What Is METI's "Matrix Table"? A Beginner's Guide to Using It for Export Classification — Where to Get It, How to Read It, and the Pitfalls [2026 Edition]

Hello, this is Hamamoto from TIMEWELL. There is one question I hear more than any other from people who have just been assigned to export control: "My senior colleague told me to 'look it up in the matrix table' — what is that?" It is not a matrix in the mathematical sense. It is an official tool published free of charge by Japan's Ministry of Economy, Trade and Industry (METI) — an Excel workbook that compiles the export control regulations into a single reference table.

At its core, it really is just an Excel file. But in day-to-day export control work, whether or not you can use this table fluently makes a real difference in both the speed and the reliability of your export classification, known in Japanese practice as gaihi hantei (該非判定) — the determination of whether an item is or is not subject to list-based controls. In this article, I cover where to get the table, how to read it, how to use it within METI's five-step classification workflow, and the pitfalls that almost every beginner falls into at least once. Everything here is drawn from primary sources: METI's official pages and the original legal texts. By the time you finish reading, you should be able to respond to "look it up in the matrix table" with your hands, not just a nod.

If you are not yet confident about how far your company's export control program has come, I would suggest starting with our free export-control readiness check before reading on. It takes about three minutes, and knowing where you stand will make the rest of this article feel much more concrete.

What the Matrix Table Is: Matching Common Names to Official Names

METI describes the Matrix Table on its official page as follows: "The matrix table is a compilation of the laws and regulations that specify controlled goods and technologies, arranged into a single table using Microsoft Office Excel."[^1] The name comes from the fact that the legal provisions are laid out in a grid — a matrix — of rows and columns. Nothing more, nothing less.

So what is this table actually for? To answer that, you first need to understand the term gaihi hantei — export classification. Borrowing METI's definition: "Export classification is the procedure for determining whether goods to be exported or technologies to be provided fall under the list controls. If, as a result of the classification, the goods or technologies are found to be controlled, a license from the Minister of Economy, Trade and Industry is required in principle."[^1] List controls (list kisei) are the mechanism by which the government designates weapons and items with a high risk of military diversion on a control list — one of the pillars of Japan's security export control regime.[^2]

The tricky part is that this list is not written in any single statute. The foundation is the Foreign Exchange and Foreign Trade Act, commonly known as the Gaitame-ho (外為法).[^4] But the Act itself contains no item list. The list of controlled goods sits in Appended Table 1 of a cabinet order called the Export Trade Control Order (Yushutsu Boeki Kanri Rei),[^5] while the list of controlled technologies sits in the Appended Table of a separate cabinet order, the Foreign Exchange Order (Gaikoku Kawase Rei).[^6] The detailed technical thresholds, in turn, are delegated to a ministerial ordinance commonly called the Goods Specification Ministerial Ordinance (Kamotsu-to Shorei).[^7] The first thing that confuses newcomers is almost always this gap between common names and official names, so here is the mapping up front.

Common name	Official name	Role
Gaitame-ho (Foreign Exchange Act)	Foreign Exchange and Foreign Trade Act	The statute that underpins the entire export control regime
Export Trade Control Order (Yushutsu-rei)	Export Trade Control Order (Cabinet Order No. 378 of 1949)	The cabinet order that sets out the list controls for goods in Appended Table 1
Foreign Exchange Order (Gaitame-rei)	Foreign Exchange Order (Cabinet Order No. 260 of 1980)	The cabinet order that sets out the list controls for technologies in its Appended Table
Goods Specification Ministerial Ordinance (Kamotsu-to Shorei)	Ministerial Ordinance Specifying Goods and Technologies Pursuant to Provisions of Appended Table 1 of the Export Trade Control Order and the Appended Table of the Foreign Exchange Order (Ordinance of the Ministry of International Trade and Industry No. 49 of 1991)	The ministerial ordinance that defines the detailed specifications delegated by the cabinet orders
Matrix Table	No formal legal name (a reference table published by METI in Excel format)	A cross-referencing tool that lines up the above cabinet orders, ordinances, and circular notices by list entry

The Matrix Table is what threads all of these scattered provisions together. In METI's words: "The matrix tables organize controlled goods and technologies by list entry (items 1 through 15) of Appended Table 1 of the Export Trade Control Order and the Appended Table of the Foreign Exchange Order, respectively, and set out the provisions of the cabinet orders, ministerial ordinances, circular notices, and so on in a single view."[^1] One caveat deserves attention here: the coverage is items 1 through 15 only — that is, the list controls. Item 16, the catch-all controls — the mechanism under which even unlisted items require a license when there are concerns about end use or end users — is not covered by the Matrix Table.

Let me also settle the question of legal standing at the outset. The legal basis for an export classification is always the original text of the cabinet orders and the ministerial ordinance. The Matrix Table is METI's official tool for making those original texts easier to search and cross-reference — that is the relationship between the two. Do not stop at the table; always finish by checking the original text. This instinct is worth building from day one.

Where to Get It: Three Excel Files and How to Identify the Effective Version

You only need to remember one place: the page titled "Export Classification / About the Matrix Tables for Goods and Technologies" on METI's security export control website.[^1] Three Excel files are published there, free of charge.

Version	Contents	Best suited for
Goods matrix table (Excel)	A compilation of the provisions on goods in Appended Table 1 of the Export Trade Control Order	Classifying physical goods for export
Technology matrix table (Excel)	A compilation of the provisions on technologies in the Appended Table of the Foreign Exchange Order	Classifying technology transfers such as drawings and know-how
Combined goods-and-technology matrix table (Excel)	A compilation covering both goods and technology provisions	Checking goods and their related technologies together

When you download the files, always check the version notation. As of July 2026, the published version is labeled as corresponding to the amendments effective February 14, 2026 (Reiwa 8), applicable from that date onward, and the page's last update date is shown as February 18, 2026.[^1] The reason METI uses the phrase "effective-date version" is that the tables are replaced to match the effective date each time the cabinet orders or the ministerial ordinance are amended. Put the other way around: a file you downloaded last year may not reflect this year's regulations.

As an aside, one pattern I hear about surprisingly often from export control practitioners is an entire team continuing to use an old matrix table sitting on the company's shared drive. Excel files do not break, so nobody notices anything is wrong. Unglamorous habits work best here: put the download date in the file name, and check the last-update date on METI's page every time you run a classification. The original texts of the current cabinet orders, ordinances, and circular notices are always available on METI's related-laws page[^3] and on the e-Gov statute search portal.

How to Use It in Export Classification: METI's Five Steps

Let's place the Matrix Table within the overall classification workflow. METI lays out the export classification procedure in five steps.[^1]

STEP 1 is identifying the item. Clarify exactly what it is you intend to export or what technology you intend to provide. Is it a finished product or a component? Does it include software? If this stays vague, every subsequent comparison will drift. STEP 2 is gathering information: collect catalogs, specification sheets, and other materials that show the item's specs — dimensions, capacity, materials, performance values. These are the raw materials you will later check against the legal thresholds.

The Matrix Table's moment comes in STEP 3. Because it is Excel, you can use the search function. METI itself recommends searching across the table using the product's name and its synonyms.[^1] The key point is to search synonyms as well — for a reason I will explain in the next section: the names used in the legal texts often do not match the product names you use every day. In STEP 4, you read the provisions of the list entries your search turned up, compare the functions and specifications those entries require — dimensions, capacity, materials, and so on — against the catalog information you gathered in STEP 2, and determine whether the item is controlled or not.

STEP 5 is the one that tends to be underestimated. You document the result in a classification report (gaihi hantei-sho), obtain sign-off from the responsible manager, and make the determination an organizational decision. It must not end as one person's working memo. The Exporter Compliance Standards under the Foreign Exchange and Foreign Trade Act require companies to designate a person responsible for classification confirmation.[^1] For a more detailed walkthrough of the full classification workflow, see our article explaining METI's export classification guidelines.

To be candid, the back-and-forth between STEP 3 and STEP 4 is the most labor-intensive part of the whole process. At companies with large product portfolios, it is not unusual for a single item to take tens of minutes of Excel searching and spec-sheet comparison. Our company offers TRAFEED, an export control AI agent that supports this preliminary research with AI. In a joint field study with Okayama University using roughly 30,000 past screening records, we confirmed an AI classification accuracy of over 95% (our own research); the technology is covered by Japanese Patent No. 7862062 and is in use at more than 20 organizations. That said, no matter what tool you use, the final classification decision rests with your company's export control manager. Tools speed up the research; people make the decision. That line does not move.

How to Read the Table: List Entries, Ordinance Specs, and Circular-Notice Interpretations — Three Layers

The first time you open the Matrix Table, the sheer width of it can be overwhelming. But once you grasp the structure, there is nothing to fear. Vertically, the table lists the entries of Appended Table 1 of the Export Trade Control Order (or the Appended Table of the Foreign Exchange Order); horizontally, it lines up the wording of the cabinet order, the detailed specifications set by the Goods Specification Ministerial Ordinance, and the interpretations given in circular notices. The skeleton of the table is: for each list entry, the ordinance specs and the circular-notice interpretations, mapped side by side.[^1]

Why is it split into three layers? Appended Table 1 of the Export Trade Control Order enumerates goods from item 1 (weapons) through item 16 (catch-all targets), but from item 2 onward most entries are worded as "those with specifications prescribed by ordinance of the Ministry of Economy, Trade and Industry," delegating the concrete thresholds to the ministerial ordinance.[^5] Incidentally, Appended Table 1 has a middle column and a lower column: the middle column lists the goods, and the lower column lists the controlled destinations — the countries and regions being shipped to. Article 1, Paragraph 1 of the Export Trade Control Order defines the scope of export licensing under Article 48, Paragraph 1 of the Foreign Exchange and Foreign Trade Act as the export of goods listed in the middle column of Appended Table 1 to the regions listed in the lower column of the same table.[^5] On the technology side, each entry of the Appended Table of the Foreign Exchange Order follows the format "technology pertaining to the design, manufacture, or use of the goods listed in the middle column of item X of Appended Table 1 of the Export Trade Control Order, as prescribed by ordinance of the Ministry of Economy, Trade and Industry" — a structure tied back to the goods list and the ordinance.[^6] The delegate is the Goods Specification Ministerial Ordinance — formally, the Ministerial Ordinance Specifying Goods and Technologies Pursuant to Provisions of Appended Table 1 of the Export Trade Control Order and the Appended Table of the Foreign Exchange Order, enacted on October 14, 1991 as Ordinance of the Ministry of International Trade and Industry No. 49 of 1991.[^7][^8] The name is so long that virtually nobody in practice says it out loud in full. Reading the cabinet order alone, or the ordinance alone, gives you no complete picture — and that is precisely why a table that lays them out side by side is so valuable.

One thing to remember when interpreting the table is how terminology is handled. METI explains: "Terms in the 'Terms' column of the matrix table carry a common interpretation within the same list entry (except where the interpretation is limited to specific provisions)."[^1] In other words, within a single list entry, the meaning of a term is unified — that is the ground rule. For technology classification, METI additionally directs users to the common terminology interpretations for all list entries found in Service Transaction Circular Notice 1(3)(a) through (ta).[^1]

The other crucial point is that legal names differ from everyday names. To use METI's own example, GPS is defined in the regulations as "equipment that receives radio waves from satellite navigation systems."[^1] This is exactly why a failed search using the catalog name must never be taken as instant proof that an item is not controlled — and why I recommended synonym searches in the previous section. If you want to properly understand how the entries of Appended Table 1 are organized, our articles on how to read Appended Table 1 of the Export Trade Control Order and a comparison of controlled items organized by list entry are good entry points.

Pitfalls Beginners Fall Into — and How the Table Differs from CISTEC's Item-by-Item Comparison Tables

Finally, let me lay out the stumbling blocks head-on. Every one of these is something METI explicitly warns about on its official page[^1] — which, read the other way, means a great many people have actually fallen into each of these holes.

The first pitfall is continuing to use an outdated table. METI's original wording is: "The items subject to list controls are, as a rule, amended every year, so always confirm the latest laws and regulations when performing export classification."[^1] The current Matrix Table is named for the amendments effective February 14, 2026 precisely because that is when the most recent amendment took effect — and when the next amendment arrives, the table will be replaced again. Even an item once determined to be non-controlled can flip after an amendment. Think of export classification not as a one-time ritual but as something to revisit with every regulatory change.

The second pitfall is fixating on a single list entry. Some items — machine tools and carbon fiber, for example — are controlled under multiple list entries. Machine tools fall under both item 2 (nuclear-related) and item 6 (conventional-weapons-related).[^1] Clearing one entry does not mean you are done. The third pitfall is overlooking components and accessories. METI states explicitly that even when a finished product is not controlled, its components and accessories can still be.[^1]

The fourth pitfall is taking another company's classification report at face value. "Our supplier gave us a classification report, so we're fine" is a dangerous way to operate. METI is unambiguous: "the party held liable for violations of the Foreign Exchange and Foreign Trade Act is the party that exports the goods."[^1] Use another company's report as reference material by all means — but re-verify it yourself. It takes effort, but given where the liability sits, I regard it as a step that cannot be skipped.

Now, in practice you will also frequently hear the name "item-by-item comparison table" (komoku-betsu taihi-hyo), published by CISTEC — formally the Center for Information on Security Trade Control, a specialist body in the export control field.[^10] It is often confused with the Matrix Table, but they are different things. The item-by-item comparison table is a book that compiles the relevant laws and regulations for every good and technology controlled under Appended Table 1 of the Export Trade Control Order, the Appended Table of the Foreign Exchange Order, the Goods Specification Ministerial Ordinance, and related circular notices, and enables classification via a checksheet format. The latest edition is the February 2026 edition — that is, the edition corresponding to the amendments to the Export Trade Control Order and related regulations effective February 14, 2026 — priced at 4,400 yen for CISTEC supporting members and 8,800 yen for the general public.[^9]

	Matrix Table	Item-by-item comparison table
Publisher	METI (Ministry of Economy, Trade and Industry)	CISTEC (Center for Information on Security Trade Control)
Format	Excel file	Book (checksheet format)
Cost	Free	Paid (February 2026 edition: 4,400 yen for supporting members, 8,800 yen for the general public)
Strengths	Lines up cabinet orders, ordinances, and circular notices by list entry; cross-searchable with Excel	Lets you work through a classification step by step along a checksheet

If you ask me which to use, my recommendation is a sequence: start with the free Matrix Table to get comfortable with the structure of the regime, and once your classification volume grows and you start wrestling with verification procedures and record-keeping, consider the checksheet-style comparison table. Note that the regulatory framework described in this article is based on publicly available information as of July 2026. For the fine-grained operational details of individual item classifications and the contents of the most recent amendments, always confirm against METI's latest public notices and circulars and the original texts of the cabinet orders and ordinances.

The Matrix Table is a tool that starts paying off the day you learn how to use it. Download the latest version from METI's page and try searching for one of your company's flagship products by name and by synonyms. Even just looking at the list entries and ordinance wording that come up will raise your resolution on what export control work actually involves. And if you would like to talk through building out your classification process or making it more efficient, please book a consultation. Using your own product lineup as the example, we can explore together how much of the time currently spent on classification research can be cut.

References

[^1]: Export Classification / About the Matrix Tables for Goods and Technologies — METI, Security Export Control — last updated February 18, 2026 (accessed July 7, 2026) [^2]: Security Export Control (overview of the regime) — METI — accessed July 7, 2026 [^3]: Security Export Control: Related Laws and Regulations — METI — accessed July 7, 2026 [^4]: Foreign Exchange and Foreign Trade Act (Act No. 228 of 1949) — e-Gov Statute Search — current text (accessed July 7, 2026) [^5]: Export Trade Control Order (Cabinet Order No. 378 of 1949) — e-Gov Statute Search — current text (accessed July 7, 2026) [^6]: Foreign Exchange Order (Cabinet Order No. 260 of 1980) — e-Gov Statute Search — current text (accessed July 7, 2026) [^7]: Ministerial Ordinance Specifying Goods and Technologies Pursuant to Provisions of Appended Table 1 of the Export Trade Control Order and the Appended Table of the Foreign Exchange Order (Ordinance of the Ministry of International Trade and Industry No. 49 of 1991) — e-Gov Statute Search — current text (accessed July 7, 2026) [^8]: Ministerial Ordinance Specifying Goods and Technologies Pursuant to Provisions of Appended Table 1 of the Export Trade Control Order and the Appended Table of the Foreign Exchange Order (Japanese-English parallel text) — Japanese Law Translation Database System (Ministry of Justice) — accessed July 7, 2026 [^9]: Item-by-Item Comparison Table for Appended Table 1 of the Export Trade Control Order and the Appended Table of the Foreign Exchange Order (B01, February 2026 edition) — CISTEC — accessed July 7, 2026 [^10]: Center for Information on Security Trade Control (CISTEC) website — accessed July 7, 2026