Hello, this is Hamamoto from TIMEWELL. Japan's semiconductor export controls have been tightened four times in less than three years: the 23 items of manufacturing equipment in July 2023, the critical and emerging items in May 2025, the overhaul of the supplementary export controls in October 2025, and the FPGA-embedded-equipment rule that took effect on February 14, 2026. Each amendment has been written up individually, in Japanese and occasionally in English. What is much harder to find is a single article that connects them and answers the practical question: what do Japan's semiconductor export controls actually look like today? That is what this piece sets out to do, with the effective dates and item lists verified against METI and CISTEC primary sources.
One note before we start. For the catch-all (supplementary) controls in general — how they differ from the list controls and how the 2025 overhaul reshaped them — see my companion guide on list controls versus catch-all controls. This article keeps its focus on semiconductors.
A fill-in classification checklist: For the list-control side of the four layers below, this sheet lets you classify advanced-computing ICs (3A090, 4A090, HBM) and semiconductor manufacturing equipment (3B-series) one item at a time — against Japan's Appended Table 1 Row 7 and the goods ordinance alongside the US EAR (ECCN, Country Group D:5, 744.23, FDP, License Exceptions). What you fill in doubles as your internal classification record and as the explanation you hand to a customer. → Download the Semiconductor Classification Checklist (Free. Registration with your company name and work email address is required.)
The Short Answer: Four Layers of Controls
Before the detail, here are the four amendments in one table. Use it to work out which layers touch your business.
| Effective date | Common name | Legal basis (promulgation) | What it means for semiconductors |
|---|---|---|---|
| July 23, 2023 | The 23 equipment items | Amendment to the Goods and Technologies Ministerial Ordinance (promulgated May 23, 2023) | 23 items of advanced semiconductor manufacturing equipment made subject to licensing for all destinations |
| May 28, 2025 | Critical and emerging items (21 items in press coverage) | Cabinet Order No. 102 of 2025 (promulgated March 28, 2025), plus ministerial ordinances of April 3 | Advanced semiconductor and quantum computing items added to the list controls |
| October 9, 2025 | Overhaul of the supplementary export controls | Cabinet Order No. 175 of 2025 (promulgated April 9, 2025) | Item 16(1) specified items created, covering integrated circuits and inspection equipment; end-user checks required even for general destinations |
| February 14, 2026 | FPGA-embedded equipment and the regular list amendment | Cabinet Order No. 376 of 2025 (promulgated November 14, 2025) | New Item 7(10-2) brings FPGA-carrying modules, assemblies, and equipment into scope |
The first two are expansions of the list controls, the third strengthens the catch-all controls, and the fourth returns to the list controls. Japan has been tightening both nets — the one that catches goods by specification and the one that catches transactions by end use and end user — in alternation.
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The Framework: Japan Regulates Exports Through Two Nets
A quick primer so the four amendments make sense. Japan's export regulations rest on the Foreign Exchange and Foreign Trade Act, implemented through the Export Trade Control Order (a cabinet order) and the Goods and Technologies Ministerial Ordinance, which define the controlled items.
The first net is the list controls: the goods enumerated in Items 1 through 15 of Appended Table 1. Semiconductor manufacturing equipment and integrated circuits sit mainly in Item 7, the electronics item. If a product's specifications exceed the thresholds, a license from the Minister of Economy, Trade and Industry is required regardless of destination. The second net is the supplementary export controls, better known as the catch-all controls, grounded in Item 16. Even for goods outside the list, a license is required when the exporter knows the goods may be used for weapons of mass destruction or conventional weapons, or when METI issues an individual notice (an "inform" notice).
The point to hold on to is that "not caught by the list controls" never means "no export control work to do." That two-net structure is exactly why the October 2025 amendment matters for semiconductors, as we will see below.
July 23, 2023: The 23 Items of Semiconductor Manufacturing Equipment
The starting point was the United States. On October 7, 2022, the US announced its export controls on advanced computing and semiconductor manufacturing items, adding deposition tools and other equipment to the EAR's control list (3B090 and related entries). Washington then pressed Japan and the Netherlands to move in parallel. Japan opened a public comment period on March 31, 2023, promulgated the amendment to the Goods and Technologies Ministerial Ordinance on May 23, 2023, and brought it into force on July 23, 2023 after the customary two-month notice period.
The 23 items were written into Article 6, Paragraph 1 of the ministerial ordinance — the provision corresponding to Item 7 of Appended Table 1 — as sub-items 17(ru) through 17(fu) and 17-2. The economy minister at the time described the measure as one that "complements the Wassenaar Arrangement." Adding controlled items on the strength of trilateral coordination, without waiting for consensus in the international regime, was close to unprecedented in Japanese export control practice.
The 23 Items at a Glance
| Process step | Items | Representative equipment |
|---|---|---|
| Cleaning | 3 | Equipment removing impurities under vacuum; equipment that modifies surface properties before removing impurities |
| Deposition | 11 | Cobalt electroplating tools, selective tungsten and molybdenum deposition tools, ruthenium interconnect deposition tools, atomic-layer deposition tools, EUV mask deposition tools |
| Annealing | 1 | Thermal treatment equipment that removes voids from thin films |
| Lithography | 4 | EUV pellicles and the equipment that manufactures them, coater-developers designed for EUV, ArF immersion lithography equipment |
| Etching | 3 | Etching tools for three-dimensional device structures, wet-chemical etching tools, high-aspect-ratio etching tools |
| Inspection | 1 | EUV mask inspection equipment |
Press reports framed the list as equipment needed to manufacture logic chips at the 10-to-14-nanometer generation and below, but the regulation itself defines the items by equipment specifications and process steps. Even so, a glance at the line-up — heavy on EUV and advanced deposition — makes the intent plain: the target is leading-edge logic and memory manufacturing capability.
An All-Destination Licensing Requirement Is Not an Embargo
This is the most common misunderstanding. The rule is not a country-specific ban; it is a licensing requirement covering all destinations. Exports to 42 countries and regions — the Wassenaar participants minus Russia and Japan, plus Taiwan and Singapore — can rely on bulk licenses with simplified procedures. Exports to the remaining roughly 160 countries, China among them, require individual licenses, and a license will not be granted where military diversion is a concern. Japan deliberately chose not to name China, and I think that design choice matters: it anchors the regulation's justification in diversion risk rather than in the identity of any one country.
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May 28, 2025: Critical and Emerging Items for Advanced Semiconductors and Quantum
The second wave came in 2025. Cabinet Order No. 102 of 2025, promulgated on March 28, together with ministerial ordinances and circulars promulgated on April 3, added a set of advanced semiconductor and quantum computing items to the list controls with effect from May 28, 2025. METI's official label is "critical and emerging items"; the figure of 21 items comes from press coverage rather than the regulation itself.
The substance is a generation beyond the 2023 list: items connected to GAAFET-structure integrated circuits, cryogenic CMOS, quantum computers and their components, and manufacturing equipment such as nanoimprint lithography and mask writing tools. For companies supplying equipment or materials in these areas, this amendment — not the 2023 one — is usually the one that bites.
October 9, 2025: The Supplementary Export Controls Overhaul and What It Means for Chips
The first two amendments were list-control stories. The third is different in kind. Cabinet Order No. 175 of 2025, promulgated on April 9, overhauled the supplementary (catch-all) export controls themselves with effect from October 9, 2025.
The overhaul has three pillars: a new inform-notice mechanism for Group A countries (the former whitelist) aimed at transshipment diversion; the split of Item 16 into Item 16(1) specified items and Item 16(2) everything else, with exporter-side end-use and end-user checks now mandatory for specified items even toward general destinations; and a new end-user requirement for UN arms-embargoed destinations. The full picture is in the list controls versus catch-all controls guide; here I will stay with the semiconductor angle.
Integrated Circuits and Inspection Equipment Are Now "Specified Items"
| # | Category | Touchpoint with the semiconductor supply chain |
|---|---|---|
| 1 | Machine tools | Precision machining of equipment parts and jigs |
| 2 | Radar, radio navigation, and radio remote-control equipment | Electronics dense with semiconductors |
| 3 | Integrated circuits | Commodity and consumer-grade chips themselves |
| 4 | Aircraft, spacecraft, and their parts | On-board semiconductors and electronics |
| 5 | Navigation instruments | Inertial navigation and guidance electronics |
| 6 | Inspection equipment | Includes semiconductor test and inspection equipment |
Categories 3 and 6 deserve your attention. Until this amendment, commodity ICs and inspection equipment outside the list controls required no checks for general destinations unless an inform notice arrived. Now, so long as the goods fall under the HS codes designated by METI's public notice, exporters must verify end use and end users themselves — including for shipments to China. This was the moment Japan's semiconductor export controls reached beyond leading-edge products into the commodity tier.
The End User List Grew to 835 Entities
Timed to the effective date, METI updated its End User List to 835 entities across 15 countries and regions, an increase of 87, published on September 29, 2025 and applied from October 9. Entities of concern for conventional weapons were listed for the first time. For semiconductor trading companies and component makers, the practical meaning is simple: the screening population your compliance team matches against has changed.
February 14, 2026: FPGA-Embedded Equipment Enters the Scope
The fourth and most recent step. Cabinet Order No. 376 of 2025, promulgated on November 14, 2025, created a new Item 7(10-2) in Appended Table 1 with effect from February 14, 2026, covering modules, assemblies, and equipment that incorporate field-programmable logic devices.
Standalone FPGAs were already list-controlled. The gap was that embedding a controlled chip inside a larger product could take the product out of scope — a loophole this amendment closes, using new concepts such as user-configurability and aggregate lookup table input count to draw the line. Notably, this provision is not a Wassenaar-agreed control; it carries a distinctly Japanese signature. If your products carry FPGAs, you now need classification work even if you never thought of yourself as an equipment maker. The thresholds and classification details are in my write-up of the February 2026 amendment to the Export Trade Control Order.
The Other Side of the Board: China's Countermeasures
Japan's tightening has a mirror image. On July 3, 2023, China's Ministry of Commerce and the General Administration of Customs issued Announcement No. 23 of 2023, placing eight gallium-related and six germanium-related items under export licensing with effect from August 1, 2023 — ten days before Japan's 23-item rule took effect, a timing that is hard to read as coincidence. The controls have since expanded into rare earths and related technologies, which we track in our map of China's rare earth export controls.
An aside from client conversations: the questions I hear most often lately are not about what leaves Japan but about what stops arriving. Companies in the semiconductor supply chain now have to manage outbound licensing risk and inbound material risk at the same table.
Which Layer Catches Your Product? A Three-Step Workflow
Faced with four layers of regulation, the practical starting point is straightforward. Work through three checks in order.
- Run the list-control classification. For semiconductor equipment and parts, compare your product specifications against Item 7 of Appended Table 1 and Article 6 of the Goods and Technologies Ministerial Ordinance. The 2023 equipment items, the 2025 critical and emerging items, and the 2026 FPGA rule are all caught at this step. If you lack the data, request parameter sheets from your suppliers.
- Even if the product is outside the list controls, check whether it is an Item 16(1) specified item. This test runs on HS codes, not specifications. If you handle integrated circuits or inspection equipment, build a mapping between your product codes and the HS codes designated in METI's notice.
- Complete the catch-all checks: verify end use, verify the end user, and screen counterparties against the 835-entity End User List. Decide in advance who escalates and how if an inform notice arrives.
A supplier request can be as simple as this: "To complete our classification under Japan's Foreign Exchange and Foreign Trade Act, could you provide a parameter sheet (classification report) for product X, keyed to Appended Table 1 of the Export Trade Control Order and the Goods and Technologies Ministerial Ordinance? We will use the result for export license applications and our internal records." For the documentation side, our guide to non-applicability certificates covers formats and wording.
A Five-Point Compliance Checklist
- A mapping of your product catalog against the four layers, at the part-number level
- An HS-code mapping for Item 16(1) specified items — essential if you handle commodity ICs or inspection equipment
- A written procedure for End User List screening: when to screen, how long to retain evidence, and who owns it
- An escalation flow for inform notices, from receipt to license application
- A standing process for absorbing amendments, with a named owner and a fixed cadence
The fifth point is the least glamorous and the hardest to sustain. Given that Japan has amended these rules every year since 2023, the safe assumption is that something will change again next year.
Frequently Asked Questions
Are exports of semiconductor manufacturing equipment to China banned outright?
No. The 23-item rule is a licensing requirement for all destinations, and licenses can be granted where there is no diversion concern. In practice, though, individual licenses for advanced equipment bound for China face a high bar, and the rule functions as a substantial restriction.
We make components and materials, not equipment. Does any of this apply to us?
Yes. Since October 2025, integrated circuits and inspection equipment outside the list controls are covered as Item 16(1) specified items, with mandatory end-user checks. And if your products carry FPGAs, the February 2026 amendment applies directly. "Equipment makers only" stopped being true in 2023.
What is the difference between the 23 items and the 21 items?
The 23 items are the semiconductor manufacturing equipment added with effect from July 23, 2023. The 21 items are the press label for the critical and emerging items — advanced semiconductor and quantum related — in force since May 28, 2025, which are not limited to equipment. The similar numbers cause constant confusion, but they are separate amendments.
Where should we start with classification?
Start with a full inventory of your export items and collect parameter sheets from suppliers. Then run the three-step workflow: Item 7 classification, the Item 16(1) HS-code check, and the catch-all end-use and end-user checks. If the volume is large, AI-assisted screening is worth evaluating.
Where TRAFEED Fits
Looking back over these three years, the real burden on companies is not that classification became harder — it is that the updating never ends. Cabinet orders, ministerial ordinances, public notices, and the End User List all move on separate schedules, and every move forces another revision of your internal mappings. Keeping up by hand has stopped being realistic.
TRAFEED, TIMEWELL's export control AI agent, converts primary sources such as METI's public notices and the End User List into machine-readable form and supports the full workflow from classification to end-user screening and audit-ready records. Its AI classification accuracy exceeds 95 percent (joint validation with Okayama University, in-house study), the classification method is covered by Japanese Patent No. 7862062, and it is in use at more than 20 organizations. If every amendment still triggers a late-night spreadsheet session at your company, take a look at TRAFEED.
Key Takeaways
- Japan's semiconductor export controls consist of four layers: the 23 equipment items (July 23, 2023), the critical and emerging items (May 28, 2025), the supplementary export controls overhaul (October 9, 2025), and the FPGA-embedded-equipment rule (February 14, 2026)
- The 23-item rule licenses all destinations: 42 countries and regions qualify for bulk licenses, while roughly 160 others, including China, need individual licenses
- Since October 2025, commodity integrated circuits and inspection equipment outside the list controls require end-user checks as Item 16(1) specified items, and the End User List has grown to 835 entities
- From February 2026, modules, assemblies, and equipment incorporating FPGAs are controlled — chip-level classification alone is no longer enough
- The practical workflow is three steps: list-control classification, the Item 16(1) HS-code check, and catch-all end-use and end-user verification, backed by a standing process for absorbing amendments
If you do one thing after reading this, make a one-page mapping of your products against the four layers. The exercise has a way of revealing exactly where your exposure sits.
Related Articles
- List Controls vs. Catch-All Controls: The Complete Comparison
- The February 2026 Amendment to the Export Trade Control Order: The FPGA Rule Explained
- A Map of China's Rare Earth Export Controls, 2025-2026
- How to Write a Non-Applicability Certificate
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References
METI (primary sources)
- Overhaul of the supplementary export controls (in force October 9, 2025): https://www.meti.go.jp/policy/anpo/apply-01/20251009_catchminaoshi/20251009catchall.html
- Supplementary export controls (catch-all) overview: https://www.meti.go.jp/policy/anpo/catchall.html
- Explanatory materials on the supplementary export controls overhaul (October 2025): https://www.meti.go.jp/policy/anpo/law_document/20250409_catchallshiryou.pdf
- Outline of the amendments for critical and emerging items (April 2025): https://www.meti.go.jp/policy/anpo/law_document/seirei/20250403_gaiyo.pdf
- Outline of the amendments to the Export Trade Control Order (November 2025): https://www.meti.go.jp/policy/anpo/law_document/seirei/20251114_gaiyo01.pdf
- Cabinet decision on the amendment to the Export Trade Control Order (November 11, 2025): https://www.meti.go.jp/press/2025/11/20251111001/20251111001.html
- End User List update press release (September 29, 2025): https://www.meti.go.jp/press/2025/09/20250929006/20250929006.html
- End User List: https://www.meti.go.jp/policy/anpo/law00.html#userlist
Cabinet orders: Cabinet Order No. 102 of 2025 (in force May 28, 2025), Cabinet Order No. 175 of 2025 (in force October 9, 2025), Cabinet Order No. 376 of 2025 (in force February 14, 2026)
CISTEC, law firms, and others
- CISTEC, outline of the ministerial ordinance amendment adding the 23 semiconductor equipment items (April 28, 2023): https://www.cistec.or.jp/service/doushikoku/handotai23_pubcome00.pdf
- CISTEC, commentary on the fiscal 2025 regular list amendment (November 18, 2025): https://www.cistec.or.jp/export/express/251117/12_kaisetsu.pdf
- CISTEC, China's export controls on gallium and germanium items (July 5, 2023): https://www.cistec.or.jp/service/uschina/20230704.pdf
- Anderson Mori & Tomotsune, overview of Japan's new semiconductor export control amendment (April 7, 2023): https://www.amt-law.com/asset/pdf/bulletins5_pdf/230407.pdf
- JETRO, China tightens export controls on gallium and germanium (October 2023): https://www.jetro.go.jp/biznews/2023/10/4bd6b4e86473c0f1.html
