What Is Gaihi Hantei? Japan's Export Classification Process (Aligned with the Feb 14, 2026 List Update)

Hello, this is Ryuta Hamamoto from TIMEWELL.

If you buy from Japanese manufacturers, re-export Japan-origin goods, or run a global trade desk that gets Japanese paperwork, you will meet the phrase gaihi hantei (該非判定). Colleagues may translate it loosely as "export classification" or "controlled / not controlled determination." The single most common question I hear from companies that trade with Japan is still: "We received a certificate — can we just trust it?" This article is the entry guide for that first stumble.

Gaihi hantei is the start of the Japanese export-control workflow. Get it wrong and transaction screening and shipment checks collapse with it. Get the procedure into muscle memory and the rest of FEFTA practice becomes readable.

I give the whole picture first, then the hands-on steps. Technical terms are defined on first use.

Forms you can use: Classification certificate, non-applicability certificate, item-by-item comparison, catch-all check sheet, and classification log in Word/Excel. → Download the 2026 classification template pack (Free. Company name and work email required.)

Gaihi hantei in 30 seconds

Gaihi hantei is the process of deciding whether goods or technology you will export (or transfer) fall inside or outside the control lists the Japanese government maintains. You do not judge by product name. You judge whether specifications, performance, and structure meet thresholds written into statute and ordinance. That is both the starting point and a legal duty under FEFTA.

Four steps:

Step	What you do	Tool	Detailed guide
1 Classify	List real specs; get a first sense of candidate list-control item numbers	Goods and Technology Matrix Table	List vs catch-all
2 Cross-reference	Match specs to Appended Table 1 and the Goods and Technology Ministerial Ordinance	Appended Table 1, Ministerial Ordinance	This article, Step 2
3 Compare	Line regulatory specs against your specs, row by row	Item-by-item comparison table, parameter sheet	Comparison table guide
4 Certify	Record result and rationale in a classification record (non-applicability certificate)	Classification record	Non-applicability certificate guide

Classify → cross-reference → compare → certify. That spine is Japanese export classification. To stress-test whether your framework can run it, use the free export-control readiness check (about three minutes).

For the list itself, see Appended Table 1 explained.

[Effective Feb 14, 2026] The amendment to check first

Classification is not "once and done." Lists amend almost every year. The priority update for current work is the amendment effective 14 February 2026.

Public comment ran 4 September–3 October 2025. Cabinet decision 11 November. Promulgated 14 November 2025¹. The list package — Appended Table 1, the Goods and Technology Ministerial Ordinance, and operational-notice interpretations — took effect 14 February 2026¹. The three-month gap was intentional, to give year-end operations room.

The core change tracks international export-control regime agreements. METI's press release notes that modules, assemblies, and devices incorporating FPGAs were added as a new item under Item 7 of Appended Table 1². Wording refinements included "pressure" → "shock pressure" in one ministerial-ordinance entry and "botulinum toxin" → "botulinum neurotoxins" in Item 3-2¹.

Some pieces landed earlier: certain "sterilized/disinfected" interpretations and a firearms/ammunition exclusion in Item 1 on 15 November 2025; deletion of "glass eels" on 1 December 2025²¹.

Aspect	At first publication (Feb 2026)	Mid-2026 practice
Effective edition	Prior edition still in use	Feb 14, 2026 edition; METI posts Matrix Tables for both Nov 15, 2025 and Feb 14, 20261
Covered items	Prior list	FPGA-embedded devices under Item 72
Comparison table	Old edition	CISTEC February 2026 item-by-item comparison table3
Guidance	Prior edition assumed	METI Security Trade Control Guidance — Introductory v3.0 (March 2026)4
Violation statistics	"Mostly classification" (informal)	METI FY2024 analysis: 52% of FEFTA export-control violations stem from classification5
Catch-all	Prior framework	Expanded effective October 9, 20256
Foreign User List	Prior count	835 entities after September 29, 2025 amendment7

Rule for straddle shipments: do not ship on an old-edition record for item numbers that moved. Re-classify on the new effective edition. Writing the 2026-form record: non-applicability certificate guide. Full amendment map: February 2026 Export Trade Control Order amendment.

The procedure — four steps in working order

Step 1: Break the product down to judgeable specs

List operating frequency, precision, output, materials, dimensions, control method — not "it's an inverter so it must be controlled." The statute keys on thresholds such as "can it control output frequency at 600 Hz or above," not marketing names.

With specs in hand, open METI's Goods and Technology Matrix Table. It is an index that maps regulated items to statutory provisions — a first filter for candidate item numbers.

Behind this step sits the two-pillar structure: list controls (goods specs) and catch-all controls (end-use and end-user). If that split is fuzzy, read list vs catch-all before going further.

Step 2: Cross-reference Appended Table 1 and the ministerial ordinance

List controls for goods live in Appended Table 1 (Items 1–15) plus the Goods and Technology Ministerial Ordinance. Two tiers: Table 1 says "which item," the ordinance says "which numeric threshold."

Japanese statutory phrasing trips beginners: "the following goods," "of a specification set by Ministerial Ordinance," and the logical difference between different Japanese words that both translate as "or." Misread them and the determination fails. CISTEC's basic courses put legal-term interpretation in section one for a reason.

One product can hit multiple item numbers — non-controlled under one, controlled under another. Work from function, not product family name, and check every related item.

Step 3: Compare line by line

The mechanical tool is the item-by-item comparison table (CISTEC publishes a widely used version). Regulatory specs on the left, your values on the right, apply / not apply per row.

Use the February 2026 edition aligned to the 14 February 2026 amendment³. An old edition will miss moved item numbers.

Drop results into a parameter sheet per product so the basis stays auditable. How to obtain and use the comparison table: our guide.

Step 4: Record result and rationale

For a non-controlled conclusion, the manufacturer's or supplier's document is often called a non-applicability certificate in practice. Content is still a classification conclusion.

The heavy fields are rationale and supporting materials. Example shape: "Sensor precision is XX, which does not reach regulatory value YY in Article Z of the Ministerial Ordinance; therefore not under Item X of Appended Table 1." Pair article number with measured or specified value. Keep catalog, specs, and composition data with the record.

Approval fields for classifier, supervisor, and superior are not decoration. They record who decided what, on what basis, and that the organization signed. At audit or customer challenge, this file is the company's defense. Details and 2026 form: non-applicability certificate guide.

Controlled, non-controlled, out of scope — do not mix them

Result	Meaning	List-control license	Next step
Controlled	Meets list-control regulatory specs	Required in principle	License application, bulk license, or exception analysis
Non-controlled	Compared to provisions; below thresholds	Not required	Catch-all check (use, end-user)
Out of scope	Not covered by any list-control item number	Not required	Catch-all check

Neither "non-controlled" nor "out of scope" is the finish line. Catch-all can still force a license if WMD-related risk or a concerning end-user is present. "Non-controlled, so we ship" is a classic failure phrase.

List controls and catch-all, restated

Regulation	Focus	Scope	Basis
List controls	The goods themselves	Goods Items 1–15 of Appended Table 1 and related technology	Spec vs regulatory value
Catch-all controls	How goods are used, and who uses them	Essentially all other industrial goods (food, timber, etc. carved out)	End-use and end-user criteria

Catch-all expanded under the supplementary export-control review effective 9 October 2025⁶. Some transactions once handled loosely now need explicit license applications. Division of labor: list vs catch-all guide.

Why 52% of FEFTA violations start here

METI's "Analysis of FEFTA Violation Cases (FY2024)" (December 2025) attributes 52% of export-control violations to classification⁵. Of that, 32% involve no classification at all or an assumption that "our products are not regulated." Add 36% under "inadequate management framework," and roughly nine in ten violations sit in classification operations and internal governance.

Penalties are not light: for individuals, imprisonment up to 10 years or fines up to 30 million yen; for corporations, fines up to 1 billion yen; administrative export bans up to three years. "We thought it was general-purpose" and "the customer said it was fine" still show up in case files. Classification is risk management, not paperwork theater.

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[METI statistics] 52% of FY2024 FEFTA violations stem from classification

No classification or assumed non-controlled: 32%. Inadequate management framework: 36%. About nine in ten violations consolidate into classification ops and governance⁵.

If person-dependent classification is your risk, a 30-minute TRAFEED consultation can map current state.

→ Book a TRAFEED consultation

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Requesting classification from a Japanese manufacturer (template)

When your company lacks detailed specs, ask the component or equipment maker for a classification record. A sloppy request comes back on an old edition or wrong model. State four things: target model and name, destination country, response deadline, and "latest effective edition after the 14 February 2026 amendment."

Sample request text:

Thank you for your continued support. Could you please issue a classification record (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 edition reflecting the amendment effective February 14, 2026. We would be grateful for your response by [date].

Do not accept the return at face value. Minimum check: item number and provision stated? Latest effective edition? Model match? Those three catches prevent a lot of rework.

Foreign buyers: remember that your own export (or re-export) may still need EAR / EU dual-use classification. A Japanese non-applicability certificate is evidence for FEFTA list status. It is not a global free pass.

After determination — forms that connect the workflow

METI publishes eight forms as an appendix to its Security Trade Control Guidance. After classification:

Transaction screening (catch-all)

Four forms: intended-use checklist, end-user checklist, "clearly" guideline sheet, transaction screening record. Evaluate whether the product could support WMD development for a country or actor of concern.

The critical end-user tool is METI's Foreign User List — foreign companies and organizations of concern regarding WMD development, expanded to 835 entities on 29 September 2025⁷. Check the latest edition every transaction. Manual reconciliation is becoming unrealistic; automated list feeds and change detection are spreading.

If concern appears, the 19-item "clearly" guideline probes whether it is clear or reasonably explained. Excess packaging secrecy, odd payment terms, refusal of installation support — even one flag can put the deal inside catch-all. Final decision-maker signs the screening record.

Shipment management

Shipment checklist: classification record approved? Screening approved? Physical item identical to screened item? License obtained if required? This unglamorous last mile stops careless violations.

Continuous framework review

Responsible-department list and audit checklist keep the system from rotting. Audits check latest-edition classification, seven-year document retention, and regular training.

US side: ECCN double-check

Watching only Japan's list is no longer enough for many supply chains. EAR extraterritoriality means US ECCN work runs in parallel for US-origin content, US technology, or reexports. Keep the ECCN classification guide and ECCN number cheat sheet next to the Matrix Table.

Watch especially the US Affiliates Rule (Entity List 50% ownership), scheduled to return after suspension on the Federal Register timeline into late 2026⁸. Semiconductor, advanced equipment, and materials chains should refresh screening early.

From reading METI guidance to operating it — TRAFEED

METI's Security Trade Control Guidance — Introductory v3.0 (March 2026)⁴ raised the bar for company-led self-management. The Feb 2026 list amendment¹, Oct 2025 catch-all reform⁶, 835-entity Foreign User List⁷, and US Affiliates Rule timeline⁸ are too many moving parts for a pure headcount model.

TRAFEED is our export-control AI agent for METI-aligned classification support, structured rationale storage, and list monitoring. Japanese Patent No. 7862062 covers classification logic we use; more than 20 organizations run it. AI packs the groundwork; people make the final call.

Challenge	How TRAFEED addresses it
Classification is person-dependent	Rationale stored as structured data; handovers automated
Tracking table amendments is slow	Regulatory updates captured and reflected in logic
Version control across effective dates	History per effective edition; re-judge on latest
Parameter sheets and audit prep are manual	Sheets generated; history electronic

Who this is for

• Classification rests on one or two staff
• Past records lag the 14 February 2026 amendment
• Internal CP needs alignment with METI Guidance v3.0
• You cannot produce past rationale instantly 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 ask the manufacturer? The exporter bears the obligation. Manufacturer records are supporting evidence, not a transfer of liability. Always confirm latest effective edition.

Non-controlled vs out of scope? Non-controlled = compared and below threshold. Out of scope = no item number covers it. Both still need catch-all review.

What if we are unsure? Do not unilaterally stamp non-controlled. Escalate to the export-control function, use METI's security trade-control inquiry window, or CISTEC consultation. Asking is risk mitigation, not weakness.

How long does a past record stay valid? If the effective edition changes for related item numbers, review. Items moved under the 14 February 2026 amendment must not ship on old records. Retain records for seven years in principle.

When in doubt, stop

We walked classify, cross-reference, compare, certify. The one rule I want foreign teams dealing with Japanese exporters to keep: when in doubt, stop. Do not invent a clean answer to keep a shipment date. Ask the manufacturer for edition-dated evidence, run catch-all, and check EAR if US content is in play.

As a first step this week: identify which Appended Table 1 item your flagship Japan-sourced SKU is closest to, and who in each legal entity owns the classification decision. Start there.

Related articles

• What is a non-applicability certificate?
• How to use the item-by-item comparison table
• List controls vs catch-all controls
• Appended Table 1 guide
• ECCN classification guide
• February 2026 Export Trade Control Order amendment
• 52% of FY2024 FEFTA violations stem from classification

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. CISTEC Secretariat, "On the FY2025 Regular List Amendments (Explanation)" (November 18, 2025). https://www.cistec.or.jp/export/express/251117/12_kaisetsu.pdf ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶

2. METI, Cabinet Order partially amending the Export Trade Control Order (November 2025). https://www.meti.go.jp/press/2025/11/20251114001/20251114001.html ↩ ↩² ↩³

3. CISTEC, Item-by-Item Comparison Table (February 2026 edition). https://www.cistec.or.jp/publication/shoseki/b01_taihihyou.html ↩ ↩²

4. METI, Security Trade Control Guidance — Introductory, v3.0 (March 2026). https://www.meti.go.jp/policy/anpo/guidance/guidance.pdf ↩ ↩²

5. METI, Analysis of Foreign Exchange Act Violation Cases (Security Trade Control), FY2024 (December 2025). https://www.meti.go.jp/policy/anpo/gaitameho_document/ihanjireigaitamehou6.pdf ↩ ↩² ↩³

6. METI, Review of Supplementary Export Controls (effective October 9, 2025). https://www.meti.go.jp/policy/anpo/apply-01/20251009_catchminaoshi/20251009catchall.html ↩ ↩² ↩³

7. METI, Amendment to the Foreign User List (September 29, 2025). https://www.meti.go.jp/press/2025/09/20250929006/20250929006.html ↩ ↩² ↩³

8. 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/ ↩ ↩²