Hello, this is Ryuta Hamamoto from TIMEWELL. Export-control beginners often ask: “What exactly are the 28 May 2025 semiconductor and quantum ‘21-item’ controls?” I walk that question carefully here, staying close to primary materials.
On 28 May 2025, FEFTA, the Export Trade Control Order, the Goods and Technologies Ordinance, and the Foreign Exchange Order Appended Tables were amended to add a total of 21 advanced semiconductor and quantum-related items to list controls (Appended Table 1). This is the second wave after the July 2023 semiconductor manufacturing equipment (23-item) controls. The net now reaches quantum, GAAFET (Gate-All-Around FET), and cryo-CMOS (cryogenic CMOS).
Media often frame this as “China-bound advanced semiconductor export controls.” The text does not name destinations. The architecture is all-destination licensing: a METI license is required in principle regardless of destination. Below I unpack that structure and how it sits next to U.S. Advanced Computing FDPR and the AI Diffusion Rule.
One note up front: “21 items” is a media label, not METI’s official term. Primary materials say “critical and emerging items.” I keep restating that so the label does not harden into “official fact.”
Work item by item, from both the Japanese and the US side: A fill-in checklist for advanced-computing ICs (3A090, 4A090, HBM) and semiconductor manufacturing equipment (3B series), classified from both Japan's Appended Table 1 Row 7 plus the goods ordinance and the US EAR (ECCN, TPP/PD thresholds, Country Group D:5, 744.23, FDP, license exceptions). Under all-destination licensing you can keep the route you walk for every item as a completed sheet for internal use and for customers. → Download the semiconductor classification checklist (Free. Registration with your company name and work email address is required.)
What you will learn
- Overall picture of the 28 May 2025 FEFTA / Export Trade Control Order amendments
- Contents of the “21 items” (9 manufacturing tools + 5 design tech + 4 ICs + 3 quantum)
- Meaning of all-destination licensing and how Group A general comprehensive licenses fit
- Application process (standard 90 days) and review criteria
- Complementarity with U.S. Advanced Computing FDPR and AI Diffusion Rule
- Affected Japanese companies and five practical steps
Three terms first
GAAFET (Gate-All-Around FET)
Transistor structure adopted from ~3 nm-class advanced logic onward. Unlike FinFET, the gate surrounds the channel on all sides, cutting leakage while raising performance. Samsung has used GAA from 3 nm; TSMC targets 2 nm. This reform expressly lists GAAFET IC design technology and production technology as separate controlled items.
cryo-CMOS (cryogenic CMOS)
CMOS ICs that operate near liquid-helium temperatures (~4 K) or colder for superconducting-qubit control and readout. Design and process differ from room-temperature CMOS. Intel, IMEC, and others research it as essential quantum-system technology. Listed as a standalone item alongside quantum computers.
All-destination licensing
Goods and technology under list control (Export Trade Control Order Appended Table 1) require a METI license in principle regardless of destination. That is not unique to emerging items. It is standard Appended Table 1 architecture. Media emphasize that the emerging 21 items stated worldwide scope from day one.
| Term | In one line | Role in this article |
|---|---|---|
| GAAFET | Advanced transistor from ~3 nm | Design tech + production tech (2 items) |
| cryo-CMOS | Cryogenic CMOS for qubit control | Standalone controlled item |
| All-destination licensing | License in principle for any destination | Core feature of the 21 items |
Amendment overview: when, what, how
Publication and entry into force
| Date | Event |
|---|---|
| 31 Jan 2025 | Public comment released (Mainichi, Nikkei, Bloomberg report “21 items”) |
| 25 Mar 2025 | Cabinet decision |
| 28 Mar 2025 | Cabinet order published |
| 3 Apr 2025 | Related ordinances published |
| 28 May 2025 | Entry into force |
Amended instruments include the Cabinet Order partially amending the Foreign Exchange Order and Export Trade Control Order, plus the Goods and Technologies Ordinance and FEFTA Appended Tables. Critical/emerging items, including the 21 semiconductor/quantum items, were added to list controls.
Legal architecture
Japan’s export control is a three-layer stack: FEFTA (statute) → Cabinet orders (FEFTA Order / Export Trade Control Order) → ordinances (Goods and Technologies Ordinance / Appended Tables). This package amended Cabinet orders and ordinances together; the FEFTA statute itself did not need amendment.
Internationally, it implements Wassenaar Arrangement (WA) and related multilateral consensus in domestic law, while also complementing U.S. China-related semiconductor controls. BIS has said publicly that allied export controls are not fully aligned with the U.S. Japan’s tightening helps close that gap.
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Breaking down the 21 items
“21 items” is media language; primary materials say “critical and emerging items.” Combining METI’s 28 March 2025 materials, 3 April amendment summary, CISTEC commentary, and reporting:
Category 1: Advanced semiconductor manufacturing equipment (9)
- Scanning electron microscopes (SEM) for semiconductor device/IC imaging
- Multi-beam mask writers (EUV mask)
- EUV lithography peripherals (mask pellicle production tools; additional EUV coat/develop tools)
- Advanced ALD (Atomic Layer Deposition) tools
- ALE (Atomic Layer Etching) tools
- Refined epitaxial growth tool specifications
- Refined anisotropic dry-etch tool specifications
- 3D packaging / advanced packaging tools
- Advanced reliability test equipment (advanced packaging)
July 2023’s 23 items centered on advanced-node manufacturing tools. This wave thickens next-gen process tools (ALD/ALE/3D packaging). Lasertec EUV mask inspection and Disco 3D-packaging dicing are watch areas for me when I map a Japanese tool portfolio.
Category 2: Advanced semiconductor design/production tech and software (5)
- Technology required to design GAAFET-structure ICs
- Technology required to produce GAAFET-structure ICs
- Multi-layer GDSII data generation programs (EDA-class layout-to-physical tools)
- Design tools for sub-14 nm nodes (mentioned at public-comment stage)
- Simulation software for 3D chip stacking
GDSII is the industry-standard layout data format; EDA covers circuit design, layout, and verification. Controlling GDSII generators affects EDA vendors and Japanese design houses. “Technology” is broad: know-how, process information, and software use rights.
Category 3: Advanced ICs and related devices (4)
- High-performance CMOS ICs
- Cryogenic CMOS circuits (cryo-CMOS for qubit control)
- Advanced IC chips
- Parametric signal amplifiers (qubit readout)
Cryo-CMOS and parametric amps form the quantum system’s control layer. The reform controls not only qubits but the peripherals that make them run.
Category 4: Quantum computers and peripherals (3)
- Quantum computers themselves (performance specs, e.g. fully controlled/connected/usable physical qubits 34–100 with C-NOT error ≤ 0.0001, or 100+ qubits meeting other performance levels)
- Technology required to design/produce quantum computers
- Cryogenic cooling equipment (dilution refrigerators / cryocoolers generating ~10 mK environments)
Exact numeric thresholds live in ordinance detail and may move with technology. Always check the latest ordinance text. Domestic dilution-refrigerator makers include ULVAC, among others.
The same 28 May 2025 package also refined other Appended Table 1/2 categories (heavy-water catalysts, iodine pentafluoride, metal AM tools, IR-explicit EM absorbers, high-temp ceramic composite coatings, and more). Those are WA specification refinements. They are not counted inside the media “21.”
Unpacking “all-destination licensing”
List-control baseline
Appended Table 1 goods require a METI license in principle for any destination: “all destinations license.” That architecture already applied to listed items. What is new is item addition and worldwide scope stated from the start for these emerging items.
Simplified procedures for Group A
| Group | Main countries/regions | Available license form |
|---|---|---|
| A (26) | U.S., Korea, Taiwan, UK, Germany, France, Netherlands, other WA participants | General comprehensive license (registration; no case-by-case filing) |
| B | Other WA members / selected states | Special / specific comprehensive licenses (more conditions) |
| C | Most other countries | Mainly individual licenses |
| D | UN arms-embargo destinations etc. | Presumption of denial |
Group A is the former “White country” set. Common misconception: Group A is not exempt. Procedures are lighter. Controls still apply. When Bloomberg and DCD stressed that Korea, Singapore, and Taiwan are “in scope,” that was the nuance they were trying to land.
Difference from prior practice
Some generic semiconductor-related items used to be handled with China-focused individual-license practice. The emerging 21 items put worldwide scope in the text from day one.
Practically, Group A can simplify via general comprehensive licenses, but maintaining those licenses raises compliance load: dedicated chief export officer and classification officers, annual audits, training.
Editorial note: Group A is not excepted from the 21 items (comprehensive licensing available; control still applies). Some high-concern quantum, cryogenic, and GAAFET items may be excluded from comprehensive licenses under ordinance carve-outs. Check the latest ordinance per product. Avoid over-generalizing.
Application process and review criteria
Standard individual-license flow
- Classification: self-assess whether items meet Appended Table 1 specs
- Export license application: METI Trade Control Department (paper or NACCS/CCAR)
- Attachments: end-use / end-user documentation
- METI review including inter-agency consultation (standard 90 days)
- License issuance for customs presentation
For emerging items with thin case history, 4–6 months is possible. Build lead time into tool delivery plans before sales promises it away.
Group A general comprehensive licenses
For companies mainly shipping to Group A:
- Appoint chief export officer and classification officer
- Submit registration to METI
- After registration, export without individual applications (with reporting duties)
Again: some quantum/cryogenic/GAAFET items may be carved out of comprehensive licensing. Verify ordinance exclusions.
Review criteria
- End-user review: military/defense research links; sanctioned parties
- End-use review: WMD / conventional-weapons diversion concern
- Catch-all link: unlisted items can still need licenses when use/user raise military diversion concern
- Foreign End User List: listed parties generally denied
The 9 October 2025 catch-all reform further strengthens complementary controls. Watch unlisted commercial goods as well as the 21 items.
Relationship with U.S. Advanced Computing FDPR and AI Diffusion Rule
Main U.S. controls
| Control | Timing | Content |
|---|---|---|
| BIS rule (7 Oct 2022) | Oct 2022 | Starting point for China advanced semiconductor/SME controls |
| BIS rule (17 Oct 2023) | Oct 2023 | Advanced Computing expansion; broader SME |
| BIS rule (Dec 2024) | Dec 2024 | HBM addition; Entity List expansion |
| FDPR | Ongoing expansion | Extraterritorial EAR on foreign-made items using U.S. tech/software |
| AI Diffusion Rule | Jan 2025 published | Compute allocation by country Tier (late Biden) |
FDPR variants include Advanced Computing FDPR, Entity List FDPR, and SME FDPR.
AI Diffusion Rule was published in January 2025 under Biden. The Trump Administration announced rescission in May 2025 while preparing alternatives. Japan was Tier 1 (18 allies) with license exceptions under AI Diffusion. Reporting suggests Japan retains comparable status under replacement designs.
Fit with Japan’s 21 items
Japan’s package is WA-based plus conscious complementarity with U.S. controls:
- Items the U.S. already targets for China are elevated in Japan to worldwide licensing architecture
- Including Group A (U.S., Korea, Taiwan, and others) helps block third-country diversion
- Avoids naming China; destination-neutral on its face
BIS has said allies are not fully aligned (especially semiconductors as “insufficient”). Japan’s tightening helps close that gap and signals Tier-1-worthy rigor.
Dual-compliance practice
Japanese companies making tools in Japan with U.S.-origin technology for China export may need:
- Japanese export license (when the 21 items apply; METI)
- U.S. EAR license (when FDPR applies; BIS)
Separate paper trails, authorities, and validity windows. Compliance load rises sharply. New work includes U.S.-origin content ratios, EAR status from suppliers, and synchronized dual filings. Honestly, this part is still messy in practice for mid-sized tool makers.
Affected Japanese companies
Semiconductor manufacturing equipment
- Tokyo Electron (coat/develop, etch, deposition)
- SCREEN Holdings (wet clean)
- Advantest (testers)
- Nikon (lithography / precision equipment)
- Lasertec (mask inspection, EUV-related)
- KOKUSAI ELECTRIC (batch ALD)
- Disco (dicing/grinding)
- Tokyo Seimitsu (metrology)
Tokyo Electron’s China revenue share was ~45% in FY2024 (controlled items are a subset). SCREEN, Advantest, and Lasertec often show 20–40% China shares, with the 21 items concentrated in higher-end lines.
Quantum hardware
- ULVAC (dilution refrigerators)
- Sumitomo Heavy Industries (cryocoolers)
- Hitachi, Fujitsu, NEC, Toshiba (quantum R&D)
- RIKEN-linked startups
Overseas R&D collaboration (IBM, European IQM, etc.) becomes licensed; sensitive tech sharing under joint research also triggers deemed export.
EDA / design tools / advanced packaging
- EDA: foreign majors plus Japanese agents and design houses
- Advanced packaging materials: Shin-Etsu, JSR, TOK
- Substrates: Shinko Electric, Ibiden
Deemed export impact
Deemed export treats providing controlled technology to foreign persons or persons under foreign organizational influence inside Japan like an export. Domestic transfers of 21-item technology to foreign researchers are in scope. After May 2022, transfers to Specified Category persons (e.g., under foreign government influence) are treated like destination exports.
University quantum/advanced-semiconductor labs are among the highest-risk environments. Align with the Sensitive Technology Management Guidance (5th edition, September 2025).
Five practical steps
Step 1: Inventory 21-item applicability
Map products and technology against the 21 items: Category 1 for tool makers, Category 2 for design/EDA, Categories 3–4 for quantum. Document non-applicability with classification sheets and parameter tables so reasoning is reproducible.
Step 2: Build end-user / end-use review
- Confirm customer business and organization form
- Military/defense research / sanctioned links
- Collect End User Statements
- Screen Foreign End User List and Entity List
Standardization and automation here cut lead time.
Step 3: Consider comprehensive licenses
If Group A dominates:
- Appoint chief export and classification officers
- Maintain Internal Compliance Programme (CP)
- Register with METI
- Annual audit and training
Confirm per-item exclusions from comprehensive licensing.
Step 4: Dual compliance with U.S. FDPR
For tools/parts made with U.S.-origin technology:
- Obtain EAR status from suppliers
- Track U.S.-origin content (de minimis)
- Internalize BIS license process
- Schedule Japan–U.S. dual filings
AI export-control agents help here. TRAFEED (formerly ZEROCK ExCHECK) is METI-aligned and supports transaction design across Japan–U.S. rules.
Step 5: Deemed export for R&D and university links
- Specified Category screening for foreign researchers
- Joint-research contract revisions (clear tech-transfer scope)
- Pre-publication checks for international co-authored papers
- Systems under Sensitive Technology Management Guidance 5th edition
Quantum and GAAFET research is internationally collaborative. Balance science and export control deliberately. That balance is a management choice, not a footnote.
FAQ
Q1. Are non-21-item products free to export?
No. Other Appended Table 1 items remain controlled. Unlisted items can still need catch-all licenses when use/user raise military diversion concern. Catch-all was further strengthened on 9 October 2025.
Q2. How do these relate to the 2023 semiconductor equipment 23 items?
2023 focused on advanced-node manufacturing tools; 2025’s 21 extend into next-gen quantum/GAAFET/cryo-CMOS. Both are cumulative Appended Table 1 additions.
Q3. What should SMEs do first?
Classify under CISTEC guidance. If 21-item exposure is plausible, appoint a classification officer and build end-user review. Consider general comprehensive licenses if Group A dominates. External security-trade consultants or export-control AI agents are options when resources are thin.
Q4. Penalties?
FEFTA: 3–10 years imprisonment; fines up to JPY 30 million or 5× transaction value (corporate dual liability); export bans up to 3 years. Multiple 2024–2025 administrative cases were published. Reputation and trade stoppage often exceed fines.
Q5. Comprehensive vs individual licenses: where to start?
Usually run individual licenses while building systems, then register for comprehensive licenses. Immediately after the 21-item entry into force, individual cases dominate as practice accumulates.
Latest developments as of July 2026
No major statutory rewrite of the 21 items themselves, but the surrounding economic-security frame is moving. At the 16th Japan–India annual summit on 2 July 2026, both sides issued a joint declaration on semiconductors, critical minerals (rare earths), clean energy, ICT (submarine cables), and pharmaceuticals with roughly ¥2 trillion of investment (Japan–India summit joint press conference (Prime Minister’s Office, 2 July 2026)). Rewiring semiconductor supply among partners connects to Group A comprehensive licensing and anti-diversion themes in this article. As of July 2026, item-level regulatory linkage is not yet confirmed, but export-control practice increasingly needs multi-country design. See Japan–India summit 2026 and economic security.
Summary
On 28 May 2025, FEFTA and Export Trade Control Order amendments added 21 advanced semiconductor and quantum items to list controls. “21 items” is media language. Primary materials say “critical and emerging items.”
Breakdown that I use in practice: 9 manufacturing tools + 5 design/EDA + 4 IC/cryo-CMOS + 3 quantum systems/coolers. All-destination licensing means a license in principle for any destination; Group A can simplify via general comprehensive licenses. Standard review sits near 90 days. End-use and end-user review is the core, not the form-filling.
If I had to name the largest practical challenge, it is dual compliance with U.S. Advanced Computing FDPR and the AI Diffusion Rule’s successors. Five steps still hold: classification, end-user review, comprehensive licenses, FDPR dual compliance, deemed export for R&D.
Export control needs accurate rule understanding and operational design. A year after entry into force, practice is accumulating. Dual U.S. application, item volume, and ordinance updates still keep desk load high.
TIMEWELL’s AI export-control agent TRAFEED (formerly ZEROCK ExCHECK) (TRAFEED service catalog (PDF)) is METI-aligned and multilingual. It supports 21-item applicability triage, Group A comprehensive-license operations, and parallel U.S. FDPR management.
If your questions sound like “Do our tools fall under the 21 items?”, “We want Group A comprehensive licenses,” or “We need dual Japan–U.S. compliance,” start at TRAFEED consultation. Service details: TRAFEED service page.
Related articles
- China dual-use export restrictions toward Japan (January 2026)
- China dual-use import/export license catalog 2026
- AI Diffusion Rule rescission and replacement trends
- Deemed export risk guide
- Export compliance program build guide
References
METI (primary)
- Amendment overview (April 2025 Cabinet/ordinance): https://www.meti.go.jp/policy/anpo/law_document/seirei/20250403_gaiyo.pdf
- Critical/emerging items materials (May 2025): https://www.meti.go.jp/policy/anpo/law_document/20250328_ristshiryou.pdf
- Cabinet decision press release (4 April 2025): https://www.meti.go.jp/press/2025/04/20250404001/20250404001.html
- Catch-all amendment materials (effective 9 Oct 2025): https://www.meti.go.jp/policy/anpo/law_document/20250409_catchallshiryou.pdf
- Security trade control overview (Dec 2024): https://www.meti.go.jp/policy/anpo/daigaku/seminer/r6/meti4.pdf
- Sensitive Technology Management Guidance 5th ed. (Sep 2025): https://www.meti.go.jp/policy/anpo/daigaku/guidance5.pdf
Public comment / statutes
- e-Gov public comment (Cabinet order draft): https://public-comment.e-gov.go.jp/pcm/1040?CLASSNAME=PCM1040&id=595125012&Mode=1
- Export Trade Control Order (e-Gov): https://laws.e-gov.go.jp/law/324CO0000000378/
Commentary
- CISTEC Cabinet/ordinance amendment note: https://www.cistec.or.jp/export/express/250403/250403.html
- EY Japan on security trade control strengthening: https://www.ey.com/ja_jp/technical/ey-japan-tax-library/tax-alerts/2025/tax-alerts-02-06-03
- Nishimura Asahi / Anderson Mori Tomotsune etc. on 23 semiconductor items: https://www.amt-law.com/asset/pdf/bulletins5_pdf/230407.pdf
- Anderson Mori English on catch-all Oct 2025: https://www.amt-law.com/en/insights/trending-news/trending-news_20250512001_en_001/
Reporting
- Nikkei on advanced semiconductor export-control tightening: https://www.nikkei.com/article/DGXZQOUA316FJ0R30C25A1000000/
- Mainichi on 21 semiconductor items added to list controls: https://topics.smt.docomo.ne.jp/article/mainichi/business/mainichi-20250131k0000m020326000c
- Jiji on dual-use technology export-control strengthening: https://www.jiji.com/jc/article?k=2025013101101&g=pol
- Bloomberg: Japan Plans to Curb Exports of Chips, Quantum-Computing Tech: https://www.bloomberg.com/news/articles/2025-01-31/japan-plans-to-curb-exports-of-chips-quantum-computing-tech
- Japan Times: Japan plans to curb exports of chips and quantum-computing tech: https://www.japantimes.co.jp/business/2025/02/01/tech/japan-plans-chip-export-curbs/
- DCD: Japan to expand export restrictions on semiconductor and quantum computing technology: https://www.datacenterdynamics.com/en/news/japan-to-expand-export-restrictions-on-semiconductor-and-quantum-computing-technology/
U.S.-related
- BIS semiconductor export-control press: https://www.bis.gov/press-release/department-commerce-implements-controls-quantum-computing-other-advanced-technologies-alongside
- Hogan Lovells: Japan's New Chip Equipment Export Rules Take Effect: https://www.hoganlovells.com/en/publications/japans-new-chip-equipment-export-rules-take-effect
- CSIS Translation (Japanese semiconductor export controls): https://www.csis.org/analysis/csis-translation-updated-japanese-export-controls-high-performance-semiconductor
- Stanford FSI: Japan's Export Control on Quantum Technology: https://fsi.stanford.edu/sipr/japan-qt
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