[June 2026 Update] List Controls vs. Catch-All Controls: Practical Compliance for the October 9, 2025 Amendment, the 835-Entity Foreign End-User List, and the U.S. Affiliate Rule (50%)

Hello, I'm Ryuta Hamamoto from TIMEWELL.

"List Controls" and "Catch-All Controls" are the two cornerstones every export compliance professional in Japan needs to understand. But the lines between them were redrawn over the past nine months. The October 9, 2025 amendment to the Complementary Export Controls and the September 29, 2025 revision of the Foreign End-User List (now 835 entities, an increase of 87)[^userlist] together rewrote how both regimes are applied in practice. On top of that, the U.S. BIS Affiliate Rule (50% Rule) is scheduled to take effect on November 10, 2026[^bisaff2511], pulling both List Controls and Catch-All Controls into a global compliance conversation that no longer stops at Japan's borders.

The questions I keep hearing from compliance leads have shifted: "Since October 2025, do we really need to check end-use and end-user requirements even for shipments to Group A countries?" "We can't keep up with the Foreign End-User List screening for every counterparty." "We're not sure how to treat an overseas subsidiary when only the parent appears on the list." Those are not edge cases anymore—they are weekly conversations.

This article restates the fundamental difference between the two regimes, then maps the October 9, 2025 end-use and end-user requirements, the 835-entity Foreign End-User List, and the November 2026 U.S. Affiliate Rule onto day-to-day compliance work, using primary sources current as of June 2026.

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Five updates compliance teams must internalize as of June 2026

Between 2025 and 2026, amendments to the rules around List Controls and Catch-All Controls came one after another. Before we get into the main body, here are the five updates every export compliance lead needs to have at their fingertips.

Amendment / effective date	Date	Summary
Complementary Export Controls (Catch-All) amendment	October 9, 2025	Clarified the end-use and end-user requirements; expanded the operational scope of "Inform" notices, including for Group A destinations[^meti1009]
Foreign End-User List revision	September 29, 2025	Listed entities expanded to 835 (an increase of 87)[^userlist]
China's export controls targeting Japan	February 24, 2025	China imposed its own export controls on 40 Japanese companies
U.S. Affiliate Rule (50%)	Scheduled for November 10, 2026	Subsidiaries 50%+ owned by Entity List / MEU List companies become automatically subject to the same controls[^bisaff2511]
METI Security Trade Control Guidance v3.0	March 2026	A full overhaul of the foundational document on internal control programs and export classification practice[^metiguide]

Of these five, the first three directly affect the way List Controls and Catch-All Controls are operated on the ground. The U.S. Affiliate Rule is technically a U.S. regulation, but for Japanese companies re-exporting items that contain U.S. products or U.S. technology, the operational mindset required is essentially the same as for FEFTA.

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Summary (What you will learn from this article)

• List Controls: regulate specific goods and technology by item (all destinations)
• Catch-All Controls: regulate even non-list items based on the end-use and end-user requirements (Complementary Export Controls)
• October 9, 2025 amendment: clarified the end-use and end-user requirements; an "Inform" notice can now require a license application even for shipments to Group A countries where diversion is a concern[^meti1009]
• Foreign End-User List (835 entities) (revised September 29, 2025): 87 additional entities, making counterparty screening mandatory[^userlist]
• U.S. Affiliate Rule (50%): scheduled for November 10, 2026; subsidiaries 50%+ owned by Entity List companies fall under the same controls automatically[^bisaff2511]
• 52% of FY2024 FEFTA violations trace back to export classification; 36% stem from gaps in the control framework itself[^meti2024]

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Table of Contents

1. Understanding the two pillars of export control
2. What are List Controls? Covered items and how to determine applicability
3. What are Catch-All Controls? Verifying the end-use and end-user requirements
4. Inside the October 9, 2025 Complementary Export Controls amendment
5. Impact of the 835-entity Foreign End-User List (September 2025 revision)
6. The U.S. Affiliate Rule (50%, scheduled for November 2026) and Japanese companies
7. Country and region group classifications and regulatory differences
8. Concrete actions companies should take
9. Using AI to streamline export control operations

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Understanding the two pillars of export control

Japan's export control framework

Japan's export controls are operated under the Foreign Exchange and Foreign Trade Act (FEFTA). The regime divides broadly into two pillars.

Regime	Overview
List Controls	Regulate specific goods and technology by item
Catch-All Controls	Regulate even non-list items based on the end-use and end-user requirements

Why two regimes?

List Controls alone cannot stop attempts to engineer around the rules.

For example, instead of exporting a high-performance machine tool that is squarely controlled, a company might ship large volumes of machine tools just below the spec threshold—knowing the end use is military. That is exactly the gap List Controls cannot close.

Catch-All Controls plug that gap by requiring a license when there is reason to believe the item will end up in WMD development, or when a military organization is the end user—even if the item itself is non-listed.

How the two regimes relate

[Goods or technology to be exported]
    ↓
[List Controls check]
    ↓
  Controlled → METI Minister approval required
    ↓
  Non-controlled
    ↓
[Catch-All Controls check]
    ↓
  Controlled → METI Minister approval required
    ↓
  Non-controlled → Export permitted without a license

Important: Even when an item is "non-controlled" under List Controls, the Catch-All Controls check is still required.

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What are List Controls? Covered items and how to determine applicability

Definition of List Controls

List Controls are the regime that requires METI Minister approval for exports to all countries and regions of specific goods and technology assessed as likely to be used in the development of weapons of mass destruction or other conventional weapons.

Covered items

Controlled items are enumerated in Items 1 through 15 of Appended Table 1 of the Export Trade Control Order.

Item No.	Area	Examples
Item 1	Weapons	Firearms, ammunition, military vehicles
Item 2	Nuclear	Nuclear fuel materials, reactors
Item 3	Chemical weapons	Chemical weapons precursors
Item 3-2	Biological weapons	Biological agents, toxins
Item 4	Missiles	Rockets, unmanned aircraft
Item 5	Advanced materials	Carbon fiber, ceramics
Item 6	Materials processing	Machine tools
Item 7	Electronics	Semiconductors, integrated circuits
Item 8	Computers	High-performance computers
Item 9	Telecommunications	Cryptographic devices, communications equipment
Item 10	Sensors and lasers	High-performance cameras, lasers
Item 11	Navigation	GPS, inertial navigation systems
Item 12	Marine	Submersibles, underwater detection equipment
Item 13	Propulsion	Jet engines, gas turbines
Item 14	Other	Related equipment not covered above
Item 15	Sensitive items	Cryptography, stealth technology

How to determine applicability

Whether an item falls under List Controls is determined through the following steps.

Step 1: Identify candidate item numbers

From the product category, narrow down the item numbers that might apply.

Step 2: Check the detail in the ministerial ordinance

Detailed regulatory standards (specifications) for each item number are codified in the "Ministerial Ordinance Defining Goods or Technology Pursuant to Appended Table 1 of the Export Trade Control Order and the Appended Table of the Foreign Exchange Order" (commonly the "Goods and Technology Ministerial Ordinance").

Step 3: Cross-reference with parameter sheets

Compare your product specifications against the regulatory thresholds and reach a controlled / non-controlled determination.

Characteristics of List Controls

Characteristic	Content
All destinations covered	Applies to every destination, including friendly Group A countries
Item / specification based	Regulated regardless of end-use or end-user
License required	An export license is required if the item is controlled

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What are Catch-All Controls? Verifying the end-use and end-user requirements

Definition of Catch-All Controls

Catch-All Controls require METI Minister approval even for goods and technology that are not subject to List Controls, when there is reason to believe they may be used for the development of weapons of mass destruction or conventional weapons.

The formal name is "Complementary Export Controls"—they exist to complement List Controls.

Two categories of Catch-All Controls

Category	Coverage	What to verify
WMD Catch-All	Nuclear, chemical, biological weapons, missiles	End-use and end-user
Conventional Weapons Catch-All	Conventional weapons (firearms, tanks, etc.)	End-use and end-user

The two triggers that require a license

There are two situations in which a license becomes necessary under Catch-All Controls.

Trigger 1: Objective trigger (Inform requirement)

When the exporter has received a notification ("Inform") from the METI Minister stating that the export may be used in WMD development or similar.

Trigger 2: Subjective trigger (Catch requirement)

When the exporter themselves knows that the destination is engaged in WMD development or similar.

Points to verify for end-use

Confirm that the goods or technology will not be put to any of the following uses.

End-use	Specific examples
WMD development	Manufacture of nuclear bombs, biological weapons, chemical weapons
Missile development	Manufacture of ballistic or cruise missiles
Conventional weapons development	Manufacture of tanks, fighter aircraft, warships

Points to verify for end-user

Confirm that the end-user at the destination is not:

• An organization engaged in WMD development or similar
• A military or military-affiliated body
• An entity listed on the Foreign End-User List
• Any other entity of concern

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Inside the October 9, 2025 Complementary Export Controls amendment

Background

On October 9, 2025, Catch-All Controls (Complementary Export Controls) were substantially overhauled at the operational level[^meti1009].

Background to the amendment:

• The rise of diversion routes since Russia's invasion of Ukraine
• The risk of dual-use goods (machine tools, semiconductors, UAV components) being diverted to military use
• A growing number of cases where consumer-grade drone parts were used militarily in conflict zones
• The need for international alignment with U.S. EAR and EU dual-use regulations

Clarifying the end-use and end-user requirements

The core of the October 9, 2025 amendment is that the operational rules underpinning the two requirements that make up Catch-All Controls—the end-use requirement and the end-user requirement—have been written down explicitly[^meti1009].

Requirement	Content	What the amendment clarified
End-use requirement	Whether there is a risk the item will be used in WMD or conventional weapons development	Explicitly states that "concerns about diversionary procurement" are included
End-user requirement	Whether the end-user may be engaged in WMD development or similar	Clarifies the treatment of entities on the Foreign End-User List and their subsidiaries
Inform notice	METI Minister notice that triggers a license application	Explicitly states the notice can be issued even for Group A destinations

A license can now be required even for Group A destinations when diversion is a concern

The biggest operational shift introduced by the October 9, 2025 amendment is the formal recognition that, even for shipments to Group A countries (the 27 former "white" countries), the METI Minister can issue an Inform notice if there is a concern about diversionary procurement[^meti1009].

Until now, the rule of thumb was simple: "Group A destinations are in principle outside the Catch-All scope." After October 2025, situations like the following are now in scope:

Transaction pattern	Previous practice	From October 9, 2025
Goods flow to a third country via a Group A trading company	No check required	Can be the subject of an Inform notice
Assembly at a local subsidiary in a Group A country, then resale to a country of concern	No check required	A license application may be required under the end-user requirement
Dual-use items to Group A with military diversion risk	No check required	The end-use requirement now needs ongoing follow-up

This means Group A shipments now have to be supported by a framework that can respond the moment an Inform notice arrives.

Operational work that has grown post-amendment

After the amendment, the workload on export compliance teams has shifted in the following ways.

1. Group A shipments are now included in end-use and end-user checks
2. Counterparties have to be screened against the Foreign End-User List up the ownership chain to parent companies and controlling shareholders
3. The internal Compliance Program (CP) needs an immediate-response flow for Inform notices
4. The classification rationale for the past two years must be retained electronically and producible on demand for audits

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[Post October 9, 2025 Amendment] Is your catch-all compliance aligned with the latest rules?

The October 9, 2025 Complementary Export Controls amendment clarified the end-use and end-user requirements, and made it possible to issue an Inform notice—requiring a license application—even for shipments to Group A countries (former "white" countries) where diversionary procurement is a concern[^meti1009]. On September 29, 2025, the Foreign End-User List was revised, expanding the listed entities to 835 (up 87)[^userlist].

TRAFEED lets you check, in under 30 minutes, whether your counterparties match any of those 835 entities and whether your internal flow already reflects the amended end-use and end-user requirements.

→ Book a TRAFEED consultation

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Impact of the 835-entity Foreign End-User List (September 2025 revision)

What changed on September 29, 2025

On September 29, 2025, METI revised the Foreign End-User List[^userlist]. The number of listed entities is now 835, an increase of 87 compared to the prior version.

The Foreign End-User List is METI's published list of entities based in foreign countries or regions that require verification due to WMD concerns or concerns about the development of conventional weapons, given their transaction patterns. It functions as the primary reference list for the end-user requirement check. Transactions with listed entities are in principle subject to a WMD Catch-All license application.

What's inside the 87 additions

The entities added in the September 29, 2025 revision fall mainly into the following categories.

Category	Main additions
China	Research institutes and military-civil fusion entities related to semiconductor manufacturing and AI
Russia	Defense industry companies and research institutes
Belarus	Defense supply chain entities related to Russia
Iran / North Korea	Affiliates of entities already listed

What you need to do to reconcile this against your counterparty base

When an entity appears on the Foreign End-User List, subsidiaries and affiliates of any listed parent must be treated as carrying effectively the same risk. In practice, three steps are required.

1. Extract your own counterparty list (credit-cleared parties, suppliers, customers, distributors)
2. For each counterparty, trace up to the parent company and controlling shareholder and reconcile against the 835 entities
3. Where there is a match, run the case through the internal CP transaction approval flow and record the rationale

If you reconcile against 835 entities manually, even five minutes per counterparty adds up to about eight hours for a base of 100 counterparties. From what I see in the field, the more global the company, the harder this workload weighs on individual compliance leads.

Response flow when there is a match

Exports to entities on the Foreign End-User List require a license application unless it is clear that the export will not be used in WMD development or similar. In practice the response looks like this:

Situation	Response
The counterparty itself appears on the 835-entity list	In principle, file a license application
The parent company appears on the list	Carefully review the end-use and end-user requirements; consider a license application
An existing counterparty has been newly added	Run a continuation-of-business assessment through the CP; suspend the transaction if necessary

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The U.S. Affiliate Rule (50%, scheduled for November 2026) and Japanese companies

What is the Affiliate Rule?

The Affiliate Rule announced by the U.S. Department of Commerce's Bureau of Industry and Security (BIS) automatically applies the same export controls to subsidiaries and affiliates 50% or more owned, directly or indirectly, by entities on the Entity List, the Military End User (MEU) List, or the Military-Intelligence End User (MIEU) List[^bisaff2511].

The effective date is now November 10, 2026 (a one-year postponement notified in the Federal Register on November 12, 2025)[^bisaff2511].

Why this matters for Japanese companies

The Affiliate Rule is a U.S. rule, but Japanese companies that re-export items containing U.S. products, U.S. software, or U.S. technology are required to comply with the U.S. EAR. The following cases in particular require attention.

Case	Risk
Exporting products that contain U.S. semiconductors or software to a 50% subsidiary of an Entity List company	EAR violation; subject to penalties
Selling U.S.-origin products to a third-country company whose parent is on the Entity List	Same as above
Lacking visibility into a counterparty's parent company	Continuing to transact without recognizing the violation risk

Why the 50% "ownership chain" gets complex

The operational difficulty of the Affiliate Rule is that whether the 50% threshold is met has to be assessed through the chain of ownership.

For example, if Entity List company A owns 60% of company B, and company B owns 70% of company C, then A's indirect ownership of C is 42% (0.6 × 0.7)—below 50%, so C is in principle out of scope. By contrast, if A owns 100% of B and B owns 55% of C, A's indirect ownership of C is 55%, and C is in scope under the Affiliate Rule.

Running this ownership-chain check by hand against the roughly 2,000 entities on the Entity List (as of June 2026) is not realistic.

What Japanese companies should start doing now

1. Build visibility into the parent company and controlling shareholder structure of major counterparties
2. Assess capital relationships with Entity List companies against the 50% threshold
3. Maintain an internal ledger of exports that contain U.S. products or U.S. technology
4. Reflect all of the above in the internal CP in time for the November 10, 2026 effective date

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Country and region group classifications and regulatory differences

Group classification

Under FEFTA, export destination countries and regions are classified into the following groups.

Group	Number of countries / regions	Characteristics
Group A	27 countries	Countries with established export control systems
UN arms embargo countries	10 countries	Countries subject to UN sanctions
General countries	All others	Countries not in the above categories

Group A countries (27)

Argentina, Australia, Austria, Belgium, Bulgaria, Canada, Czech Republic, Denmark, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Republic of Korea, Luxembourg, Netherlands, New Zealand, Norway, Poland, Portugal, Spain, Sweden, Switzerland, United Kingdom, United States of America

UN arms embargo countries (10)

Afghanistan, Central African Republic, Democratic Republic of the Congo, Iraq, Lebanon, Libya, North Korea, Somalia, South Sudan, Sudan

Examples of general countries

China, Russia, Iran, Syria, Ukraine, Turkey, Pakistan, Myanmar, etc.

Regulatory differences by group

Regime	Group A	UN arms embargo	General
List Controls	Covered	Covered	Covered
WMD Catch-All	In principle not covered	Covered	Covered
Conventional weapons Catch-All	In principle not covered	Covered	Covered
Anti-diversion measures (newly introduced in 2025)	Covered	Covered	Covered

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Concrete actions companies should take

Taking the October 9, 2025 amendment, the 835-entity Foreign End-User List, and the scheduled Affiliate Rule together, the following five steps are what export compliance teams should be running as of June 2026.

Step 1: Re-baseline your product classification

Start by confirming which of the categories below each of your products falls into.

Item to confirm	How to verify
List-controlled item	Cross-reference against Items 1–15 of Appended Table 1 of the Export Trade Control Order
Item whose operational treatment changed in the 2025 amendment	Internal inventory of machine tools, semiconductors, UAV-related items
U.S. EAR-controlled item	Maintain a ledger of U.S.-origin parts and software content ratios

According to METI's "Analysis of FY2024 FEFTA Violation Cases," 52% of violations trace back to export classification[^meti2024]. The premise here is that the underlying documents (parameter sheets, undertakings) are stored electronically and can be diffed against every amendment.

Step 2: Verify the destination (up to the parent company)

Whether a counterparty falls under the 835-entity Foreign End-User List has to be checked not just for the counterparty itself but up the ownership chain to the parent company and controlling shareholder.

Item to confirm	How to verify
Group classification	METI's list of country groups
835-entity Foreign End-User List	Reconcile the counterparty plus its parents and affiliates
Entity List	Reconcile against the U.S. BIS Entity List (roughly 2,000 entries)
Final end-use	Contract terms and end-use confirmation from the counterparty

Step 3: Update the internal Compliance Program (CP)

The CP needs to be updated to reflect the October 9, 2025 amendment, the 835-entity Foreign End-User List, and the upcoming Affiliate Rule.

Item	Content
Update regulations	Revise internal export control regulations to reflect the new operation of end-use and end-user requirements
Run training	Communicate the amendment across sales, procurement, and legal
Update checklists	Reflect the 835-entity Foreign End-User List and the Entity List
Inform notice immediate response flow	Build a framework that can respond even for Group A destinations
Electronic retention	Store classification rationale for the past two years in a format that can be produced on demand during audits

The METI Security Trade Control Guidance v3.0 (March 2026) also strongly recommends updating internal control frameworks and export classification practice[^metiguide].

Step 4: Strengthen transaction screening

Strengthen transaction screening, including for Group A destinations.

Item to verify	What to confirm
End-use verification	Civilian end-use and absence of diversion concerns
End-user verification	Not a military, military-affiliated body, or Foreign End-User List entity
Final end-user verification	Confirmation of resale destination and ultimate destination
Undertakings	Undertakings on end-use, re-export, and third-country resale
Ownership structure verification	Visibility into parent / subsidiary structures with the Affiliate Rule in mind

Step 5: Periodic review and audit readiness

Export control is never a "set it and forget it" task.

• Inventory amendments and new cases at least every six months
• Have the CP approved by management once a year
• Maintain electronic retention so classification rationale can be produced on demand during audits

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Using AI to streamline export control operations

The increased workload from the 2025 amendment—in numbers

Taking the October 9, 2025 amendment, the 835-entity Foreign End-User List, and the scheduled Affiliate Rule together, corporate export compliance work has grown along the following dimensions.

Task	Previously	As of June 2026
Item classification	List Controls only	List Controls + post-amendment end-use requirement
Group A destinations	Light check	Diversion risk and Inform-notice readiness also required
General-country destinations	Check only where concerns existed	In principle, always check
End-user screening	748-entity Foreign End-User List	835 entities + Entity List + Affiliate Rule
Parent / ownership structure verification	Optional	50%-threshold ownership-chain check is effectively mandatory

For a company with around 100 counterparties, the screening work that used to fit into 20–30 hours per month before the amendment has, by 2026, expanded to 60–80 hours per month—based on what compliance leads are telling me directly.

How TRAFEED (formerly ZEROCK ExCHECK) solves this

TRAFEED (formerly ZEROCK ExCHECK) is the world's first export-control-specialized AI agent, with a built-in decision engine that covers the October 2025 amendment, the 835-entity Foreign End-User List, and the U.S. Affiliate Rule.

Function	Content
List Controls check	Automatic reconciliation against Items 1–15 of Appended Table 1 of the Export Trade Control Order
Catch-All end-use and end-user requirements	Built-in decision logic for the October 9, 2025 amendment
835-entity Foreign End-User List reconciliation	Bulk reconciliation in 5 seconds when you upload your counterparty list
Entity List reconciliation	Automatic reconciliation against the U.S. BIS Entity List (roughly 2,000 entries)
Ownership-chain check (Affiliate Rule support)	Automatic expansion of parent / subsidiary structures against the 50% threshold
Multilingual support	Decisions directly on English- and Chinese-language transaction documents
Electronic retention of decision rationale	Stored in a format that can be produced on demand during audits

Implementation benefits

Metric	Effect
Screening time	From 60 hours / month down to 6 hours / month (90% reduction)
Missed screenings	Effectively zero, eliminating both amendment lag and human oversight
Time to reflect regulatory changes	Decision logic updated within 72 hours of an amendment notice
Audit readiness	Retrieve two years of decision rationale in 3 seconds

Coverage status for the 2025 amendments and the 2026 effective date

TRAFEED has already incorporated the October 2025 Catch-All amendment and the September 2025 Foreign End-User List revision. It also has pre-launch coverage for the U.S. Affiliate Rule (50%) scheduled for November 10, 2026.

• Built-in logic for the amended end-use and end-user requirements
• The 835-entity Foreign End-User List incorporated
• Periodic updates of the Entity List, MEU List, and MIEU List
• Ownership-chain checks against the 50% threshold of the Affiliate Rule
• CP-update support aligned with the METI Security Trade Control Guidance v3.0

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Summary

Differences between List Controls and Catch-All Controls

Item	List Controls	Catch-All Controls
Basis for the determination	Item / specification	End-use requirement and end-user requirement
Target destinations	All destinations	Primarily general countries; post-amendment, Group A is also in scope
Timing of the check	Export classification	After export classification (for items determined non-listed)
Impact of the October 9, 2025 amendment	Limited	End-use and end-user requirements clarified; significant operational change

Key points as of June 2026

• The October 9, 2025 amendment clarified the end-use and end-user requirements
• The 835-entity Foreign End-User List (up 87) made end-user screening a heavy workload
• An Inform notice can now apply even to Group A destinations where diversion is a concern
• The U.S. Affiliate Rule (50%) is scheduled for November 10, 2026
• The CP must be updated in line with METI Security Trade Control Guidance v3.0

Actions companies should take

1. Re-baseline product classification under the post-amendment rules
2. Reconcile counterparties—up to the parent company and controlling shareholder—against the 835-entity Foreign End-User List
3. Reflect the October 9, 2025 amendment, the Foreign End-User List, and the Affiliate Rule in the internal CP
4. Build a framework that can respond to an Inform notice within 72 hours
5. Use an AI agent to compress monthly workload from 60 hours down to 6

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In a 2026 where amendments keep landing, make your catch-all operation "instant-response ready"

The October 9, 2025 Catch-All amendment, the 835-entity Foreign End-User List, China's February 24 export controls on 40 Japanese companies, the U.S. Affiliate Rule (50%) scheduled for November 10, 2026[^bisaff2511], and METI's Security Trade Control Guidance v3.0 (March 2026)[^metiguide]: in the space of a single year, export compliance teams have measurably more to do. According to METI's "Analysis of FY2024 FEFTA Violation Cases," published in December 2025, 52% of violations trace back to export classification, and 36% stem from gaps in the control framework itself[^meti2024]. In the companies I see absorbing every amendment with overtime, something always slips through eventually.

TIMEWELL's TRAFEED (formerly ZEROCK ExCHECK) is the world's first export-control AI agent, automating List Controls, Catch-All Controls, and Foreign End-User List reconciliation in a single workflow.

What TRAFEED solves

Challenge	How TRAFEED solves it
Manual end-use and end-user checks after the October 9, 2025 amendment	Built-in amended logic; rationale documents generated automatically
Heavy lift to reconcile your counterparty base against the 835-entity Foreign End-User List	Upload your counterparty list and get a bulk reconciliation in 5 seconds
Diversion-risk checks now required even for Group A shipments	Automatic decisions based on the combination of destination, end-use, and end-user
50% ownership-chain checks for the November Affiliate Rule	Automatic expansion of parent / subsidiary / group ownership structures

[Who this is for]

• Teams that lose time on diff tracking and CP updates every time the rules change
• Overseas subsidiaries that can't use English- or Chinese-language transaction documents directly and have to translate before screening
• Organizations without an electronic retention setup for two years of classification rationale that can be produced on demand during audits
• Companies that haven't finished reconciling against China's February 24 list of 40 Japanese companies or the 835-entity Foreign End-User List

If even one of these applies, a 30-minute TRAFEED consultation is enough to map out the gaps and the next steps.

→ Book a TRAFEED consultation (30 minutes) ／ → See TRAFEED service details

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References

• METI, "Revisions to the Complementary Export Controls (effective October 9, 2025)"
• METI, "Revision of the Foreign End-User List" (September 29, 2025)
• METI, "Security Trade Control Guidance: Introduction, v3.0"
• METI, "Security Trade Control"
• Federal Register, U.S. Affiliate Rule one-year suspension (November 12, 2025)
• J-Net21, "About List Controls and Catch-All Controls"
• CISTEC, Center for Information on Security Trade Control

Related articles

• Complete Guide to China's Export Controls Targeting Japan
• What Is a Non-Applicability Certificate? Export Classification Steps and How to Write a Parameter Sheet
• Complete Guide to Dual-Use Technology and Export Control
• 52% of FY2024 FEFTA Violations Trace Back to Export Classification
• Complete Guide to the U.S. Affiliate Rule (50%): Preparing for November 2026

[^meti1009]: METI, "Revisions to the Complementary Export Controls (effective October 9, 2025)." https://www.meti.go.jp/policy/anpo/apply-01/20251009_catchminaoshi/20251009catchall.html [^userlist]: METI, "Revision of the Foreign End-User List for Foreign and Regional Entities Requiring Verification due to WMD Concerns or the Development of Conventional Weapons" (September 29, 2025). https://www.meti.go.jp/press/2025/09/20250929006/20250929006.html [^bisaff2511]: 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/ [^metiguide]: METI, "Security Trade Control Guidance: Introduction, v3.0" (March 2026). https://www.meti.go.jp/policy/anpo/guidance/guidance.pdf [^meti2024]: METI, "Analysis of FEFTA Violation Cases (Security Trade Control), FY2024" (December 2025). https://www.meti.go.jp/policy/anpo/gaitameho_document/ihanjireigaitamehou6.pdf