more.
- Update the classification documents: reissue the classification documents for the new entry Item 7 (10-2). Organize the technical information to judge applicability to the three requirements and the exclusion conditions.
- Review bulk licenses: confirm whether newly controlled items fall within the scope of general bulk, special general bulk, and specific bulk licenses, and carry out switch-over procedures within the six-month transitional measure.
- Notify your business partners: inform trading companies, agents, overseas subsidiaries, and end users about handling of the new entry and version control of the classification documents.
- Update your internal CP: reflect the new entry Item 7 (10-2) and set up training opportunities in each of the sales, procurement, logistics, and legal departments.
A rough guide to the practical workload (from TIMEWELL's support cases) Reissuing a classification document takes a guide of 4 to 8 hours per product (the average where there are many models of the same type). At a mid-sized manufacturer holding 50 or more FPGA-equipped AI inference boards or measuring instruments, it is not unusual to spend the equivalent of two to three person-months from inventory through to updating the classification documents. At several companies that consulted us about adopting TRAFEED, the conspicuous mistakes were duplicating identical classification effort across variations of the same model number, and rework arising from trying to reuse classification documents from the old order.
Frequently asked questions
Q1. If my industrial equipment carries only one FPGA, is it controlled? If the total LUT input count (number of FPGAs × number of LUTs × number of inputs) is below 1,800,000, it is not applicable. If the total is at or above the threshold and it is user-configurable, it falls under control. Check the number of LUTs and inputs from the product specifications and calculate.
Q2. What if I ship the FPGA with its function fixed in firmware? If the user cannot reconfigure it and the function is fixed, there is room for it to fall outside scope. However, caution is needed if "user-rewritable" room physically remains. The vendor makes the classification, taking into account the disclosure status of the technical information.
Q3. Are internal transfers to an overseas subsidiary also covered? Yes. Even for intra-group transactions, as long as cargo leaves Japan for abroad, it is subject to the Export Order.
Summary
- The headline change of the partial amendment to the Export Trade Control Order effective February 14, 2026 (Cabinet Order No. 376 of 2025) is bringing FPGA-embedded equipment under control (creation of Appended Table 1, Item 7 (10-2)). Modules, assemblies, and equipment with a total LUT input count of 1,800,000 or more are covered.
- It extends standalone-FPGA controls to the equipment level and closes the loophole of routing through general-purpose boards. In addition, peptide synthesis equipment, high-entropy alloy powder, and others were added, while juvenile eels were deleted to resolve double control.
- Acceptance of pre-enforcement license applications began on December 15, 2025. The transitional measure for bulk-license matters runs for six months (through August 14, 2026).
- Even under existing contracts, cargo not yet shipped as of the enforcement date is subject to the new order (the criterion is the law in force at the time of shipment).
- In practice it is the five steps: inventory your products, update the classification documents, review bulk licenses, notify business partners, and update the internal CP. Bear in mind that at a mid-sized manufacturer this becomes a burden on the scale of two to three person-months, and we recommend an early start.
Related articles
- What Is Export Classification? A Complete Guide from the Basics to Practical Handling (2024 Edition) (/en/columns/2024)
- Export Control in the Semiconductor Industry: A Practical Guide (/en/columns/semiconductor-industry-export-control)
- A Guide to the Simultaneous Impact of the U.S. EAR, China, and the EU's Three Regulations (/en/columns/ear-china-eu-three-regulations-simultaneous-impact)
- Complete Guide to the 2026 Edition of China's "Dual-Use Items and Technologies Export and Import License Control Catalogue" (/en/columns/china-dualuse-catalog-2026)
Introducing the AI export control agent "TRAFEED"
Every time Japan's Appended Table 1 is amended, you have to review all of your products' classification documents and roll them out to your business partners. When the scope of control expands in the form of "controlled as standalone for a long time, newly covered once embedded in equipment," as with FPGA-embedded equipment, inventory and classification at the BOM level become an enormous amount of work.
TRAFEED (formerly ZEROCK ExCHECK), the world's first AI export control agent developed by TIMEWELL, cross-references export control lists and sanctions lists from around the world, including Japan's Appended Table 1, the U.S. CCL, EU Annex I, and China's Dual-Use Items Catalogue, simply by uploading item information and business-partner data, and returns a classification with supporting evidence. Because list revisions are automatically reflected on the system side, the burden of keeping up with annual amendments drops substantially.
Do you have concerns like these?
- You want to review the classification of your FPGA-equipped products to match the new entry Item 7 (10-2)
- You do not know the format for the classification document that corresponds to the new entry (the requirements for stating the LUT total and the exclusion conditions)
- You want to finish the BOM inventory and classification-document updates for 50 or more products in time for the February 2026 enforcement
- You want to check not only Appended Table 1 but also the U.S. CCL, EU Annex I, and China's Dual-Use Items Catalogue all at once
See the TRAFEED service details
Apply for a one-on-one TRAFEED consultation (a 30-minute online consultation)
References
- METI press release, "A Cabinet Order Partially Amending the Export Trade Control Order Was Decided by the Cabinet" (November 11, 2025) https://www.meti.go.jp/press/2025/11/20251111001/20251111001.html
- METI, "Overview of the Amendment to the Export Trade Control Order and Related Regulations (November 2025)" https://www.meti.go.jp/policy/anpo/law_document/seirei/20251114_gaiyo01.pdf
- METI, "On the Acceptance of Pre-Enforcement License Applications" https://www.meti.go.jp/policy/anpo/apply-01/pre-apply.html
- METI, "Related Laws and Amendment Information" https://www.meti.go.jp/policy/anpo/law00.html
- e-Gov Law Search, "Export Trade Control Order (Cabinet Order No. 378 of 1949)" https://laws.e-gov.go.jp/law/324CO0000000378/
- e-Gov Law Search, "Ordinance Specifying Goods or Technologies Based on the Provisions of Appended Table 1 of the Export Trade Control Order and the Appended Table of the Foreign Exchange Order" https://laws.e-gov.go.jp/law/403M50000400049/
- CISTEC, "On the 2025 Routine List Revision and Related Matters (Commentary)" (November 18, 2025) https://www.cistec.or.jp/export/express/251117/12_kaisetsu.pdf
- Shin Nihon Hoki, "Partial Amendment to the Export Trade Control Order (Cabinet Order No. 376 of November 14, 2025; effective from February 14, 2026)" https://www.sn-hoki.co.jp/article/pickup_hourei/pickup_hourei4470499/
- Classification commentary, "Newly Created Classification: Export Order Appended Table 1, Item 7 (10-2)" https://note.com/exportcontrol/n/n84978df6ef76