Japan Adds Permanent Magnets, Perovskite Solar Cells and Six More Items to Pre-Contract Reporting (Effective August 16, 2026): The Obligation That Sits Outside List Control Licensing

This is Ryuta Hamamoto from TIMEWELL. On August 16, 2026, an amendment that is unusually easy for export control teams to miss takes effect in Japan: METI Notification No. 71, promulgated on June 16, 2026, adds technologies to the advance reporting obligation under the public-private dialogue scheme for strengthened technology management.¹

What makes this scheme awkward is not its substance but the fact that nothing in a typical company catches it before the deadline. Most companies have list-control classification built into their internal compliance program (CP), but this advance report is a separate obligation from licensing, and METI has explicitly said it is not asking companies to amend their CPs for it.² The practical result is that someone notices just before signing, or nobody notices at all and the contract gets signed.

So in this article I go through exactly what is being added on August 16 as confirmed against the official comparative table of the notification, break the scope question into four tests, and set out how to insert this step into your contract process.

One point first. Designating a technology as a "critical managed technology" is a regulatory classification. It is not a judgment that the company holding the technology, or the counterparty receiving it, is problematic. The technologies in scope are civilian technologies that Japanese manufacturers have built up over decades, and METI itself states that "the purpose is not to stop technology transfer but to ensure thorough and appropriate technology management."³ I am writing this from the position of the companies that have to live with the rule, not from the position of the regulator.

If you want to start from the form that records the decision: We publish the classification certificate and non-applicability certificate formats with a fill-in guide and Q&A (Word), plus four Excel sheets: the classification certificate, the item-by-item comparison schedule, a catch-all confirmation sheet, and a decision log. The advance report covered in this article is a separate obligation from a licence application, but the way you record who decided what and when is the same. You skip building the forms and can send them straight into internal approval or to a counterparty. → Download the classification certificate template set (Free. Your company name and work email are required.)

The eight items added on August 16, 2026

Here is the bottom line. The comparative table marks six places as newly inserted, which amount to eight individual technology items.¹ In every case the object is "technology relating to design or manufacture." Technology relating to use, and the export of goods themselves, are out of scope.²

Category	Technology added (design or manufacturing technology)
(a)(7) Electronic components	Film-type solder resist (resist used as insulating material to coat circuit boards)
(c)(3) Items used in manufacturing semiconductor integrated circuits	Liquid-type solder resist used in semiconductor manufacturing
(c)(4) Same as above	Gallium nitride semiconductor substrates, or ingots, boules and other preforms, with an electrical resistivity of 0.01 ohm-centimeter or less at a temperature of 20 degrees
(i) Permanent magnets (new category)	Permanent magnets
(j)(1) Solar cells and items used to manufacture them (new category)	Solar cells using compounds with a perovskite structure, and modules formed by connecting them in series or parallel (including those laminated with cells other than perovskite cells)
(j)(2) Same as above	Laser processing machines used to manufacture perovskite solar cells or modules
(k)(1) Optical components and items used to manufacture them (new category)	Scintillators used for X-ray detection (limited to sintered bodies or sheets) whose output light spectrum has a full width at half maximum below 50 nanometers, and the phosphors used to manufacture them
(k)(2) Same as above	Arrays of the scintillators above (limited to sintered bodies)

Read by category label, the notification previously ran from (a) electronic components, (b) carbon fiber and silicon carbide fiber, (c) items used in manufacturing semiconductor integrated circuits, (d) electron microscopes, (e) items used in manufacturing metal products, (f) storage batteries, (g) items used in manufacturing displays, through (h) endoscopes: eight categories. The new (i), (j) and (k) take it to eleven.¹

Worth pausing on: permanent magnets enter as a single line, "technology relating to the design or manufacture of permanent magnets," with no sub-items narrowing it by application or specification. Other categories are bounded by numerical thresholds or end uses; this one reads as design and manufacturing technology for the magnet itself. If magnets are in your portfolio, read that line in the notification text before you start debating scope internally.

One caveat on sourcing: as of this writing (July 30, 2026) I could not find a published consolidated text of the notification reflecting the August 16 amendment. The notification linked from METI's scheme page is still the version last amended effective January 14, 2026.⁴ What is set out above is therefore what can be confirmed from the comparative table published on METI's amendment-information page.¹⁵

The 19 technologies already in scope

Looking only at the additions will not tell you where you stand, so here is the existing list. METI's overview material (November 2025) sets out the technologies in scope as of November 14, 2025, numbered 1 through 19.³

No.	Technology in scope	Brought into scope
1	Multilayer ceramic capacitors	At launch (applied from December 30, 2024)
2	Surface acoustic wave filters or bulk acoustic wave filters	At launch
3	Electrolytic copper foil (limited to circuit-board grade equivalent to or better than Class U of IPC-4562B)	At launch
4	Dielectric film (limited to smoothing film capacitors used in energy control units of electric vehicles)	At launch
5	Synthesis of barium titanate powder	At launch
6	Manufacture and firing of carbon fiber precursor	At launch
7	Manufacture and firing of silicon carbide fiber precursor	At launch
8	Semiconductor lithography resist (optimized for use with light of wavelength 248 nm or shorter)	At launch
9	Technology required to manufacture non-ferrous metal target material (limited to wiring processes for integrated circuits formed with EUV equipment)	At launch
10	Scanning electron microscopes or transmission electron microscopes	At launch
11	Sensor elements, magnetic circuits and related items using giant magnetoresistance or tunnel magnetoresistance effects	June 9, 2025
12	Manufacture of titanium sponge (limited to pressure and temperature control in the step separating titanium from titanium chloride by magnesium reduction, and to crushing and packing steps)	June 9, 2025
13	Binder materials for lithium-ion batteries (principally polyvinylidene fluoride, styrene-butadiene rubber or polyacrylic acid)	June 9, 2025
14	Sulfide solid electrolytes (lithium-ion conductivity at room temperature of 0.1 mS/cm or more in the glass state; 1 mS/cm or more in the crystallized glass or crystallized state)	June 9, 2025
15	Screw configuration of twin-screw extruders used to manufacture lithium-ion battery separators	June 9, 2025
16	Quantum dots	January 14, 2026
17	Materials with thermally activated delayed fluorescence (TADF) properties for OLED displays	January 14, 2026
18	Retardation film	January 14, 2026
19	Insertion portion of flexible endoscopes (rigid tip diameter of 16 mm or less) meeting any one of the following: more than 2 million total pixels; field of view above 120 degrees at a 0-degree viewing direction; or, for ultrasound endoscopes, a non-zero viewing direction with a field of view of 100 degrees or more	January 14, 2026

From August 16, the eight items in the previous section sit on top of these 19. A note on arithmetic: the "27 items" total is my own addition of the two, not a figure published by METI, so it is safer to hold the breakdown in mind rather than the sum.

What stands out about the list is that almost every line is core territory for Japanese materials and components manufacturers. METI's overview material states that the screening criterion for technologies is those "that other countries are interested in acquiring and in which Japan holds indispensability or an advantage."³ In other words, the stronger the position, the more likely inclusion — which is precisely why inclusion says nothing negative about the company or the transaction.

Why "separate from list control" matters

This is where misunderstanding is most common. In day-to-day export control you classify against the list first (see list control versus catch-all control) and obtain a license if the item is caught. The advance report is a second obligation sitting outside that.

METI's Q&A 1-1 states that "the provision of list-controlled technology is subject to a separate license application and falls outside the reporting obligation under this measure."² Item 2 of the notification explains why. A "critical managed technology" is defined as a technology listed in the middle column of Row 16 of the Appended Table of the Foreign Exchange Order — that is, the complementary (catch-all) control — where, if the recipient fails to manage the information appropriately after provision, specified concerns arise, and which is enumerated in the notification.⁶

The two obligations compare as follows.

Aspect	Provision of list-controlled technology	Advance report under the scheme
Legal basis	Service transaction license under the Foreign Exchange Act	Foreign Exchange Act Article 55-8 (other reports)7
Technology in scope	Technology caught by list control	Technologies in Row 16 of the Appended Table of the Foreign Exchange Order that are enumerated in the notification6
Required action	Obtain a license	File a report
Timing	License before provision	File before the contract is concluded6
Destinations	Varies by destination	All foreign countries other than the 27 listed in Appended Table 3 of the Export Order68
Nature of technology	Design, manufacture, use	Design or manufacture only (use is out of scope)2
Goods	In scope	Out of scope2
Penalties	Article 69-7	Article 71, item 97

The layered structure of the law is worth having at hand when you explain this internally. Article 55-8 of the Foreign Exchange Act empowers the competent minister to require reports.⁷ Article 18-8, paragraph 1 of the Foreign Exchange Order provides that where such a report is sought, the matters to be reported shall be designated "by notice to those persons or another method prescribed by Ministry of Finance Ordinance or Ministry of Economy, Trade and Industry Ordinance."⁹ Article 10, paragraph 3 of the Ordinance on Trade Relations Invisible Trade (the "Invisible Trade Ordinance") then provides that the minister shall "order the submission of the necessary report, specifying the matters to be reported by way of a notification (kokuji) or a notice," and paragraph 4 requires the person so ordered to "submit the report without delay."¹⁰ That notification is the instrument amended here. Statute, cabinet order, ministerial ordinance, notification: four layers, with the deadlines and the technology list moving in the bottom one. Which is exactly why you miss it if you are not tracking notification amendments.

Four tests for whether a report is required

Scope is the product of four factors — technology, type of act, destination country, and timing. Fail any one of them and no reporting obligation arises.

First, the technology. It must be "technology relating to the design or manufacture" of an item enumerated in the notification. Technology relating to use is excluded,² and the export of goods is itself outside the measure.² Even when you provide design or manufacturing technology for production equipment, the transaction is out of scope so long as it does not involve providing design or manufacturing technology for the items listed in the notification.²

Second, the type of act. METI's overview material states that the scope is, "for the time being, limited to technology transfers that enable manufacturing or product development in another country, such as transfers of manufacturing to local subsidiaries and joint ventures, and contract manufacturing or licensing to companies in other countries," and expressly excludes licensing that does not involve direct technical instruction.³ Licensing published patents is likewise out of scope, though it can come into scope if accompanied by the provision of non-public know-how or technical instruction.² Whether the recipient is a wholly owned subsidiary or a local joint venture makes no difference.²

Third, the destination. Item 1 of the notification covers provision in "a foreign country other than the regions listed in Appended Table 3 of the Export Trade Control Order."⁶ Appended Table 3 comprises 27 countries: Argentina, Australia, Austria, Belgium, Bulgaria, Canada, the Czech Republic, Denmark, Finland, France, Germany, Greece, Hungary, Ireland, Italy, the Republic of Korea, Luxembourg, the Netherlands, New Zealand, Norway, Poland, Portugal, Spain, Sweden, Switzerland, the United Kingdom and the United States.⁸ Everything not on that list is in scope, which means Mexico, India, the ASEAN countries and Taiwan — destinations where a great many Japanese companies run contract manufacturing and joint ventures every day. This is not a classification aimed at any particular country; it reuses the existing Appended Table 3 grouping. Ordinary civilian transactions falling inside a broad category is a consequence of that design choice, and it helps to read it that way.

Fourth, the timing. The report must be filed "before the contract for the transaction concerned is concluded."⁶ This is the part that departs most from export control instincts. A license needs to be in hand before shipment or before provision; this report is triggered at contract stage, when no technology has moved yet.

Item 1 of the notification also carries exclusions. Sub-item (a) covers transactions falling under the items of Article 9, paragraph 2 of the Invisible Trade Ordinance other than items 7 and 8. That paragraph enumerates "service transactions not requiring a license," with item 9 covering technology already in the public domain, item 10 research activities in basic science, and item 11 the minimum technology necessary to file or register industrial property rights.⁶²¹⁰ Sub-item (b) covers transactions whose sole purpose is to enable inspection, testing or quality assurance, and similar transactions, where it is clear that the specified concerns are slight. Q&A 1-10 gives three examples.²

• Provision of technical information required by the laws of the destination country or region in connection with exporting the item, where that requirement is also common in other countries or regions
• Hosting factory tours and similar activities, where the content is not limited to a specific company and is generally provided on request to unspecified business partners
• Provision of product information as part of sales activities, where the content is not limited to a specific company and is generally provided on request to unspecified business partners

Where you conclude that an exclusion applies, document the basis. Every one of these exclusions turns on findings of fact — whether something is already public, whether technical instruction is involved — and whether a reporting obligation existed may be examined later, working back from the contract date. Without the material you relied on at the time, the judgment cannot be reconstructed.

Additional provision under existing projects is the biggest gap

In preparing for August 16, the most commonly missed exposure is not new contracts but existing ones.

Q&A 1-5 says that technology provision completed before the notification takes effect is not caught retroactively, but adds: "if you provide new technology that had not been provided before the effective date — for example, additionally providing drawings or process information for a new product — that falls within the scope of reporting."² If you hand a new drawing or a new recipe to an existing joint venture or contract manufacturer on or after August 16, that can be reportable.

Q&A 1-14 goes further on minor specification changes: "where technology is additionally provided in order to improve performance, reporting may be required even if the business operator regards the change as minor." It also notes that "where future version upgrades are anticipated in advance, reporting that plan together with the initial report may make a further report unnecessary."² For relationships built on continuous improvement, filing once at project level, plan included, is the lighter operating model.

The flow of drawings and recipes to overseas sites runs through the same channels as deemed exports and export control risk in drawings. If you already maintain an inventory of technology provision, adding one column to that register is the shortest route.

What happens after you file

"Reporting obligation" sounds forbidding, but reading how the scheme is built, the report is an entry point rather than an endpoint. It is designed in three stages.³

1. Advance report. Reporting before the contract is made mandatory under Article 55-8 of the Foreign Exchange Act. Because the report is "merely the trigger for the public-private dialogue, the reporting items are kept to the necessary minimum (a one-page form)."
2. Public-private dialogue. After establishing a shared understanding of the current situation and the issues, government and industry examine technology management measures together, through consideration of support measures, provision of information on concerns, and advice on specific countermeasures.
3. Inform. Where concerns about technology leakage are not dispelled, an "inform" requiring a license application may be issued. That said, the material states that "as a general rule, the aim is resolution through dialogue on the basis of a relationship of trust."

METI's overview material states plainly that "the purpose is not to stop technology transfer but to ensure thorough and appropriate technology management," and that no inform is issued where the dialogue dispels concerns about technology management.³ The material on the government's side of the exchange is also spelled out: information on concerns relating to counterparties, examples of technology leakage and countermeasures at other companies, and international security concerns surrounding the technology.² That is information most companies cannot easily assemble on their own, so treating the dialogue as a source rather than a cost is the rational stance.

The timeline is published as well. Whether to issue an inform is to be decided, as a general rule, within 30 days of the advance report, taking account of how the technology-management discussion between the operator and the relevant industry division is progressing.³ Q&A 3-1 restates this — no fixed number of days before signing is prescribed, METI expects to decide within 30 days as a general rule, and some cases may require longer, so early consultation is recommended.² Consulting before the details of the contract are settled is expressly possible.²

The mechanics of filing are light. You download the form (Word) from METI's page, complete it, and send it to a dedicated mailbox (bzl-gijutsukanri-jizenhokoku(at)meti.go.jp, replacing (at) with @); a completed example is attached as the second page.⁴ I was not able to retrieve the form file itself this time, so I will not enumerate its fields. What I can confirm is the description of it as "the reporting items are kept to the necessary minimum (a one-page form)."

The penalty sits on a different provision, at a different level

For the sake of calibrating internal urgency, it is worth reading the penalty provisions rather than paraphrasing them.

Failure to report falls under Article 71 of the Foreign Exchange Act, which provides for "imprisonment for not more than six months or a fine of not more than 500,000 yen," with item 9 covering the case where a person "fails to report, or makes a false report, in violation of an order under Article 55-8." For legal entities, the dual liability provision in Article 72, paragraph 1, item 5 applies the fine in the relevant article.⁷

Unlicensed service transactions, by contrast, fall under Article 69-7, paragraph 1, item 1: "imprisonment for not more than seven years or a fine of not more than 20 million yen, or both," and for legal entities, up to 700 million yen under Article 72, paragraph 1, item 2 (or, where five times the value of the subject matter exceeds 700 million yen, up to five times that value).⁷ Different orders of magnitude. I have set out the penalty structure in more detail in penalties for Foreign Exchange Act violations.

The operating practice matters more than the maximum. Q&A 3-6 states that "guidance and advice under the Foreign Exchange Act may be given in respect of a failure to report. Where, even after that, there is no indication of an intention to improve and the case is judged to be egregious, it may become subject to penalties."² The overview material likewise puts guidance, advice and improvement orders first,³ and the interim report of the industry structure council said that "if an advance report is not filed, except in egregious cases, the response should be a careful guidance process based on the compliance standards for exporters."¹¹ This is not a regime where a missed report leads straight to criminal liability. But fixing it after receiving guidance and having the step in place before August 16 are very different things to explain internally.

Why the step does not appear in internal workflows

Here is the core of it. Legally this is a reporting obligation that bites before signing, yet it rarely makes it into internal procedure manuals. Three reasons, all of them verifiable facts rather than my speculation.

First, no CP amendment is requested. Q&A 3-7 states that "in connection with the introduction of this system, business operators are not being asked to amend their existing internal compliance programs (CP)," while adding that "voluntary amendment of a CP in light of this system is not precluded. If you make an amendment, please file a notification of the change."² CPs are normally revised in response to externally requested items. With no request, the topic never reaches the CP revision agenda, and the step never gets created.

Second, the information lives on two different pages. As of July 30, 2026, the related-legislation section of METI's scheme page (anpo08.html) links to the notification as last amended effective January 14, 2026, and the overview material posted there is the November 2025 version listing 19 technologies.⁴ The August 16 amendment appears as a comparative table on the amendment-information page (law09-2.html) instead.⁵ The teams most likely to miss the addition are the ones diligently checking the scheme's own landing page.

Third, the Q&A has not caught up with the added technologies. It is marked "prepared April 9, 2025" and "to be revised as necessary," and I could not confirm a revised version covering the August 16 additions. Q&A 2-4 in particular reads to the effect that solder resist is not reportable under this measure, whereas film-type and liquid-type solder resist come into scope on August 16.¹² Relying on that older wording to reach a conclusion about the post-August 16 position would be a mistake.

None of this is a criticism of how METI runs the scheme; it is friction that arises as a live regime expands in stages. But signing a contract without knowing the friction exists is a loss borne by the company, so it is worth holding as fact.

Seven steps to be ready by August 16

Roughly two and a half weeks remain. In priority order:

1. Reconcile the 27 items against your own technology. Take the list of 19 plus 8 and match it against what you design and manufacture. The unit of assessment is not the product but "technology relating to design or manufacture," so working from the technical information side — drawings, recipes, process conditions, tooling design — catches more than working from the product catalogue. Among the new additions, the relevant territory is solder resist (film and liquid), GaN substrates and ingots, permanent magnets, perovskite cells and modules plus the laser processing machines used to make them, and X-ray scintillators, their phosphors and scintillator arrays.

2. List overseas deals scheduled for signature on or after August 16. Cover transfers of manufacturing to local subsidiaries and joint ventures, contract manufacturing abroad, and licensing accompanied by technical instruction, and line them up against planned signing dates. If the destination is outside the 27 countries in Appended Table 3, it belongs in the assessment queue.

3. Check planned additional provision under existing projects. As noted, this is where gaps appear. Ask your engineering teams whether new drawings or process information are due to go to existing contract manufacturers or joint ventures on or after August 16. For projects with continuous version upgrades, consider reporting the plan as a whole.²

4. Put a check gate immediately before signature. Insert a line item — "advance reporting requirement for critical managed technology confirmed" — immediately before internal approval, legal review, or execution. You do not need to wait for a CP revision; one added line on the contract review checklist or the approval form is enough. If you do amend the CP, file the notification of change.² I have written separately about building an internal compliance program.

5. Work back at least 30 days from the signing date. The inform decision is expected within 30 days as a general rule, with the caveat that some cases take longer.² Filing 30 days out, or 45 to be comfortable, keeps a pending decision from holding up execution. Pre-filing consultation is available before the details are fixed.

6. Record the basis when you conclude an exclusion applies. Public domain, inspection and quality assurance only, licensing without technical instruction — each of these involves findings of fact. Record the decision maker, the date, the provision relied on (notification Item 1(a) or (b); the relevant item of Article 9, paragraph 2 of the Invisible Trade Ordinance) and the reasoning. Keeping "reported" and "assessed as not reportable" in the same register is the practical arrangement.

7. Change how you monitor. Add the amendment-information page (law09-2.html) to your regular checks alongside the scheme page. Where a judgment is genuinely unclear, the same dedicated mailbox that receives reports also serves as the inquiry channel.⁴

Universities and research institutions are not outside this. Q&A 1-11 states that "a joint research activity as such is not subject to reporting, but where design or manufacturing technology is provided within it, that act is in scope," and that scope is determined "regardless of the type of entity — whether a company or a university or research institution — based on what kind of technology provision is taking place."² The test is the content of the technology provision, not the type of entity. Universities with departments touching listed technologies through industry collaboration need the same gate in their research contract process.

The context this rule sits in

Finally, some background from the primary record on why the scheme took this shape.

The starting point is the interim report of the Subcommittee on Security Export Control of the Trade and Commerce Committee of the Industrial Structure Council, published on April 24, 2024.¹² That report incorporated the "establishment of a new public-private dialogue scheme for strengthened technology management." The related ministerial ordinance and notification were promulgated on October 30 of the same year, and the notification itself provides that it applies from December 30, 2024.⁶⁴

The interim report noted that taking account of the risk of military diversion arising over time is already within the existing catch-all provision (Article 9, paragraph 2, item 7 of the Invisible Trade Ordinance) and could be addressed through a change in operation, but concluded that because that provision mirrors the catch-all provision for goods, "it is appropriate to establish a provision clarifying that the measure to be introduced applies only to the provision of technology."¹¹ The design responds to the fact that technology becomes harder to manage as time passes after transfer, and the measure leaves goods out of scope entirely.³¹¹ For the structure of catch-all control itself, see what catch-all control is.

Consideration for industry was written into the report as well. On mandating pre-contract reporting, it said that "the technologies and types of acts covered should be expressly set out in law," that "in order to minimize the impact on business, the government needs to indicate in advance how much time the process will take," and that the government "should coordinate with industry from the stage of selecting the technologies in scope, so that companies can recognize for themselves that they hold a covered technology." On types of acts, it warned that cross-licensing, widely used for efficiency, and a blanket regulation of joint research could impede innovation, and that scope should be limited for the time being and reviewed in light of actual cases.¹¹

Section 2.2 of the report — the section that builds the scheme — closes with a sentence worth keeping: "While it is necessary to strengthen technology management under the public-private dialogue framework, it is necessary to avoid a result in which companies are obstructed in their overseas business. The government is required to exercise sufficient care in operating this measure and to respond appropriately where companies actually face unreasonable situations."¹¹ That is a line companies can cite. If the operation of the rule feels unreasonable in a specific case, it is the premise the council itself set out.

Technologies have been added twice so far — effective June 9, 2025 (Notification No. 63) and January 14, 2026 (Notification No. 166) — and Notification No. 71, effective August 16, 2026, is the third round.¹¹³¹⁴ I could not find published material stating the reasons for selecting the six provisions added this time. The most recent (19th) meeting of the subcommittee was held on April 10, 2026 on the agenda "current circumstances surrounding security export control and future direction," but the published materials are the list of members, the handling of proceedings, and the summary record; the substantive discussion materials are not public.¹⁵ I will not speculate about the selection rationale. What I will say is that building your process on the assumption that this pace of addition continues is the realistic choice.

Summary

• On August 16, 2026, METI Notification No. 71 adds eight items (six newly inserted provisions) to the advance reporting obligation under the public-private dialogue scheme: solder resist (film and liquid types), GaN semiconductor substrates and related preforms, permanent magnets, perovskite solar cells and the laser processing machines used to make them, and X-ray scintillators, phosphors and arrays
• This report is separate from list-control licensing. Scope is limited to technologies in Row 16 of the Appended Table of the Foreign Exchange Order that are enumerated in the notification, and only design or manufacturing technology counts — technology relating to use, and goods, are out of scope
• The filing deadline is before the contract is concluded. Destinations in scope are all foreign countries other than the 27 in Appended Table 3 of the Export Order, which covers many everyday manufacturing destinations
• Because METI does not request CP amendment, the step does not appear in internal contract workflows on its own. Adding one line immediately before internal approval or legal review is the minimum viable response
• The inform decision is expected within 30 days as a general rule, so working back from the signing date with margin is the safe approach
• A missed report is handled through guidance and advice first, but having the step in place before August 16 makes the internal conversation far easier
• Designating a technology is a regulatory classification, not a judgment about the company that holds it or the counterparty that receives it

Track notification amendments, reconcile the 27 items against your technology register, and place a check gate ahead of contract execution. The work itself is unglamorous, but because the list expands in stages, what you really need is a way to keep that reconciliation table current. TRAFEED, our own service, supports classification and counterparty screening with AI and keeps an audit trail of the judgments; carrying obligations that sit outside licensing — like this advance report — on the same register means you are not redoing the inventory from scratch every time a notification changes.

See the TRAFEED service details

Related articles

• List control versus catch-all control
• What catch-all control is
• Deemed exports and the "specified categories"
• Export control risk in drawings
• Building an internal compliance program (CP)
• Penalties for Foreign Exchange Act violations

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References

• METI, comparative table for Notification No. 71 (promulgated June 16, 2026; effective August 16, 2026)
• METI, Security Export Control, "Related Legislation and Amendment Information"
• METI, Trade and Economic Security Bureau, "Public-Private Dialogue Scheme for Strengthened Technology Management" (November 2025)
• METI, consolidated text of the notification on matters to be reported by persons intending to conduct transactions for the purpose of providing critical managed technology
• METI, "Q&A on the Public-Private Dialogue Scheme for Strengthened Technology Management" (prepared April 9, 2025)
• METI, "Public-Private Dialogue Scheme for Strengthened Technology Management" landing page
• Industrial Structure Council, Trade and Commerce Committee, Subcommittee on Security Export Control, Interim Report (April 24, 2024)
• e-Gov Law Search: Foreign Exchange and Foreign Trade Act; Foreign Exchange Order; Ordinance on Trade Relations Invisible Trade; Export Trade Control Order

Footnotes

1. METI, "Notification of the Ministry of Economy, Trade and Industry No. 71, comparative table" (promulgated June 16, 2026; effective August 16, 2026) https://www.meti.go.jp/policy/anpo/law_document/kokuji/20260616_kokuji_2.pdf ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶

2. METI, "Q&A on the Public-Private Dialogue Scheme for Strengthened Technology Management" (prepared April 9, 2025; to be revised as necessary) https://www.meti.go.jp/policy/anpo/250409_kanmintaiwa-qa.pdf ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸ ↩⁹ ↩¹⁰ ↩¹¹ ↩¹² ↩¹³ ↩¹⁴ ↩¹⁵ ↩¹⁶ ↩¹⁷ ↩¹⁸ ↩¹⁹ ↩²⁰ ↩²¹ ↩²² ↩²³ ↩²⁴

3. METI, Trade and Economic Security Bureau, "Public-Private Dialogue Scheme for Strengthened Technology Management" (November 2025 overview material) https://www.meti.go.jp/policy/anpo/251114_kanmintaiwa-gaiyo.pdf ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸ ↩⁹

4. METI, "Public-Private Dialogue Scheme for Strengthened Technology Management" (reporting procedure and related legislation; as retrieved on July 30, 2026 the related-legislation section links to the version effective January 14, 2026) https://www.meti.go.jp/policy/anpo/anpo08.html ↩ ↩² ↩³ ↩⁴ ↩⁵

5. METI, Security Export Control, "Amendment Information" (the June 16, 2026 entry describes the change as the addition of technologies to the public-private dialogue technology management scheme) https://www.meti.go.jp/policy/anpo/law09-2.html ↩ ↩²

6. METI, notification on "Matters to Be Reported by Persons Intending to Conduct Transactions for the Purpose of Providing Critical Managed Technology under Article 10, Paragraph 3 of the Ordinance on Trade Relations Invisible Trade" (Notification No. 178, consolidated text as last amended by Notification No. 166, effective January 14, 2026) https://www.meti.go.jp/policy/anpo/law_document/kokuji/20251114_kokuji.pdf ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸

7. e-Gov Law Search, "Foreign Exchange and Foreign Trade Act" (Act No. 228 of 1949), Articles 55-8, 69-7, 71 and 72 https://laws.e-gov.go.jp/law/324AC0000000228 ↩ ↩² ↩³ ↩⁴ ↩⁵

8. e-Gov Law Search, "Export Trade Control Order" (Cabinet Order No. 378 of 1949), Appended Table 3 https://laws.e-gov.go.jp/law/324CO0000000378 ↩ ↩²

9. e-Gov Law Search, "Foreign Exchange Order" (Cabinet Order No. 260 of 1980), Article 18-8 https://laws.e-gov.go.jp/law/355CO0000000260 ↩

10. e-Gov Law Search, "Ordinance on Trade Relations Invisible Trade" (Ministry of International Trade and Industry Ordinance No. 8 of 1998), Article 9, paragraph 2 and Article 10, paragraphs 3 and 4 https://laws.e-gov.go.jp/law/410M50000400008 ↩ ↩²

11. Industrial Structure Council, Trade and Commerce Committee, Subcommittee on Security Export Control, "Interim Report" (April 24, 2024), pp. 9-11 https://www.meti.go.jp/shingikai/sankoshin/tsusho_boeki/anzen_hosho/pdf/20240424_1.pdf ↩ ↩² ↩³ ↩⁴ ↩⁵

12. METI, "Industrial Structure Council, Trade and Commerce Committee, Subcommittee on Security Export Control, Interim Report" page https://www.meti.go.jp/shingikai/sankoshin/tsusho_boeki/anzen_hosho/20240424_report.html ↩

13. METI, "Notification of the Ministry of Economy, Trade and Industry No. 63, comparative table" (promulgated April 9, 2025; under its supplementary provisions the technology-adding amendments — inserting (a)(6), (e) and (f) — took effect "on the day on which two months have elapsed from the date of promulgation," that is, June 9, 2025). The linked PDF compiles the notifications promulgated that day; No. 63 begins at p. 48 and its supplementary provisions are on p. 54 https://www.meti.go.jp/policy/anpo/law_document/kokuji/20250409_kokuji.pdf ↩

14. METI, "Notification of the Ministry of Economy, Trade and Industry No. 166, comparative table" (promulgated November 14, 2025; effective January 14, 2026) https://www.meti.go.jp/policy/anpo/law_document/kokuji/20251114_houkokukokuji.pdf ↩

15. METI, "Summary Record of the 19th Meeting of the Subcommittee on Security Export Control, Trade and Commerce Committee, Industrial Structure Council" (held April 10, 2026) https://www.meti.go.jp/shingikai/sankoshin/tsusho_boeki/anzen_hosho/pdf/019_gijiyoshi.pdf ↩