List Controls vs Catch-All Controls in Japan: Comparison Tables Plus the October 9, 2025 Amendment [2026 Edition]

Hello, this is Ryuta Hamamoto from TIMEWELL. When people start Japanese export control, the first wall is almost always the same: what is the difference between list controls and catch-all controls? Here is the answer in one table up front.

Dimension	List controls	Catch-all controls (complementary export controls)
What is regulated	Items enumerated in rows 1–15 of Appended Table 1 of the Export Order (the item itself)	Nearly all other goods and technology (row 16; excluding food, lumber, and the like)
Decision criteria	Item and specifications (classification)	End use and end user (objective requirements), plus inform notices from the METI Minister
Destinations	All destinations	Mainly destinations outside Group A; after October 9, 2025, Group A can also fall under the inform requirement only
When a license is required	Always, if the item is controlled	When the exporter knows of a risk, or receives a notice

In one sentence: list controls bind the item; catch-all controls bind the use and the counterparty. On top of that sits the review of complementary export controls promulgated April 9, 2025 and effective October 9, 2025 — the catch-all amendment people mean when they search for recent Japan rule changes. Nearly everything that moved moved on the catch-all side. The division of labor with list controls is unchanged. Teams that had been running on "non-controlled under list controls means effectively no check" feel the operational impact most.

US readers often map this onto a familiar EAR pattern: CCL classification first, then catch-all and end-user rules for everything else. The mapping is useful, not exact. Japan uses its own Appended Table 1 structure, Group A destination list, Foreign End User List, and inform-notice machinery. If you run a Japan subsidiary, ship under Japanese export declarations, or buy from Japanese manufacturers who must license under FEFTA, you need the Japan vocabulary — not only ECCNs.

I unpack the four dimensions from the legal structure, pin the amendment to promulgation and effective dates, and close with a checklist you can put on a wall. By the end, "we're non-controlled, so we're safe" should look like the most expensive misunderstanding in the playbook.

Rows 1–15 and row 16: one table, two regimes

Japan's dual-use export controls sit under the Foreign Exchange and Foreign Trade Act (FEFTA). The document that names what is regulated is Appended Table 1 of the Export Trade Control Order: rows 1 through 16. Rows 1–15 are list-control territory. Row 16 is catch-all territory.

Appended Table 1	Regime	Contents
Rows 1–15	List controls	Weapons, nuclear, chemical and biological weapons-related items, missiles, advanced materials, machine tools, semiconductors, and so on, enumerated item by item
Row 16	Catch-all controls	Nearly all goods and technology outside rows 1–15 (excluding food, lumber, and the like)
Of which row 16(1)	Catch-all (specified items)	Machine tools; radar, navigation radio, and wireless remote-control equipment; integrated circuits; aircraft and spacecraft and their parts; navigation equipment; and inspection equipment, where the HS codes in the Goods and Technologies Ordinance apply (clarified effective October 9, 2025)
Of which row 16(2)	Catch-all (other)	Row 16 goods other than specified items

Why two regimes? List controls alone cannot stop just-below-threshold engineering. Imagine shipping machine tools specified just under the list threshold, knowing the end use is military. A pure parameter list cannot stop that transaction. Catch-all controls close the gap by covering non-listed items when WMD risk, conventional-weapons risk, or a concerning end user is present. The formal Japanese name is complementary export controls — they complement list controls, they do not replace them.¹

The practical sequence is two steps:

1. List classification against rows 1–15. Controlled → license for every destination.
2. If non-controlled → the goods fall into row 16 and you run catch-all (end use + end user + inform status).

A non-controlled list result is not "unregulated." It is "move to step two." Skipping step two is still common in desk reviews. If you want a quick external mirror of your process maturity, our free export-control readiness check takes about three minutes.

When classification paperwork is the bottleneck, we also publish a free pack of templates covering classification certificates, non-applicability forms, item-by-item comparison sheets, catch-all verification sheets, and a classification control log. Download the Classification Certificate and Parameter Sheet Guide + Templates (2026 edition) and keep a continuous record from list classification into the catch-all checks that follow.

What list controls are: regulation by item and specification

List controls require a license from the Minister of Economy, Trade and Industry for exports to all countries and regions when goods or technology sit in rows 1–15 and meet the parameter thresholds. Destination friendliness does not remove the license need. That is the sharp contrast with catch-all.

A quick scan of the row map:

Row	Area	Examples
1	Weapons	Firearms, ammunition, military vehicles
2	Nuclear	Nuclear materials, reactors
3	Chemical weapons	Precursors
3-2	Biological weapons	Agents, toxins
4	Missiles	Rockets, certain UAVs
5	Advanced materials	Carbon fiber, ceramics
6	Materials processing	Machine tools
7	Electronics	Semiconductors, integrated circuits
8	Computers	High-performance computers
9	Telecommunications	Cryptographic and communications equipment
10	Sensors and lasers	High-performance cameras, lasers
11	Navigation	GPS, inertial navigation
12	Marine	Submersibles, underwater detection
13	Propulsion	Jet engines, gas turbines
14	Other	Related equipment not covered above
15	Sensitive items	Cryptography, stealth-related technology

Classification works by narrowing candidate rows from product category, then comparing shipped specifications against the Goods and Technologies Ordinance thresholds. Results live in parameter sheets and classification certificates. Deeper procedure notes are in Non-Applicability Certificates and How Classification Works and How to Read Appended Table 1.

Character of list controls: inputs are item and specs only. Controlled means license everywhere. The rules are relatively black and white. The labor is technical.

What catch-all controls are: regulation by use and counterparty

Catch-all targets goods and technology outside list control — row 16. The net is wide: roughly Customs Tariff Act chapters 25–40, 54–59, 63, 68–93, and 95, with food and lumber style exclusions.¹ Japan runs two catch-all streams: WMD (from 2002) and conventional weapons (from 2008).

Not everything in the net needs a license. Two trigger families matter:

1. Objective requirements — the exporter, through contracts, specs, or communications, comes to know of a risk of use in WMD or conventional-weapons development (and related activities as defined). Split into a use check and an end-user check.
2. Inform requirement — a written notice from the METI Minister stating that a license application should be filed.

A useful memory aid: objective requirements fire on what enters the exporter's field of vision; the inform requirement fires on what enters the government's. Meeting either one means a license is required.¹

End-use screening looks for WMD (nuclear, chemical, biological, missiles) and conventional-weapons development, manufacture, or use pathways. End-user screening looks for organizations engaged (or formerly engaged) in weapons programs and for names on METI's Foreign End User List. Trigger mechanics, statutory "risk" language, and the "clearly evident" carve-out are covered in Japan's Catch-All Amendments, Explained and The "Clearly Evident" Guideline.

Everyday civilian goods are not automatically out of scope

"We don't make weapons, so this has nothing to do with us" is the most expensive instinct in export control. Industry materials from CISTEC make the point concrete.²

Carbon fiber in sports equipment can be re-tasked as structural material in missiles — which is why high-spec carbon fiber sits in list row 5. Triethanolamine appears in cosmetics and can serve as a chemical-weapons precursor. Freeze dryers used for food can be diverted into biological production equipment. The lesson is not that every consumer SKU is controlled. The lesson is that specifications and end use, not brand category, decide.

Two takeaways:

1. Thoroughly civilian products can still hit list thresholds.
2. General-purpose goods below list thresholds still sit in row 16 catch-all and can need a license based on who buys them and why.

"What you make" alone never answers the question. "What you sell, to whom, and for what purpose" does.

Destinations: Group A, general countries, UN arms-embargoed destinations

List controls are simple: all destinations. Catch-all varies.

FEFTA practice groups destinations as:

• Group A (Appended Table 3 countries with established export-control systems — the former "White Countries" set; includes the US, UK, Germany, France, South Korea, and others; 27 countries as of mid-2026)
• UN arms-embargoed destinations (a defined short list including, among others, Afghanistan, the Central African Republic, the Democratic Republic of the Congo, Iraq, Lebanon, Libya, North Korea, Somalia, South Sudan, and Sudan)
• General countries (everywhere else, including China, Russia, Iran, Turkey, Pakistan, and many others)

Regime	Group A	General countries	UN arms-embargoed
List controls	Covered	Covered	Covered
Catch-all (objective requirements)	Not covered	Covered (conventional weapons: specified items only, extended by the October 9, 2025 amendment)	Covered
Catch-all (inform requirement)	Covered only where diversion risk exists (new as of October 9, 2025)	Covered	Covered

Two notes. First, only the list-controls row is "covered" everywhere — consistent with item-based control. Second, Group A is no longer entirely outside catch-all. After October 9, 2025, the inform requirement can reach Group A where diversion risk is present.³ You are not asked to run full objective use/end-user checks on ordinary Group A shipments, but "nothing can ever happen on a Group A shipment" is no longer a safe operating assumption.

What the October 9, 2025 amendment actually changed

Date	Event
April 2024	Industrial Structure Council subcommittee interim report proposes complementary export-control review3
April 9, 2025	Related Cabinet orders, ordinances, notices, and circulars promulgated3
October 9, 2025	Review takes effect3
September 29, 2025	Foreign End User List revised (835 entities; +87)4

Three operational effects:

1. Row 16 gained specified items (row 16(1)) — six high-diversion-concern groups designated by HS codes (machine tools, certain radio/navigation gear, ICs, aircraft/spacecraft and parts, navigation equipment, inspection equipment).
2. For those specified items, conventional-weapons catch-all objective requirements now apply on general-country shipments.
3. A diversion-limited inform requirement was introduced for Group A destinations.³

Everything that moved moved on the catch-all side. List vs catch-all division of labor is unchanged. The mesh got finer, so companies that treated "list non-controlled" as "done" took the hit. Full amendment narrative and CP update checklist: Japan's Catch-All Amendments, Explained. Primary sources: METI's Review of Complementary Export Controls (effective October 9, 2025) and Complementary Export Controls (Catch-All).

Around the same period, the Foreign End User List expanded to 835 entities on September 29, 2025.⁴ On the US side, the BIS Affiliates Rule (50% ownership automatic extension of certain list controls) is scheduled to return on November 10, 2026 after a one-year suspension.⁵ If you handle US-origin items or technology, that is not a Japan-only problem. See The BIS Affiliates Rule / 50% Guide.

Daily work multiplies variables: item, destination, end use, end user, and multi-jurisdiction tracking. TRAFEED is built to support list classification, catch-all use/end-user checks, and screening against Japan's Foreign End User List in one flow. In a joint study with Okayama University (company research), AI-based screening accuracy was verified at 95% or higher. TRAFEED holds Japanese Patent No. 7862062 and is in use at more than 20 organizations. It is decision support. Final classification and licensing judgment stay with your export control officer.

Post-amendment checklist

Use this with METI's procedure flow chart and objective-requirements confirmation sheet.³

1. Classification (list controls, rows 1–15)
   Compare the product against Goods and Technologies Ordinance thresholds; document the rationale in a parameter sheet. In METI's analysis of FY2024 FEFTA violation cases, 52% of violations traced to classification and 36% to control-framework gaps.⁶ Most failures start at the entrance.

2. Row 16 split (post-amendment)
   Non-controlled under list is not the end. Separate specified items (row 16(1)) from other row 16 goods (row 16(2)). That branch decides whether conventional-weapons objective requirements apply on general-country shipments.¹

3. Destination grouping
   Group A, general country, or UN arms-embargoed. Even for Group A, assume inform can apply where diversion risk exists.³

4. End-use check (objective requirements)
   Contracts, specs, and counterparty communications for WMD or conventional-weapons development signals. Non-listed goods can still open a license question here.

5. End-user check (objective requirements)
   Screen for weapons-program involvement and against the 835-entity Foreign End User List.⁴ Even for a listed entity, the "clearly evident" path may exist when use and transaction terms show no weapons development — but that judgment requires working the guideline, not gut feel. Practical screening notes: End-User Screening Basics.

6. Inform notice status and record retention
   Confirm you have not received an inform notice. Even when the conclusion is "no license application needed," keep the trail. Years later, memory is not an audit package. Use the catch-all verification sheet in the 2026 classification templates if you lack a form.

Summary

Operating rule: non-controlled under list controls is not the end of the story. Catch-all still applies to row 16.

Dimension	List controls	Catch-all controls
What is regulated	Rows 1–15 of Appended Table 1	Row 16 (nearly everything outside list); after the amendment, split into specified items and other
Decision criteria	Item and specifications	Use and end-user requirements, plus inform notices
Destinations	All destinations	Mainly outside Group A (Group A: inform only where diversion risk, since October 9, 2025)
When a license is required	Always, if controlled	When a risk becomes known, or a notice is received

• List binds the item; catch-all binds use and counterparty (rows 1–15 vs row 16)
• "Non-controlled equals no check" is the most dangerous misunderstanding
• Catch-all amendment: promulgated April 9, 2025; effective October 9, 2025 — specified items, conventional-weapons objective expansion, Group A inform
• Civilian materials and production equipment are not automatically outside export control
• Practical loop: classify → split row 16 → group destination → end use → end user → retain records

Always verify against METI's Security Trade Control pages. This piece is a snapshot as of August 2026. To map products and counterparties onto the two regimes, book a consultation. Materials are in our resource library.

References

• METI, Complementary Export Controls (Catch-All Controls)
• METI, On the Review of Complementary Export Controls (effective October 9, 2025)
• METI, Catch-all procedure flow chart (from October 9, 2025)
• METI, Objective-requirements confirmation sheet
• METI, Revision of the Foreign End-User List (September 29, 2025)
• CISTEC, The Basics of Export Control
• METI, Security Trade Control
• Federal Register, US Affiliates Rule one-year suspension (November 12, 2025)

Related articles

• Japan's Catch-All Export Control Amendments, Explained
• The "Clearly Evident" Guideline for Catch-All Controls
• How to Read Appended Table 1 of the Export Order
• Non-Applicability Certificates and How Classification Works
• The Basics of End-User Screening
• The BIS Affiliates Rule (50%): Preparing for November 2026
• 52% of FY2024 FEFTA Violations Trace Back to Classification

Footnotes

1. METI, "Complementary Export Controls (Catch-All Controls)" (accessed August 2026). https://www.meti.go.jp/policy/anpo/catchall.html ↩ ↩² ↩³ ↩⁴

2. CISTEC, "The Basics of Export Control: The Importance of Security Export Control" (accessed August 2026). https://www.cistec.or.jp/export/yukan_kiso/anpo_jyuuyousei.html ↩

3. METI, "On the Review of Complementary Export Controls (effective October 9, 2025)" (accessed August 2026). https://www.meti.go.jp/policy/anpo/apply-01/20251009_catchminaoshi/20251009catchall.html ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷

4. METI, "Revision of the Foreign End-User List" (September 29, 2025). https://www.meti.go.jp/press/2025/09/20250929006/20250929006.html ↩ ↩² ↩³

5. Federal Register, "One Year Suspension of Expansion of End-User Controls for Affiliates of Certain Listed Entities" (November 12, 2025). https://www.federalregister.gov/documents/2025/11/12/2025-19846/ ↩

6. METI, "Analysis of FEFTA Violation Cases (Security Trade Control), FY2024" (December 2025). https://www.meti.go.jp/policy/anpo/gaitameho_document/ihanjireigaitamehou6.pdf ↩