Japan Export Classification (Gaihi Hantei): The 5 Steps and What Is Current in October 2026

Hello, this is Ryuta Hamamoto from TIMEWELL.

If you buy from Japanese manufacturers, re-export Japan-origin goods, or run a trade desk that receives Japanese paperwork, you will run into the phrase gaihi hantei (該非判定). The closest English is "export classification," or more literally a "controlled or not controlled" determination. The question I hear most from companies dealing with Japan is still the same one: "We received a certificate. Can we just trust it?" Lately a second question comes right after it: "Is this certificate based on the current rules?"

I first wrote this guide in February 2026. This version rebuilds it on primary sources as of October 4, 2026. It follows the five steps in METI's Security Trade Control Guidance (Introductory), version 3.0, published in March 2026, and adds one table that shows which editions of the law and the working tools are current right now.

The short version. Gaihi hantei is Japan's check of whether goods or technology fall under the list controls in Appended Table 1 of the Export Trade Control Order and the Appended Table of the Foreign Exchange Order. You judge specifications, not product names. The exporter is responsible. METI describes five steps: identify the item, collect information, check it against the rules, decide, and get internal approval. As of October 2026, the baseline is the list amendment that took effect on February 14, 2026. A "non-controlled" result still leaves Japan's catch-all controls, and US rules if US content is involved.

What gaihi hantei is, and who is responsible

METI defines gaihi hantei as the procedure for determining whether goods to be exported or technology to be provided fall under list controls. If they do, an export license from the Minister of Economy, Trade and Industry is required in principle¹. The legal basis is the Foreign Exchange and Foreign Trade Act (FEFTA). The control lists themselves sit in Appended Table 1 of the Export Trade Control Order for goods, the Appended Table of the Foreign Exchange Order for technology, and the Goods and Technology Ministerial Ordinance, which carries the actual numeric thresholds.

Product names do not decide anything. A frequency changer is not controlled because it is an inverter. The ordinance draws the line at conditions such as "for gas centrifuges, three-phase or more output, at a frequency of 600 Hz or more"². Change one model number and the answer can change. That is the hard part, and the part people skip.

Responsibility is the second thing to get straight. METI's guidance says the exporter carries out classification, while allowing the exporter to use a manufacturer's classification certificate after re-checking it¹. When a trading company exports a manufacturer's product, the trading company is the exporter in law and the one held responsible¹. Japan's Exporter Compliance Standards also require every exporter to appoint a person responsible for confirming whether its goods and technology fall under list controls¹.

Result	Meaning	List-control license	Next step
Controlled (gaito)	Specs meet a list-control threshold	Required in principle	License application, or check bulk licenses and exceptions
Non-controlled (higaito)	Compared against the provisions; below the thresholds	Not required	Catch-all check (end use and end user)
Out of scope (taishogai)	No list-control item number covers the item	Not required	Catch-all check

Neither "non-controlled" nor "out of scope" is the finish line. Catch-all controls can still require a license. To see whether your own framework can run this end to end, try the free export-control readiness check. It takes about three minutes.

The five steps in METI's Guidance v3.0

METI's Guidance v3.0 lays out classification in five steps: identify the item, collect information, check against the rules, decide, and approve internally¹. The earlier edition of this article used four steps of my own. I have switched to METI's breakdown, because that is what Japanese suppliers and auditors will recognize.

Step	What you do	Main tool	Detailed guide
1 Identify	List the goods and any technology that travels with them (embedded software, manuals)	Inquiry and quotation documents	This article
2 Collect	Gather documents that show specs and performance	Catalogs, spec sheets, the maker's certificate	Non-applicability certificate guide
3 Check	Search METI's Matrix Table to catch every candidate item number	Goods and Technology Matrix Table (Excel)	Matrix Table guide
4 Decide	Compare each candidate threshold with your specs, line by line	Item-by-item comparison table, parameter sheets	Comparison table guide
5 Approve	Record the result in a classification certificate and get sign-off	Classification certificate (sample form in the guidance)	Non-applicability certificate guide

Steps 1 and 2: decide what you are classifying, then get the numbers

METI's own example: if an overseas customer asks for an analytical instrument, the instrument, its embedded program, and its specifications are all "goods and technology to be exported," so all of them are in scope¹. Teams that look only at the hardware and forget the manual or the maintenance software are making the classic mistake.

Then collect the data. For your own products, ask design and manufacturing for operating frequency, accuracy, output, materials, dimensions, and control method. For third-party products, get catalogs, spec sheets, and the manufacturer's classification certificate¹. Without numbers, everything after this is guesswork.

Steps 3 and 4: search wide, then compare against the thresholds

The starting point is METI's Goods and Technology Matrix Table, an Excel workbook that lines up the order, ordinance, and circular provisions by item number. METI recommends searching it for the item's name, related terms, and synonyms¹. Statutory names often differ from everyday ones. The guidance points out that a GPS receiver appears as a "device that receives radio waves from a satellite navigation system"¹.

Once you have candidate item numbers, compare each threshold with your specs. The standard Japanese worksheets for this are CISTEC's item-by-item comparison table, which covers every controlled good and technology, and its parameter sheets, which are organized by field such as computers or telecommunications³. Both are sold by CISTEC, with an electronic version in its paid database. Foreign teams should know that CISTEC does not publish English versions of either; it points users to the regime lists instead³. For the structure of Appended Table 1 itself, see Appended Table 1 explained.

Two of METI's five cautions belong here¹. One product can be controlled under several items: machine tools appear under both Item 2 (nuclear-related) and Item 6 (conventional arms-related), so checking only one is a misclassification. And parts and accessories count. The rules are written as "pumps or parts thereof," so a part on its own still has to be checked by searching under the name of the product it belongs to.

Forms you can use. Once the comparison is done, the result goes into a classification certificate in Step 5. We offer a free Word and Excel set with a classification certificate, a non-applicability certificate form, a catch-all check sheet, and a classification log, with filled-in examples of the rationale field. Download the 2026 classification template pack (free; company name and work email required).

Step 5: put it in writing and sign it off

The result goes into a classification certificate, approved by the person responsible for classification. METI says that person should check that the item is correctly identified, that it matches the provisions, and that the latest rules were used¹. Suppliers often call the document they hand to customers a non-applicability certificate. The content is the same conclusion.

The fields that matter are the rationale and the supporting documents. A good line looks like this: "Output frequency is XX Hz, which does not reach the threshold in Article X, item Y of the Ministerial Ordinance; therefore not under Item Z of Appended Table 1." Pair the provision with the number. Anyone reading it should reach the same answer.

METI also offers a shortcut. Once an item has been classified, it generally does not need to be re-classified unless the relevant list-control rules are amended. Keep results and rationale in a log and review it whenever the rules change¹. The flip side: a company with no review routine ends up with certificates that quietly go stale. Which brings us to "current."

"Use the latest rules": the editions that are current in October 2026

METI's first caution is blunt: classify under the latest rules. List-controlled items are, in principle, amended every year¹. e-Gov's history bears that out. Japan promulgated seven amending ordinances to the Goods and Technology Ministerial Ordinance between October 2022 and November 2025². Plan for one or two changes a year.

Here is what "current" means as of October 4, 2026.

Item	Current as of October 4, 2026	Where to check
Appended Table 1 (goods item numbers)	As amended effective February 14, 2026 (Cabinet Order No. 376 of 2025)	e-Gov revision history4
Goods and Technology Ministerial Ordinance (thresholds)	Version effective February 14, 2026 (METI Ordinance No. 72 of 2025)	e-Gov2
Interpretations in the operational circulars	As partly revised January 30, 2026 (effective on issue)	METI amendment page56
Goods and Technology Matrix Table	February 14, 2026 version	METI Matrix Table page7
CISTEC item-by-item comparison table	February 2026 edition (aligned to February 14, 2026; correction notice issued June 15)	CISTEC8
CISTEC parameter sheets	February 2026 editions for computers, telecom and information security, electronics, acoustic sensors and radar, advanced materials, and chemical precursors; June 2026 edition for Appended Table 2 chemicals	CISTEC3
METI Guidance (Introductory)	Version 3.0, March 2026	METI1
METI End User List	September 29, 2025 revision (835 entities in 15 countries and regions; applied from October 9, 2025)	METI9

One label trips people up. On e-Gov, the current Export Trade Control Order shows as the version effective June 5, 2026. I compared it line by line with the February 14 version. The only changes are a renumbered cross-reference in Article 14 (from FEFTA Article 69-6 to Article 69-7) and a new supplementary provision⁴. It is housekeeping tied to a FEFTA amendment on inward direct investment¹⁰. Appended Table 1 is unchanged, so there is nothing to re-classify because of that June date.

What about the next amendment? Japan's 2025 annual list amendment went to public comment from September 4 to October 3, 2025, and was promulgated on November 14, 2025⁷. When I checked on October 4, 2026, METI's amendment page (last updated June 16, 2026) showed no draft of the next annual amendment, and e-Gov showed no promulgated amendment waiting to take effect⁵⁴. Until a draft appears, the February 14, 2026 edition is the baseline.

My practical advice: ask that every certificate state which edition it was classified under, for example "classified under the Ministerial Ordinance as in effect from February 14, 2026." When the next amendment lands, you can pull every affected certificate from your log in minutes. If a Japanese supplier's certificate carries no such date, ask for it. A certificate classified under an old edition is exactly how the "failure to follow an amendment" violations described below happen.

What the February 14, 2026 amendment changed, then and now

The amendment that sets today's baseline was approved by the Cabinet on November 11, 2025 and promulgated on November 14. The list changes (Appended Table 1, the Ministerial Ordinance, and the interpretations in the operational and services circulars) took effect on February 14, 2026⁷. The lead time was three months instead of the usual two, and license applications for newly controlled items were accepted from December 15, 2025⁷.

Most changes reflect agreements in the international export control regimes. The headline addition is high-performance FPGA (field-programmable logic device) based modules, electronic assemblies, and equipment, now controlled as Item 7(10-2) of Appended Table 1¹¹⁷. CISTEC notes that this addition did not come from a Wassenaar Arrangement decision⁷. Some items were relaxed: the threshold for real-time oscilloscopes moved from an upper 3 dB frequency of 60 GHz to 90 GHz⁷. Relaxations matter too, because a product you once classified as controlled may now be non-controlled.

Some pieces took effect earlier. Certain "sterilization" and "disinfection" interpretations, and an Item 1 exclusion for ammunition obtained in Japan for one's own use at international sporting events, started on November 15, 2025, and glass eels were removed from Appended Table 2 on December 1, 2025⁷¹¹. Item-level detail is in the February 2026 Export Trade Control Order amendment.

Aspect	First published (February 17, 2026)	Now (October 4, 2026)
Baseline edition	The February 14 amendment had just started; re-checking old certificates was the main job	February 14 edition is still the baseline; no draft of the next annual amendment yet5
e-Gov label for the Order	February 14, 2026 version	June 5, 2026 version, but only an Article 14 cross-reference changed4
METI Guidance (Introductory)	Version 2.4 (January 2025)	Version 3.0 (March 2026), with five steps and five cautions1
CISTEC worksheets	February 2026 editions just released	Comparison table correction notice on June 15; Appended Table 2 chemicals sheet updated in June3
US Affiliates Rule	Suspended, through November 9, 2026 per the Federal Register	Still suspended through November 9, 2026 in the Federal Register. The US and China announced an extension to January 10, 2027, but BIS had not published an extension rule as of October 312

Not much in the rules has moved since February. What moved is the guidance edition and the dates around it. I would not read that as "nothing to do." It is the quiet period in which to get your certificate log in order.

When to re-classify: 52% of violations start with classification

METI's analysis of FEFTA violations for fiscal 2024, published in December 2025, puts the numbers on the table. Classification problems accounted for 52% of cases decided that year: 32% where no classification was done or the exporter assumed the item was not controlled, 15% from misclassification or misreading the law, and 5% from relying on someone else's wrong classification¹³. Add 36% for weak internal management and nearly nine in ten cases come down to how classification is run and governed.

The same report lists typical cases¹³. A product once classified as non-controlled became controlled after an amendment, and the company kept exporting without a license because it never noticed the change (the report's "failure to follow an amendment"). A discontinued non-controlled product was replaced by a different model that was assumed to perform the same, so nobody classified it. A company shipped on a manufacturer's certificate without checking it, and the manufacturer turned out to be wrong. An item that needed checking under both Item 2 and Item 6 was checked under Item 2 only. None of these involved bad intent. They are gaps in routine.

Those cases translate into five triggers.

Trigger	Why	What to check
A list amendment takes effect	Thresholds and item numbers move	Certificates for shipments after the effective date use the new edition
Model change, successor, or substitute	"Compatible" products can differ in function or performance	A certificate exists for the new model number
Spec change or upgrade	Higher performance can cross a threshold	The changed specs were re-checked
A supplier certificate arrives	The exporter is liable even if the supplier erred	Name and model match, rationale holds, edition is stated
You spot an item number nobody checked	One product can fall under several items	Every relevant item number was reviewed

When you request a certificate from a Japanese manufacturer, state the model and product name, the destination country, your deadline, and that you need the determination under the latest edition. A sample request:

Thank you for your continued support. Could you please issue a classification certificate (non-applicability certificate) for your product XX (model: XXXX) under Appended Table 1 of the Export Trade Control Order and the Appended Table of the Foreign Exchange Order? The destination is [country], with shipment planned for [date]. Please base the determination on the latest rules, reflecting the amendment effective February 14, 2026, and state the effective date of the rules you applied. We would be grateful for your response by [date].

A reminder for foreign buyers: a Japanese non-applicability certificate is evidence of FEFTA list status. It says nothing about your own export or re-export under the EAR or the EU dual-use regulation.

Penalties in Japan are not light. Exporting controlled goods without a license can mean imprisonment of up to 10 years and fines of up to JPY 1 billion for a company or JPY 30 million for an individual, or up to five times the value of the goods if that is higher. Administrative sanctions include an export ban of up to three years¹. Most fiscal 2024 cases ended with a written report or explanation rather than sanctions¹³, but criminal penalties and warnings are published as a rule, and the reputational hit is often bigger than the legal one. For a closer look at the data, see 52% of FY2024 FEFTA violations stem from classification.

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[METI statistics] 52% of FY2024 FEFTA violations start with classification

No classification or assumed non-controlled: 32%. Weak internal management: 36%. About nine in ten cases come down to classification practice and governance¹³.

If classification depends on one or two people at your company, a 30-minute TRAFEED consultation can map where you stand.

Book a TRAFEED consultation

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Non-controlled is not the end: catch-all, screening, and US rules

Classification alone does not clear a shipment. METI's guidance calls classification, transaction screening, and shipment control the "three arrows" of export control, which only work when all three are done¹. Items that come out non-controlled or out of scope go on to transaction screening under the catch-all controls.

Catch-all controls require a license for items outside the lists when the end use or end user raises concerns. Their scope widened with the review of supplementary export controls effective October 9, 2025, which changed how conventional-arms-related cases are handled¹⁴. For end users, the key reference is METI's End User List. The September 29, 2025 revision lists 835 entities (87 more than before) in 15 countries and regions and, for the first time, includes entities that need checking for conventional-arms purposes⁹. METI states that the list is provided for reference and is not an embargo list⁹. A listing is a regulatory designation, not a judgment of the entity. Procedurally, if the end user is listed, a license is required unless it is clear that the goods will not be used to develop weapons of mass destruction or conventional arms⁹. For the split between the two systems, see list controls vs catch-all controls; for the screening forms, see METI's guidance forms.

Before shipment, confirm that what leaves the warehouse is the same item you classified; this is part of the Exporter Compliance Standards¹. Keep classification and screening records, from the export date, for at least seven years for Items 1 to 4 (arms and WMD-related) and at least five years for Items 5 to 16, as a best-effort obligation¹. The previous version of this article said seven years across the board. That was wrong, and I have corrected it.

US rules run in parallel. If the product contains US-origin parts or technology, you also need the EAR classification, the ECCN. The ECCN classification guide and the ECCN number cheat sheet help. On ownership screening, the US Affiliates Rule (the "BIS 50% rule") remains suspended: the stay rule at 90 FR 50857 runs through November 9, 2026¹². The US and China announced an extension of the suspension to January 10, 2027. China's Ministry of Commerce described it in an official statement on September 28¹⁵; on the US side, the Treasury Secretary's September 23 remarks have so far been reported only in the press. BIS had not published an extension rule in the Federal Register as of October 3. I track the status and worked examples in the BIS 50% rule guide.

Keeping classification from living in one person's head

Many companies run all of this through one or two people. Re-checking the log after every amendment, verifying supplier certificates, and watching US lists at the same time is, honestly, too much to keep doing by hand.

TRAFEED is TIMEWELL's export-control AI agent. It drafts the first pass of Japan export classification from spec sheets, model numbers, and product documents, showing the candidate item numbers with the rationale and the provisions it relied on. It screens counterparties against published lists, including the US Consolidated Screening List and other national sanctions lists, and keeps the evidence on file. The core logic of its risk scoring is covered by a Japanese patent (No. 7862062). As of October 2026, more than 20 organizations, trials included, have decided to adopt it. Your export control officer makes the final call; TRAFEED does not give legal advice.

Challenge	How TRAFEED helps
Classification depends on one person	Rationale and reference data are stored so anyone can retrace a decision
Finding which certificates to revisit after an amendment takes days	Classification history is kept in one place: who decided what, when, and on what basis
Supplier certificate checks and approvals are manual	Analyst review, manager review, officer approval, and send-backs are all logged
Audits and customs queries mean rebuilding the evidence	Reports with the supporting evidence can be presented as they are

Who this is for

• Classification rests on one or two staff
• You are not sure your past certificates reflect the February 14, 2026 amendment
• Your internal procedures need aligning with METI Guidance v3.0
• You cannot produce past rationale quickly at audit

If any line fits, a 30-minute consultation maps the path.

Book a TRAFEED consultation (30 min) / TRAFEED product page

FAQ

Do we classify ourselves, or rely on the manufacturer? The exporter carries the obligation. A manufacturer's certificate is supporting evidence, not a transfer of liability. Check the name and model, the rationale, and the edition of the rules it applied.

Which edition of the Japanese rules applies in October 2026? Appended Table 1 and the Ministerial Ordinance as amended effective February 14, 2026. The June 5, 2026 label on e-Gov does not change Appended Table 1. Use the February 14, 2026 Matrix Table and CISTEC's February 2026 worksheets.

How long does a past record stay valid? Until the relevant rules are amended, or the model or specs change. Keep records for at least seven years (Items 1 to 4) or five years (Items 5 to 16).

What if we are unsure? Do not stamp "non-controlled" on your own to save a shipment date. Escalate to your export-control function, contact METI's security trade control inquiry desk, or use CISTEC's consultation service. METI's guidance itself tells exporters to ask METI when classification or interpretation is unclear¹.

When in doubt, stop

We walked through METI's five steps. The one rule I want foreign teams dealing with Japanese suppliers to keep is this: when in doubt, stop. Do not invent a clean answer to protect a ship date. Ask the manufacturer for an edition-dated certificate, run the catch-all check, and look at the EAR if US content is involved.

A first step for this week: pull three Japanese certificates from your files and check which edition of the rules each was classified under. If even one carries no date, that is your signal to rebuild the log before the next amendment arrives.

Related articles

• Appended Table 1 explained
• What is a non-applicability certificate?
• How to use the item-by-item comparison table
• METI's Matrix Table guide
• February 2026 Export Trade Control Order amendment
• List controls vs catch-all controls
• ECCN classification guide
• 52% of FY2024 FEFTA violations stem from classification
• The BIS 50% rule (Affiliates Rule)

References and footnotes

[1] Ministry of Economy, Trade and Industry, Security Trade Control — Laws and Amendments (https://www.meti.go.jp/policy/anpo/law00.html) [2] Ministry of Economy, Trade and Industry, Security Trade Control Guidance (https://www.meti.go.jp/policy/anpo/guidance.html)

Footnotes

1. METI, Security Trade Control Guidance (Introductory), version 3.0 (March 2026). Definition, five steps, five cautions, Exporter Compliance Standards, penalties, record retention. In Japanese. https://www.meti.go.jp/policy/anpo/guidance/guidance.pdf ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸ ↩⁹ ↩¹⁰ ↩¹¹ ↩¹² ↩¹³ ↩¹⁴ ↩¹⁵ ↩¹⁶ ↩¹⁷ ↩¹⁸ ↩¹⁹ ↩²⁰

2. e-Gov, Ministerial Ordinance Specifying Goods and Technologies Pursuant to Appended Table 1 of the Export Trade Control Order and the Appended Table of the Foreign Exchange Order (MITI Ordinance No. 49 of 1991). Current version effective February 14, 2026; Article 1, item 8 (frequency changers). Checked October 4, 2026. https://laws.e-gov.go.jp/law/403M50000400049/ ↩ ↩² ↩³

3. CISTEC, Classification worksheets (latest editions of the comparison table and parameter sheets; note that CISTEC does not produce English versions). Checked October 4, 2026. https://www.cistec.or.jp/publication/gaihi.html ↩ ↩² ↩³ ↩⁴

4. e-Gov, Export Trade Control Order (Cabinet Order No. 378 of 1949). Revision history and the February 14, 2026 and June 5, 2026 versions, checked October 4, 2026. https://laws.e-gov.go.jp/law/324CO0000000378/ ↩ ↩² ↩³ ↩⁴

5. METI, Laws and Amendments, latest amendments (last updated June 16, 2026; checked October 4, 2026). https://www.meti.go.jp/policy/anpo/law00.html ↩ ↩² ↩³

6. METI, Partial revision of the operational circular on the Export Trade Control Order and related circulars (January 30, 2026, effective on issue). https://www.meti.go.jp/policy/anpo/20260130_tsuutatsu.pdf ↩

7. CISTEC Secretariat, "On the FY2025 Regular List Amendments (Explanation)" (November 18, 2025). Public comment period, promulgation and effective dates, application start date, background of Item 7(10-2), Matrix Table versions. https://www.cistec.or.jp/export/express/251117/12_kaisetsu.pdf ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸

8. CISTEC, Item-by-Item Comparison Table for Appended Table 1 and the Foreign Exchange Order Appended Table, February 2026 edition. https://www.cistec.or.jp/publication/shoseki/b01_taihihyou.html ↩

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

10. CISTEC, 2026 update log (June 8, 2026 entry on the promulgation of the FEFTA amendment concerning inward direct investment). https://www.cistec.or.jp/common/kosin/kosin_2026.html ↩

11. METI, Cabinet Order partially amending the Export Trade Control Order (November 2025). https://www.meti.go.jp/press/2025/11/20251114001/20251114001.html ↩ ↩²

12. Federal Register, One Year Suspension of Expansion of End-User Controls for Affiliates of Certain Listed Entities (90 FR 50857, November 12, 2025). No extension rule published as of October 3, 2026. https://www.federalregister.gov/documents/2025/11/12/2025-19846/ ↩ ↩²

13. METI, Analysis of FEFTA Violation Cases (Security Trade Control), FY2024 (December 2025). Breakdown of causes and case examples. In Japanese. https://www.meti.go.jp/policy/anpo/gaitameho_document/ihanjireigaitamehou6.pdf ↩ ↩² ↩³ ↩⁴

14. METI, Review of Supplementary Export Controls (effective October 9, 2025). https://www.meti.go.jp/policy/anpo/apply-01/20251009_catchminaoshi/20251009catchall.html ↩

15. China Ministry of Commerce, statement by the head of the Department of American and Oceanian Affairs on the outcomes of the eighth round of China–US economic and trade consultations (September 28, 2026). In Chinese. https://www.mofcom.gov.cn/syxwfb/art/2026/art_d9ea01824fc44fd8a29f7dc3f8ca9c72.html ↩