Japan Export Trade Control Order Amendments (October 2026): FPGA Modules and the Full Change Log

Hello, this is Ryuta Hamamoto from TIMEWELL. "Which amendment to Japan's Export Trade Control Order is the latest one?" sounds like a simple question. It isn't. The order promulgated on November 14, 2025 alone took effect in four stages. And if you open the Order in e-Gov, Japan's official law database, the current version is labeled "effective June 5, 2026," which makes plenty of people assume the control list changed again in June. It didn't.

Here is the short answer. As of October 4, 2026, the most recent amendment that changed what Japan controls is Cabinet Order No. 376 of 2025, whose list changes took effect on February 14, 2026. It created a new entry, Appended Table 1 Item 7 (10-2), for modules and equipment built around user-configurable FPGAs and similar devices. The June 5 order was a renumbering cleanup. What took effect on August 16 was a METI notice on reporting technology transfers, not a change to the Export Order. And METI has not yet published a draft of the next annual list revision.¹²

Key points (as of October 4, 2026)

• Latest list change: Cabinet Order No. 376 of 2025, promulgated November 14, 2025, list provisions effective February 14, 2026
• Three new entries: peptide synthesizers (Item 3-2), high-entropy and refractory metal powders (Item 5 (20)), and FPGA-embedded modules and equipment (Item 7 (10-2))
• The June 5, 2026 order (No. 194 of 2026) only fixed a penalty cross-reference in Article 14. Appended Table 1 is unchanged
• No draft of the next annual revision yet. Classify against the February 14 version

A quick orientation if Japan is not your home jurisdiction. The Export Trade Control Order is the cabinet order under Article 48 of Japan's Foreign Exchange and Foreign Trade Act (FEFTA). Appended Table 1 lists the dual-use and military goods that need an export license from METI, and Appended Table 2 lists goods that need export approval for other policy reasons. For a map of both tables, see What Is Japan's Export Trade Control Order?, and for Items 1 through 16 in detail, see Japan's Appended Table 1 explained. This piece sticks to one question: what changed, and when. If you want a quick read on where your own program stands first, try our free export compliance check.

Every amendment from May 2025 to October 2026

The table below lists the changes in order of effective date. I included METI ordinances, notices, and circulars alongside the Export Order itself, because several of them change day-to-day classification and licensing work even when the Order's text stays the same. Sources are METI's laws and amendments page and the e-Gov revision history.¹²

Effective	Instrument	What changed
May 28, 2025	Cabinet Order No. 102 of 2025 (promulgated March 28)	Additions tied to critical and emerging technologies, including advanced semiconductor and quantum computing items
Oct 9, 2025	Cabinet Order No. 175 of 2025 (promulgated April 9)	Catch-all overhaul. Item 16 split into (1) and (2); exports to Group A destinations now need a license when METI notifies the exporter
Nov 15, 2025	Part of Cabinet Order No. 376 of 2025	License exemption for temporary weapons exports that will come back to Japan; spray dryer wording changed from "sterilization" to "disinfection" in the ordinance
Dec 1, 2025	Part of Cabinet Order No. 376 of 2025	Juvenile eels removed from Appended Table 2, Item 33 (now handled under fisheries law)
Jan 14, 2026	METI Notice No. 166 of 2025	Four technologies added to advance reporting: three display-related (quantum dots and others) and flexible endoscope insertion tubes
Jan 19, 2026	Cabinet Order No. 382 of 2025 (promulgated Nov 19, 2025)	New Appended Table 2, Item 35-5: CO2-containing gas exported for sub-seabed storage (CCS) now needs export approval
Jan 30, 2026	METI circular corrections	Fixes for omissions, typos, and numbering errors in the 2025 amendments
Feb 14, 2026	List provisions of Cabinet Order No. 376 of 2025	Peptide synthesizers, high-entropy and refractory metal powders, and FPGA-embedded modules added to Appended Table 1; spec revisions across the ordinance; bulk-license changes
Jun 5, 2026	Cabinet Order No. 194 of 2026	Article 14's penalty cross-reference moved from FEFTA Article 69-6 to 69-7 after a partial FEFTA amendment
Aug 16, 2026	METI Notice No. 71 (promulgated June 16)	Advance-reporting list expanded: solder resists, gallium nitride substrates, permanent magnets, perovskite solar cells, X-ray scintillators, and more

The trick to reading this list is to sort the changes by what they ask of you. Only two of them require re-classifying products against Appended Table 1: May 28, 2025 and February 14, 2026. The October 2025 catch-all change did not add goods. It changed when a license is needed, so it lands on order screening and end-use checks rather than on the parameter-by-parameter classification. Our guide to Japan's catch-all amendments covers it.

The CO2 and juvenile eel changes sit on the Appended Table 2 side. That is export approval for treaty or resource-management reasons, a different track from the security licensing in Appended Table 1. The full list of items that need approval is in Appended Table 2 of Japan's Export Trade Control Order: all 23 export-approval items. The January and August notices are not Export Order amendments at all. They come from a separate METI ordinance and require companies to report to METI before providing certain technologies abroad. I find it useful to treat each change as a question of who in the company owns it, because that answer differs from row to row.

Honestly, the June 5 entry causes the most confusion. Comparing the February 14 and June 5 versions line by line, the only differences are the article number in Article 14 and a new supplementary provision.²

A worksheet for re-checking item numbers　Our item check sheet for Appended Table 1 and the Foreign Exchange Order table is an Excel workbook (Japanese-language) built for pasting rows from METI's matrix table, comparing each control parameter with your own specs, and keeping the reasoning. It reflects the February 14, 2026 amendments, including Item 7 (10-2). Any item with no rows checked shows up as "not yet checked" on the summary tab, so a blank never passes for "not controlled." It is our own original format. Download the item check sheet (free; company name and work email required).

The February 2026 amendment: Cabinet Order No. 376 of 2025

This was Japan's annual list revision for fiscal 2025. The draft went out for public comment from September 4 to October 3, 2025, the Cabinet approved it on November 11, and it was promulgated on November 14.³⁴

Item	Detail
Cabinet order	Cabinet Order Partially Amending the Export Trade Control Order (No. 376 of 2025)
Ordinances amended the same day	Goods and Technologies Ordinance (METI Ordinance No. 72 of 2025) and the technology-transfer ordinance (No. 71)
Cabinet decision	November 11, 2025
Promulgation	November 14, 2025
List provisions effective	February 14, 2026
Other provisions effective	Weapons exemption and spray dryer wording: November 15, 2025. Juvenile eel deletion: December 1, 2025. Advance-reporting additions: January 14, 2026
Applications accepted ahead of the effective date	From December 15, 20255

METI's overview groups the package into four parts.⁶ The first covers regime agreements and changes made "as a responsible technology holder in light of the international situation," which includes the spray dryer revision and the new emerging-technology items. The second is the temporary weapons exemption. The third adds technologies to the advance-reporting scheme. The fourth streamlines licensing.

The three new Appended Table 1 entries come from different places.

New entry	Item	Origin
Peptide synthesizers	Item 3-2 (2) 10	Australia Group agreement, which covers partly or fully automated synthesizers with a system synthesis scale of 1 mmol or more
Powders of alloys made of several elements in near-equal proportions (high-entropy alloys), and powders of refractory metals and their alloys	Item 5 (20)	Not a Wassenaar Arrangement agreement
Modules, assemblies, or equipment incorporating user-configurable FPLDs	Item 7 (10-2)	Also not a Wassenaar agreement

An earlier version of this article described the alloy powders and the FPGA entry as Wassenaar-agreed. That was wrong. CISTEC, Japan's export control information center, states plainly that neither is a Wassenaar consensus item. For the alloy powders, it reads the move as following an April 2024 interim report of METI's export control advisory subcommittee, which said Japan should be willing to start controls together with allies and like-minded countries even when a regime cannot reach consensus.³ For US readers, that is the useful context: Japan has said it is willing to control some items before the multilateral regimes agree on them.

The specification changes reach well beyond the new entries: pressure gauges (Item 2), botulinum toxins, fermenters, cross-flow filtration, spray dryers, and centrifuges (Item 3-2), superconducting materials and powder production methods (Item 5), integrated circuits and sampling oscilloscopes (Item 7), satellite terminology (Item 9), lasers (Item 10), submersible parts and spacecraft (Item 12), combustor and gas generator turbine technology (Item 13), and unmanned submersibles (Item 15).⁶ Even if none of the new entries touch your products, items you previously classified as not controlled may now sit on the other side of a revised threshold.

The spray dryer change deserves a sentence of context. Spray dryers were at the center of the Ohkawara Kakohki case, in which a Japanese equipment maker's executives were prosecuted for alleged export violations before the charges were withdrawn. In the company's damages suit against the national and Tokyo governments, the Tokyo High Court ruled on May 28, 2025, and the judgment became final on June 11. METI revised the ordinance's wording in light of that ruling.⁶³ It was a case of a legitimate civilian manufacturer caught up in an investigation that the courts later found unlawful, and the amendment aims to make the control text clearer.

On the exemptions: the temporary weapons provision covers exports that are obviously coming back, such as firearms taken abroad for international sporting events and body armor carried by Japan's National Police Agency when protecting Japanese dignitaries traveling overseas.⁴⁶ Our earlier version described it as the re-export of protective gear for foreign dignitaries visiting Japan, which got the direction backwards. The streamlining measures include exemptions for services under Japan's Official Security Assistance (OSA) program, for re-supplying a licensed program whose storage medium was physically damaged, a wider special general bulk license, and specific bulk license coverage for parts and accessories of defense equipment exported to the 16 countries that have defense equipment transfer agreements with Japan.⁶³

FPGA-embedded equipment (Item 7 (10-2)): the rule and METI's Q&A

Item 7 (10-2) is the change most likely to hit electronics makers. Article 6, item 10-2 of the Goods and Technologies Ordinance defines it as modules, electronic assemblies, or equipment that incorporate one or more user-configurable field-programmable logic devices and have an aggregate look-up table input count of 1,800,000 or more.⁷ Broken down, an item is controlled for all destinations when it meets all three of the following.

1. It is a module, electronic assembly, or piece of equipment
2. It incorporates at least one user-configurable FPLD (the family that includes FPGAs and CPLDs)
3. Its aggregate LUT input count is 1,800,000 or more

METI's operational circular defines the terms.⁸ "User-configurable" means the user can configure or change the logic cells, and the interconnects between them, inside the FPLD's logic structure to set the specific function the equipment performs. "Aggregate LUT input count" is the sum of the independent inputs available to each programmable LUT, across every physical LUT in the FPLDs or other programmable items. The circular's own example is a circuit board with two FPGAs, each with 150,000 programmable six-input LUTs: 2 × 150,000 × 6 = 1,800,000, exactly at the threshold.

Set products are where people slip. METI's Q&A (Q32) says that for equipment sold as a set combining several qualifying modules, you classify using "the input count of the module with the largest aggregate LUT input count."⁹ So FPGAs on one board add up, but separate modules in a set do not. Our earlier version said only that multiple devices are summed, which is true inside a single board or module and not across a set.

Then there is the exclusion. The circular carves out cases where the embedded FPLD is fixed to perform a specific function.⁸ What counts as "fixed" becomes clear only when you read three Q&A answers together.⁹

• Q33: If the logic cells and interconnects are already set at export and cannot be changed, the item is not user-configurable. But the "user" can include the manufacturer.
• Q34: "Fixed to perform a specific function" includes cases where the configuration is programmed and stored in IC memory or auxiliary non-volatile memory.
• Q36: A product purpose-built to perform a specific function only is fixed when the technical information needed to reconfigure the FPLD is never disclosed to anyone other than the manufacturer (the designer and maker).

If I had to pick one line to focus on, it would be the Q36 condition that the information is never disclosed outside the manufacturer. If you hand a customer the development environment or the procedure for rewriting the bitstream, even under an NDA, it becomes hard to say the information was never disclosed. I would put two things in the classification record: that the product is purpose-built, and exactly who has received the information needed to rewrite it. When in doubt, METI offers pre-application consultations, and that is the safer route.

Q34 also answers a question every OEM asks. When one of these modules goes into a larger system as a part, can you rely on the parts rule in Section 1-1 (7) (a) of the operational circular and classify only the finished system? METI's answer is no, unless the FPLD is fixed to a specific function.⁹ The module has to be classified on its own.

Technology transfers follow the goods. Under Article 19 of the Goods and Technologies Ordinance, which defines the technologies in Item 7 (1) of the Foreign Exchange Order table, the technology required to design or manufacture these modules (excluding programs) needs a license when provided to non-residents or abroad. Programs designed for designing or manufacturing them are carved out in item 5 of that article.⁷ For the goods, bulk license eligibility depends on the destination tier, ranging from general and special general bulk licenses to specific bulk licenses only, with some destinations outside bulk licensing altogether. The design and manufacturing technology is limited to specific bulk licenses.³

	Through Feb 13, 2026	From Feb 14, 2026
What is controlled	The FPLD itself (as an integrated circuit under Item 7 (1))	The FPLD plus modules, assemblies, and equipment that incorporate it
Threshold	Device-level specs	Aggregate LUT input count of 1,800,000 or more; summed within a board, highest module for set products
"User-configurable"	Not defined	Defined in the circular; the user can include the manufacturer
Parts rule	Available	Not available unless the FPLD is fixed
Who classifies	Finished goods rarely assessed on this basis	Board, module, and finished-goods makers reissue classification records

Where software can help When a control moves from the component to the equipment level, every product needs a fresh look at FPLD count, aggregate LUT inputs, rewrite capability, and who has the rewrite information. TRAFEED, TIMEWELL's export control AI agent, takes BOM and specification data and drafts the Japan export classification against Appended Table 1, with the cited parameters on file. Your export control officer makes the final call.

What changed after February, then and now

The rules kept moving after February 14. Here is what happened between this article's first version in May 2026 and October.

On June 5, Japan promulgated a partial amendment to FEFTA (Act No. 30 of 2026), with some provisions taking effect the same day. Cabinet Order No. 194 of 2026 followed to tidy up related orders. Because a FEFTA penalty article moved down one number, Article 14 of the Export Order now cites Article 69-7 instead of 69-6. The rest of the amending act is scheduled to take effect on January 4, 2027.²¹⁰ FEFTA Article 48, the export licensing provision, is unchanged in both stages, and so is Appended Table 1.

On August 16, METI Notice No. 71 took effect. It sits under Japan's public-private dialogue scheme for technology management, launched in December 2024, which asks companies to report to METI before providing certain high-risk technologies abroad.⁶ The notice added design and manufacturing technology for film-type solder resists and liquid solder resists used in semiconductor production, gallium nitride semiconductor substrates and ingots, permanent magnets, perovskite solar cells and modules plus the laser processing equipment used to make them, and X-ray scintillators with their phosphors and arrays.¹¹ If your Japanese partner licenses process technology in any of these areas to an overseas plant or joint venture, expect a reporting step on their side.

Going back a little, CO2 export approval began on January 19. Shipping CO2 overseas for sub-seabed storage now needs METI approval, premised on an agreement or arrangement with the receiving country under the London Protocol process.¹²

Item	At first publication (May 2026)	As of October 4, 2026
Current Export Order version in e-Gov	Effective February 14, 2026	Effective June 5, 2026; only Article 14's cross-reference and a supplementary provision differ
FEFTA article for unlicensed exports	Article 69-6	Article 69-7, renumbered by the partial FEFTA amendment. Japan's custodial sentence has been called kokin-kei since the June 1, 2025 Penal Code reform
FEFTA amendment	Not covered	Act No. 30 of 2026 promulgated and partly effective June 5; remainder scheduled for January 4, 2027
Advance-reporting technologies	Display and endoscope items added January 14	Solder resists, GaN substrates, permanent magnets, perovskite solar, scintillators and more added August 16
Next annual list revision	Not covered	No draft yet. Last year's public comment ran September 4 to October 3

What to check now: classification, bulk licenses, penalties

Once you know what changed, the to-do list for October 2026 is shorter than you might expect.

Start by aligning everyone on the same baseline. Appended Table 1 and the Goods and Technologies Ordinance are current as of the February 14 version, and METI's matrix table has a matching edition. Put the effective date of the version you classified against on every classification record. When the next revision lands, that one field tells you which records to revisit. For the step-by-step process METI expects, see Japan's export classification, step by step.

Then narrow down the products. For Item 7 (10-2), the candidates are boards and modules with FPGAs or CPLDs, test and measurement gear, communications equipment, image processing units, and AI inference accelerators. Pull FPLD part numbers from the BOM, compute the aggregate LUT input count from the datasheet LUT counts and input widths, and work down from the products closest to 1,800,000, checking rewrite capability and who has the rewrite information. The alloy powder entry mostly affects metal powder producers and additive manufacturing material suppliers. Peptide synthesizers affect lab equipment makers and their distributors.

On bulk licenses, an earlier version of this article said a six-month transitional period applied. I could not find a basis for that and removed it. CISTEC's list of effective dates shows the bulk license guidelines taking effect on February 14, 2026 (some forms on November 14, 2025), with no grace period mentioned.³ The May 2025 amendment did delay the part that moved items into specific bulk licensing by six months, to November 28, and the two may have been mixed up. The new tiers have applied since February 14.

Existing contracts do not get special treatment. Whether a license is needed depends on the rules in force when the goods are exported, not when the contract was signed, so anything shipped on or after February 14 falls under the new list. Shipments to an overseas subsidiary count too. If cargo leaves Japan, the Export Order applies.

Penalties under FEFTA are worth stating precisely. Exporting Appended Table 1 goods without a license is punishable under Article 69-7(1) by up to seven years' imprisonment, a fine of up to 20 million yen, or both. For goods that Article 14 of the Export Order designates as especially likely to be used for weapons of mass destruction (most of Item 1 and Items 2 through 4), Article 69-7(2) raises this to ten years or 30 million yen. In both tiers, if five times the value of the goods exceeds the cap, the fine can go up to five times the value. Corporations face fines of up to 700 million yen (1 billion yen for the heavier tier, again rising to five times the value when that is higher) under Article 72, and METI can ban a violator from exporting for up to three years under Article 53.¹⁰ The new FPGA and alloy powder entries fall in the first tier.

If you buy Japanese boards in the US, Japan's rules still matter to you in two ways. Your supplier's ship dates depend on its Japanese licensing and paperwork. And the Japanese classification does not clear anything under the EAR. Your own reexport or further manufacture still needs ECCN classification and restricted party screening on the US side. Separately, BIS's Affiliates Rule (the 50% rule) is on its own track: on the Federal Register record, its suspension under 90 FR 50857 runs through November 9, 2026. The US and China have announced an extension to January 10, 2027 (China's Ministry of Commerce confirmed it officially on September 28; the US side rests on press reports of the Treasury Secretary's September 23 remarks), but as of October 3 BIS had not published an extension rule. Our BIS Affiliates Rule guide tracks the details.

When the next annual list revision may land

METI says list-controlled items are, as a rule, revised every year.¹³ The sequence is a draft after regime meetings, public comment, Cabinet decision, promulgation, and then entry into force. For fiscal 2025, public comment ran from September 4 to October 3, promulgation came on November 14, and the list changes took effect three months later on February 14, 2026. CISTEC noted that the usual gap between promulgation and effect is two months, and suggested the extra month was a courtesy to avoid the year-end holidays.³

The e-Gov history of the Goods and Technologies Ordinance shows how irregular the timing is: promulgated December 2023 (effective February 2024), July 2024 (effective September), April 2025 (two amendments, effective May and October), and November 2025 (effective February 2026).⁷

As of October 4, 2026, the newest entry on METI's list of recent changes is the June 16 promulgation of Notice No. 71. There is no draft of the next annual revision, and e-Gov shows no promulgated-but-not-yet-effective amendments to the Export Order or the Goods and Technologies Ordinance.¹² Last year, public comment had already closed by this date. Given the steps between a draft and entry into force, my read is that the next list change will not take effect before early 2027.

Until a draft appears, the February 14 version is the baseline. I will update this article when METI publishes one.

Frequently asked questions

Q1. My unit has a single FPGA. Is it controlled? Only if its aggregate LUT input count (devices × LUTs × inputs per LUT) is 1,800,000 or more and the FPLD is user-configurable. Take the LUT count and input width from the datasheet for the configuration you actually ship.

Q2. We sell several FPGA boards together as one system. Do we add them up? Not if it is a set product combining qualifying modules. METI's Q&A (Q32) says to use the module with the highest aggregate count. Multiple FPGAs on one board are added together.

Q3. Do we need to reclassify against the June 5, 2026 version? No. The June 5 order only changed a FEFTA article number cited in Article 14. Appended Table 1 is the same as in the February 14 version.

Q4. We import Japanese FPGA boards into the US. Is a Japanese classification enough? No. It tells you how the goods were treated leaving Japan. US reexport, further manufacture, and screening still run under the EAR, and you need your own ECCN determination or the supplier's US classification.

Summary

• The latest list change in Japan is Cabinet Order No. 376 of 2025, effective February 14, 2026, which added peptide synthesizers, high-entropy and refractory metal powders, and FPGA-embedded modules and equipment.
• Item 7 (10-2) applies at an aggregate LUT input count of 1,800,000 or more. Count within a board, use the largest module for set products, and treat Q36's "never disclosed outside the manufacturer" test as the dividing line for the fixed-function exclusion.
• The June 5 order renumbered a penalty reference and the August 16 notice expanded technology reporting. Neither changed Appended Table 1.
• No draft of the next annual revision yet.

Japan's amendments do not look the same every year. Some move the unit of control, as this one did by going from the chip to the equipment. Others just fix an article number. If you can tell which kind you are looking at, you do not have to rework everything each time. A small first step: add the effective date of the classification baseline to every record you keep for Japanese-origin goods.

Related articles

• What Is Japan's Export Trade Control Order? A One-Page Map of Appended Tables 1 and 2
• Japan's Appended Table 1 explained
• Japan's export classification, step by step
• Japan's catch-all export control amendments explained
• Japan's advanced semiconductor and quantum controls
• What Is an ECCN? Classification Flow, EAR99, and de minimis
• US EAR, China, and EU controls at once

TRAFEED: Japan export classification and multi-list screening in one record

Every time Japan revises Appended Table 1, board, module, and finished-goods makers rework their classification records and push updates to distributors and overseas affiliates. A change like Item 7 (10-2) turns that into BOM-level inventory work.

TRAFEED drafts the Japan export classification against Appended Table 1 and the Foreign Exchange Order table, with the cited parameters on file. It runs restricted party screening against US, Japanese, EU, and Taiwanese lists, and checks lists published by the Chinese government for reference. Your export control officer reviews and owns the final call. TRAFEED is decision support, not legal advice.

• Re-check FPGA-bearing products against Item 7 (10-2) and METI's Q&A
• Record aggregate LUT counts, rewrite capability, and disclosure status the same way every time
• Keep Japan classification and counterparty screening in the same audit trail

Download the TRAFEED product catalog (PDF), or book a 30-minute consultation.

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References

Footnotes

1. METI, Related Laws and Amendment Information (list of recent changes, latest entry June 16, 2026; checked October 4, 2026): https://www.meti.go.jp/policy/anpo/law00.html ; documents for each change: https://www.meti.go.jp/policy/anpo/law09-2.html ↩ ↩² ↩³

2. e-Gov, Export Trade Control Order (Cabinet Order No. 378 of 1949), revision history (Cabinet Orders No. 102, 175, 376, and 382 of 2025; No. 194 of 2026) and a line-by-line comparison of the February 14 and June 5, 2026 versions (checked October 4, 2026): https://laws.e-gov.go.jp/law/324CO0000000378/ ↩ ↩² ↩³ ↩⁴ ↩⁵

3. CISTEC, Commentary on the FY2025 Annual List Revision (November 18, 2025), covering the public comment period, effective dates, Wassenaar origin, bulk license scope, and the spray dryer background: https://www.cistec.or.jp/export/express/251117/12_kaisetsu.pdf ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷

4. METI press release, Cabinet decision on the order amending the Export Trade Control Order (November 11, 2025): https://www.meti.go.jp/press/2025/11/20251111001/20251111001.html ↩ ↩²

5. METI, Accepting license applications before the effective date: https://www.meti.go.jp/policy/anpo/apply-01/pre-apply.html (start date also confirmed in the CISTEC commentary) ↩

6. METI Trade and Economic Security Bureau, Overview of the Amendments to the Export Trade Control Order and Related Regulations (November 2025): https://www.meti.go.jp/policy/anpo/law_document/seirei/20251114_gaiyo01.pdf ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶

7. e-Gov, Goods and Technologies Ordinance, Article 6 item 10-2, Article 19, and revision history (checked October 4, 2026): https://laws.e-gov.go.jp/law/403M50000400049/ ↩ ↩² ↩³

8. METI, partial amendment of the operational circular for the Export Trade Control Order (November 14, 2025), including the interpretations of Article 6, item 10-2, "user-configurable," and "aggregate look-up table input count": https://www.cistec.or.jp/export/express/251117/10-20251114_tutatu.pdf ↩ ↩²

9. METI, Q&A added and revised for the amendment (January 16, 2026 version, Q32 to Q36): https://www.meti.go.jp/policy/anpo/qanda/20260116_QAmatome.pdf ↩ ↩² ↩³

10. e-Gov, Foreign Exchange and Foreign Trade Act (Act No. 228 of 1949), Articles 53, 69-7, and 72, and effective dates of Act No. 30 of 2026 (checked October 4, 2026): https://laws.e-gov.go.jp/law/324AC0000000228/ ↩ ↩²

11. METI Notice No. 71 (promulgated June 16, 2026, effective August 16, 2026) amending the list of technologies subject to advance reporting: https://www.meti.go.jp/policy/anpo/law_document/kokuji/20260616_kokuji_2.pdf ↩

12. METI, Export approval for CO2-containing gas: https://www.meti.go.jp/policy/external_economy/trade_control/boekikanri/download/export/2026/20260113_01_ex.pdf ; commentary by Anderson Mori & Tomotsune (February 2026): https://www.amt-law.com/asset/pdf/bulletins12_pdf/260213.pdf ↩

13. METI, About export classification and the goods and technologies matrix table: https://www.meti.go.jp/policy/anpo/matrix_intro.html ↩