Hello, this is Ryuta Hamamoto from TIMEWELL. If you sell Japanese electronics, reexport boards built in Japan, or run a Japan entity that ships AI inference gear, measuring instruments, or crypto/comms hardware, the February 14, 2026 amendment to Japan's Export Trade Control Order is no longer a local-only story. It is a Wassenaar-aligned list change that reaches the equipment layer, not only the bare chip.
On November 14, 2025, Japan's 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 and pulls regime-agreed controls into Appended Table 1 of the Export Order. The practical headline is new Item 7 (10-2): modules, assemblies, and equipment that incorporate field-programmable logic devices (FPLDs), including FPGAs, when the total LUT input count hits 1,800,000 or more.
This piece walks through the legal skeleton, the three control tests, other adds and deletes, licensing transition rules, and a five-step work plan you can run whether you sit in Tokyo, Austin, or Singapore.
What you will take away
- Cabinet Order No. 376 of 2025 in one table (promulgation, enforcement, pre-enforcement licensing)
- The three control requirements for FPGA/FPLD-embedded equipment and how the 1,800,000 LUT total is counted
- Why Japan moved from standalone-device control to equipment-level control
- Peptide synthesis equipment, high-entropy alloy powder, and the juvenile-eel deletion
- How existing contracts, bulk licenses, and classification documents are treated
- Four industries most affected and five steps that still matter after the enforcement date
Three terms worth locking first
- FPGA (Field-Programmable Gate Array): an IC whose logic the user can reconfigure after manufacture. Common in AI inference, image processing, communications, test gear, and crypto acceleration (as opposed to fixed-function ASICs).
- FPLD (Field Programmable Logic Device): the broader family that includes FPGAs and CPLDs. The new entry is written against FPLD, not the narrower FPGA label alone.
- Appended Table 1 of the Export Trade Control Order: the core of Japan's list-based dual-use controls (Items 1–15). Item 7 is the electronics domain; Item 7 (10-2) is the new equipment-level entry.
You will also see classification documents (records that state whether a product falls under Appended Table 1), the Goods and Technologies Ordinance (the METI ordinance that details Appended Table 1 parameters), bulk licenses (general, special general, and specific), BOM, internal compliance program (CP), and CISTEC (Center for Information on Security Trade Control).
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Cabinet Order No. 376 of 2025 at a glance
| Item | Content |
|---|---|
| Order name | Cabinet Order Partially Amending the Export Trade Control Order |
| Order number | Cabinet Order No. 376 of 2025 |
| Cabinet decision | November 11, 2025 |
| Promulgation | November 14, 2025 |
| Enforcement | February 14, 2026 |
| Pre-enforcement license intake | From December 15, 2025 |
| Jurisdiction | METI, Trade and Economic Security Bureau |
This is Japan's routine annual list revision, built on three pillars.
- Domestic legislation of international regime lists: reflecting Wassenaar Arrangement (WA), Nuclear Suppliers Group (NSG), Missile Technology Control Regime (MTCR), and Australia Group (AG) agreements into Appended Table 1 and the Goods and Technologies Ordinance. FPGA-embedded equipment, high-entropy alloy powder, and peptide synthesis equipment all sit on this pillar.
- Removing double coverage with other statutes: for example, juvenile eels, already covered under Ministry of Agriculture, Forestry and Fisheries rules.
- A narrow special provision: temporary re-export of protective clothing used for foreign dignitary security can be license-exempt under defined conditions.
Headline change: FPGA-embedded equipment under list control
The operationally heaviest change is new Appended Table 1, Item 7 (10-2). The statutory language covers modules, assemblies, or equipment incorporating an FPLD. Article 6, Item 10-2 of the Goods and Technologies Ordinance was updated in parallel.
The three control requirements
An item is controlled for all destinations when it meets all three of the following:
- Form is a module, electronic assembly, or piece of equipment
- It incorporates one or more user-configurable FPLDs
- Total look-up table (LUT) input count is 1,800,000 or more
What "total LUT input count of 1,800,000" means
A LUT is the basic logic building block inside an FPGA. An N-input LUT can hold a truth table of 2^N entries. "Total LUT input count" is the sum of the independent input counts of all physical LUTs mounted in the equipment.
Example: a board carries two FPGAs, each with 150,000 LUTs, each LUT having 6 inputs.
Total = 2 × 150,000 × 6 = 1,800,000 — exactly at the threshold (controlled if also user-configurable)
Multiple devices are summed. A single FPGA below the line can still pull the finished board over the line when you add the rest of the BOM. That pattern is common on AI inference cards and high-end signal-processing assemblies.
Why control at the equipment level
Standalone FPLDs were already controlled as integrated circuits under Item 7 (1). Shipping a high-performance FPGA on a "general-purpose image-processing board" often left the finished equipment outside list control even when the bare die would have been controlled. Item 7 (10-2) closes that structural gap by naming modules, assemblies, and equipment explicitly.
US readers will recognize the policy instinct: close diversion paths that appear when controls stop at the component and ignore the system. The Japan entry is list-based and parameter-driven; it is not a sanctions designation of any vendor.
Classification practice and what the record should show
Not every FPGA-bearing product is controlled. Operational guidance points to exclusion room when:
- Function is fixed and the user cannot reconfigure
- Function is fixed to a specific application and technical information is not disclosed outside the manufacturer (including under NDA)
- The value-based "10% rule" style component carve-out does not save you if the device remains user-reconfigurable — the whole equipment is evaluated
The practical dividing line is whether you can show that the design does not leave the user free to rewrite the logic. A defensible classification package for Item 7 (10-2) should at least cover product name, model, and revision; FPLD count and total LUT input count; user-configurability; exclusion analysis with evidence; classifier name; and classification date. CISTEC item-by-item comparison tables updated for the February 14, 2026 ordinance version are the usual Japanese industry baseline.
Where automation helps without replacing judgment
Building those records product-by-product is heavier than most teams budget for. TRAFEED, TIMEWELL's export-control AI agent, can ingest BOM and specification data and draft multi-jurisdiction classification support across Japan's Appended Table 1 (including Item 7 (10-2)), the US CCL, EU Annex I, and China's dual-use catalogue — always with cited parameters. Final classification authority stays with your export control officer.
Old order vs new order (FPGA-related)
| Item | Through 2026-02-13 | From 2026-02-14 |
|---|---|---|
| Controlled items | Standalone FPLD (Item 7 (1) IC path) | Standalone plus modules, assemblies, equipment (Item 7 (10-2)) |
| Threshold concept | Device-level specs | Total LUT input count across mounted FPLDs |
| "User-configurable" | Not cleanly stated for equipment | Written into the control text |
| Vendor workload | Finished-good classification often limited | Finished-good vendors reissue classification documents |
| Diversion path via general-purpose boards | Functionally available | Closed at the list level |
Other amendment items
Additions (all destinations, list control)
| Category | Added item | Regime root |
|---|---|---|
| Chemicals / bio | Peptide synthesis equipment | AG (dual-use concern with biological weapons pathways) |
| Materials | High-entropy alloy powder; refractory metal powder and alloy powder | WA (extreme-environment / high-performance material concern) |
| Electronics | FPLD-embedded modules, assemblies, equipment | WA |
The Goods and Technologies Ordinance also revised multiple specification thresholds in chemicals, materials, and electronics. Treat peptide synthesis gear and advanced alloy powders as list-control work, not only catch-all work, once your SKU sits in the new parameters.
Deletion
Appended Table 2, Item 33 (juvenile eels) was removed after separate MAFF-controlled rules took effect on December 1, 2025, ending double listing under the Export Order.
Pre-enforcement licensing and transitional measures
Even after February 14, 2026, the transition design still shapes backlog and audit questions.
- Pre-enforcement applications: intake from December 15, 2025; formal licenses designed to issue on or after enforcement so post-date shipments are not stranded.
- Bulk licenses: some items move from general or special general bulk licenses toward specific bulk licenses. The transitional measure runs six months from February 14, 2026 (through August 14, 2026) and is limited to bulk-license matters. It is time to re-scope and re-file, not time to pause all work.
- Classification document versions: use the CISTEC comparison table version aligned with the February 14, 2026 ordinance. Old-version packages can fail customs acceptance.
- Existing contracts: shipment date controls, not contract date. Unshipped cargo on the enforcement date is under the new order.
Who feels this: four industry clusters
- Semiconductor and electronic equipment makers: industrial gear, instruments, servers, AI inference accelerators with FPGA content
- Board and module OEMs/ODMs: suppliers of FPGA boards to overseas finished-goods brands; expect sharper classification-document requests from customers
- Crypto and communications equipment: heavy FPGA use; overlap with Appended Table 1 Item 9 raises multi-entry complexity
- Chemical / pharma equipment and metal powder producers: peptide synthesizers and high-entropy / refractory powders
Penalty risk (Japan FEFTA frame)
Unlicensed exports on or after enforcement can violate Japan's Foreign Exchange and Foreign Trade Act. Individuals face up to 10 years' imprisonment and fines up to 30 million yen; corporations face fines up to 1 billion yen or five times transaction value, whichever is higher; administrative export bans can run up to three years. Customs rejection of stale classification packages is an operational risk even before a formal violation case.
For US-origin content reexported from Japan, you still run the EAR in parallel — ECCN, de minimis, FDP, and end-user controls. Japan list clearance does not clear the EAR.
Five practical steps (still useful after go-live)
- Inventory at BOM level: map FPGA/FPLD content and compute total LUT input count; flag SKUs at or above 1,800,000.
- Reissue classification documents: cover Item 7 (10-2) three-part tests and exclusion evidence.
- Review bulk licenses: confirm scope for general, special general, and specific bulk licenses; complete switch-over inside the six-month window where it applies.
- Notify the chain: trading companies, agents, overseas subsidiaries, and end users need version control on classification packs.
- Update the CP and train: sales, procurement, logistics, and legal all touch the new entry.
Workload reality from support conversations
Reissuing one classification document often runs on the order of 4–8 hours per product when model families are similar. A mid-size maker with 50-plus FPGA-bearing instruments or AI boards can spend multiple person-months from inventory through document refresh. The recurring failure modes we see are redoing the same work for near-identical model variants, and trying to reuse pre-amendment packages without re-baselining the ordinance version.
Frequently asked questions
Q1. My industrial unit has only one FPGA. Is it controlled?
Only if total LUT input count (devices × LUTs × inputs) is at or above 1,800,000 and the FPLD is user-configurable (and no exclusion path applies). Pull LUT and input counts from the real shipped specification, not marketing copy.
Q2. What if we ship with firmware-fixed function?
Fixed function with no user reconfiguration can support a non-controlled outcome, but residual physical rewrite capability and technical disclosure status still matter. Document the design lock and disclosure chain.
Q3. Do intra-group transfers to an overseas subsidiary count?
Yes. If cargo leaves Japan for abroad, the Export Order analysis applies even inside a group.
Q4. I am a US importer of Japanese boards. Do I care?
Yes, for two reasons. Your Japanese supplier's ability to ship on time depends on Japanese licensing and documentation. Your own reexport or further manufacture may still need US EAR classification and screening on top of whatever Japan document you receive.
If you are refreshing classification workflows after this list change, download the TRAFEED product catalog (PDF) or contact us.
Summary
- Cabinet Order No. 376 of 2025 took effect February 14, 2026. The operational centerpiece is Appended Table 1 Item 7 (10-2) for FPLD-embedded modules, assemblies, and equipment at a total LUT input count of 1,800,000 or more.
- Japan extended standalone-FPGA style controls to the equipment layer to close general-purpose board routing. Peptide synthesis equipment and high-entropy alloy powders were added; juvenile eels were removed from double coverage.
- Pre-enforcement license intake began December 15, 2025. Bulk-license transition for affected items runs six months through August 14, 2026.
- Shipment date, not contract date, decides which order applies.
- Inventory, re-classify, re-scope bulk licenses, notify partners, and update the CP remain the five-step loop — and multi-jurisdiction products still need the US EAR and other destination rules on the same shipment.
Related articles
- What Is an ECCN? Classification Flow, EAR99, and de minimis
- Export Control in the Semiconductor Industry
- US EAR, China, and EU Controls at Once
- China Dual-Use Catalogue 2026 Guide
- List Controls vs Catch-All Controls in Japan
TRAFEED for multi-list classification support
Every time Japan revises Appended Table 1, finished-goods vendors rework classification packs and push updates through distributors. Equipment-level expansions such as Item 7 (10-2) multiply BOM-level inventory work.
TRAFEED cross-references Japan's Appended Table 1, the US CCL, EU Annex I, and China's dual-use catalogue from item and counterparty data and returns classification support with cited parameters. List revisions are reflected on the system side so annual amendments are not a full manual rebuild each cycle. TRAFEED is decision support. Your export control officer owns the final call.
- Refresh FPGA-bearing products against Item 7 (10-2)
- Standardize how LUT totals and exclusion conditions appear in classification records
- Run Japan list work in the same flow as US CCL and partner-country screens
TRAFEED overview · 30-minute consultation
References
- METI press release, Cabinet Order Partially Amending the Export Trade Control Order (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, 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, Export Trade Control Order (Cabinet Order No. 378 of 1949): https://laws.e-gov.go.jp/law/324CO0000000378/
- e-Gov, Goods and Technologies Ordinance: https://laws.e-gov.go.jp/law/403M50000400049/
- CISTEC commentary on the 2025 routine list revision (November 18, 2025): https://www.cistec.or.jp/export/express/251117/12_kaisetsu.pdf
![What Is Appended Table 2 of the Export Trade Control Order? Items Requiring Export Approval, from Primary Sources [2026 Edition]](/images/columns/appended-table-2-export-approval-guide/cover.png)
