How to Write a Certificate of Non-Applicability: Required Fields, a Filled-In Sample, and What "Item 16 Applies" Means [Updated for the February 14, 2026 Amendment]

Hello, this is Ryuta Hamamoto from TIMEWELL.

A customer asks for a certificate of non-applicability, and the export team freezes. I have watched it happen more times than I can count this year. It is a fair reaction. The document has no format prescribed by law, and you do not file it with METI at all¹. Get the wording wrong, though, and your shipment stops at customs.

On February 14, 2026, the amending Cabinet Order to Japan's Export Trade Control Order (Cabinet Order No. 376 of 2025) took effect, adding FPGA-embedded modules and equipment, peptide synthesizers, and high-entropy alloy powders to the control list². Plenty of companies now need to check whether the certificates sitting in their files still hold.

This article starts from one question: what do you actually write on the certificate. Required fields, a filled-in sample, how it differs from a classification record, and the line that trips up almost everyone, "the goods fall under Item 16." After that, where to get the forms and how to ask a manufacturer for them.

It is a long piece. Jump to what you need from the table of contents.

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The short version

• No legal format exists. An addressee, product name, model number, a statement of non-applicability against Items 1 through 15, your reasoning, the effective date of the regulations, the classification date, and the issuer will carry you through customs
• A classification record documents the work. A certificate of non-applicability presents the result to someone outside your company. Different jobs
• Even when Items 1 through 15 are cleared, Item 16 normally still applies. The end-use and end-user check remains yours¹

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Summary (What You Will Learn from This Article)

• A certificate of non-applicability needs nine fields. Because no format is prescribed, this article shows a filled-in sample rather than a list of abstractions
• A classification record documents the classification work; a certificate of non-applicability presents a non-applicable result to customs or a counterparty
• METI states plainly that goods falling under none of Items 1 through 15 normally still fall under Item 16. Both the issuer and the recipient have work left to do
• "Non-controlled" and "outside the scope" are not the same thing, and mixing them up creates avoidable back-and-forth with counterparties
• No statutory validity period exists, but amendments, spec changes, and counterparty policies all force re-issuance
• The February 14, 2026 amendment added FPGA-embedded equipment (Item 7 (10-2)), peptide synthesizers, and high-entropy alloy powders. Affected products must be re-classified
• There is no official template. Practitioners buy the CISTEC item-specific comparison table and parameter sheets (February 2026 edition) and reshape them into an internal form
• TRAFEED cuts the time spent on classification work substantially, in the experience of the teams using it

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The Answer First: Classification Record vs. Certificate of Non-Applicability

If a search engine brought you here, the first thing you probably want is the difference between these two documents. So here it is, up front.

Comparison	Classification record	Certificate of non-applicability
Purpose	Record the result of the classification work	Certify that the item is not subject to controls
Result covered	Both controlled and non-controlled	Non-controlled only
Main recipients	Internal (records, approval), attachments to license applications	External: customs, trading companies, overseas counterparties
Level of detail	Item numbers checked, specifications, and reasoning in full	The conclusion (non-controlled) and product identification
Prepared by	The exporter (or the manufacturer)	The exporter or the manufacturer
Basis	Appended Table 1 of the Export Trade Control Order, the Appended Table of the Foreign Exchange Order, and the ministerial ordinance	The classification record (the classification work itself)

In one sentence: the classification record is the documented investigation, and the certificate of non-applicability is the declaration that the investigation came back clean. A certificate is one output of the classification work; you cannot issue a certificate without doing the work. When a counterparty asks for a "certificate of non-applicability," what they are really asking for is the classification work behind it. Hold on to that structure.

Where to Get the Format

The next most common question is where the format lives. There is no statutory unified format for classification records or certificates of non-applicability, which is why searching for an "official METI template" comes up empty. In practice, exporters use one of the following.

Source	Content	Cost
CISTEC official website3	Item-specific comparison table and parameter sheets (February 2026 edition)	Paid; member pricing available
JMC (Japan Machinery Center for Trade and Investment)	Field-specific parameter sheets	Paid
METI	Sample forms for some items	Published free of charge
Manufacturers	Classification records attached to components and products	Varies by product
In-house formats	The above, re-shaped for internal approval workflows	Self-made

One caution. CISTEC's item-specific comparison table and parameter sheets are paid materials provided by CISTEC (Center for Information on Security Trade Control). Do not pick up an old copy floating around the internet. As the February 14, 2026 amendment shows, the forms are revised every time the law changes, and classifying against an outdated version leads straight to missed classifications. Always obtain the latest edition from CISTEC's official website⁴.

TIMEWELL is also preparing a downloadable classification record template (Word/Excel). Our published whitepapers and practical materials are collected on the resources page, so take a look there as well.

Checklist of Items to Include in a Classification Record

Because the format is free-form, the real question becomes what to write so the document holds up internally and externally. Here are the items I would want covered. This is the structure commonly seen in practice; your industry or counterparties may require more or less.

• Product name and model number, written specifically enough to identify the item, not just a catalog name
• Whether goods or technology are being classified. If design drawings or software accompany the goods, classify the technology side too
• The item numbers reviewed (which items of Appended Table 1 of the Export Trade Control Order and the Appended Table of the Foreign Exchange Order)
• The classification result (controlled or non-controlled) and the specifications and regulatory thresholds supporting it
• The version and effective date of the regulations referenced (especially important after the February 14, 2026 amendment)
• Date of classification and the classifier's name, plus the approver's name where possible
• A note that Catch-All end-use and end-user verification was performed

Whether your organization can actually fill in all of these is a separate question. The free export compliance diagnostic is one quick way to find your current position. It takes three minutes.

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What "Item 16 Applies" Actually Means

Sooner or later a certificate lands on your desk with a line like this.

The above goods fall under none of Items 1 through 15 of Appended Table 1 of the Export Trade Control Order. Note that the goods do fall under Item 16.

And the reading stops right there. Can we ship it or not?

Here is the answer. The line means the list-based controls are cleared, and the catch-all check is still sitting with you, the exporter. It is not a refusal, and it is not a clean bill of health either.

What METI asks of each side

METI publishes a one-page note titled "Points on Issuing a Certificate of Non-Applicability" that addresses exporters and manufacturers separately¹. Three things come out of it.

Who	What is expected
Both	Customs may ask whether classification was done properly, so having a certificate showing non-applicability to the list controls is recommended. That said, the certificate is not a document you submit to METI
An exporter requesting one from a manufacturer	Confirm with the manufacturer the basis on which the goods fall under none of Items 1 through 15 under the current control list. Even so, Item 16 normally applies, so the exporter must check the end-use and the end-user
A manufacturer issuing one to an exporter	Be ready to show the exporter or customs the basis for non-applicability to Items 1 through 15, and tell the exporter to run the end-use and end-user check

Strip it down and the note says one thing. What the paper says and whether you may ship are two separate questions.

What Item 16 is

Item 16 of Appended Table 1 of the Export Trade Control Order is where the catch-all controls live. Article 4, paragraph 1 of the Order removes goods under Item 16 (1) from the license exemption where there is a risk of use in weapons of mass destruction development, and goods under Item 16 (2) where the conventional weapons criteria are met⁵. Roughly speaking, (1) is the WMD side and (2) is the conventional weapons side.

Items 1 through 15 draw the line at what a product is. Item 16 draws it at who buys it and what they do with it. That is why low specs never get you out of Item 16. Ordinary screws and off-the-shelf laptops need the end-use and end-user check like anything else.

How to write it, and how to read it

If you are issuing the certificate, saying "non-applicable" without mentioning Item 16 invites the reader to conclude that no license could ever be needed. I take METI's instruction to tell the exporter about it as a direct response to that misreading. One sentence is enough.

If you are receiving it, treat "Item 16 applies" as your cue to start the end-use and end-user check. That part was never the manufacturer's job. The mechanics are in the catch-all controls section and in the guide to the objective criteria.

Honestly, this never lands cleanly the first time. "So it is non-applicable and applicable at the same time?" is a question I get a lot. The design itself is straightforward, though. The list catches what specifications can catch, and Item 16 catches the diversion risk that specifications miss.

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Table of Contents

0. The Answer First: Classification Record vs. Certificate of Non-Applicability
1. What "Item 16 Applies" Actually Means
2. What Changed in the Amendment Effective February 14, 2026
3. What Is Export Classification? Why Is It Necessary?
4. Certificates of Non-Applicability, Classification Records, and Parameter Sheets in Detail
5. The Difference Between "Non-Controlled" and "Outside the Scope"
6. Required Fields and a Filled-In Sample
7. Validity Periods and When Re-Issuance Becomes Necessary
8. How to Request Documents from a Manufacturer (Sample Email)
9. The 4 Steps of Export Classification
10. The Six Parameter Sheet Volumes and How to Fill Them Out
11. Using the Item-Specific Comparison Table and the Latest CISTEC Editions
12. Latest Operations of the Catch-All Controls
13. Classification in the Era of Economic Security
14. Common Mistakes and Points to Watch
15. Automating Classification with TRAFEED

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What Changed in the Amendment Effective February 14, 2026

Let me start with the amendment that affects every reader of this article. The partial amendment to the Export Trade Control Order (Cabinet Order No. 376 of 2025), promulgated on November 14, 2025, came into force on February 14, 2026²⁶. It is the annual list revision, but this round has unusually broad practical impact.

Main Additions to the Control List

Added item	Item number and requirement	Background
Modules, assemblies, and equipment incorporating FPGAs (FPLDs)	New Item 7 (10-2) of Appended Table 1: user-configurable FPLDs with a total look-up table (LUT) input count of 1,800,000 or more	Wassenaar Arrangement agreement
Peptide synthesizers	Equipment for synthesizing peptides	Australia Group agreement (biological weapons diversion concern)
High-entropy alloy and refractory metal powders	Alloy powders containing multiple elements in near-equal proportions	Wassenaar Arrangement agreement (extreme-environment component concern)

The FPGA addition has the widest reach. Previously, only standalone FPLDs (as integrated circuits) were controlled, which left a loophole: mount a high-performance FPGA on a board, ship it as a "general-purpose image processing board," and the finished device escaped list controls. The amendment closes that structural weakness by extending controls to the module, assembly, and equipment level. FPGAs sit inside industrial machinery, measurement instruments, communications equipment, and AI inference boards, which means finished-product manufacturers now need to answer, at the bill-of-materials level, whether their equipment contains FPGAs and what the total LUT input count is.

For the full picture of the amendment, the LUT calculation method, and the exclusion conditions (fixed functionality, non-disclosure of technology), see the companion article: Complete guide to the Export Trade Control Order amendment effective February 2026. This article focuses on what to do with the records you already have.

Do Your Existing Records Need Re-Classification?

Re-classifying every product after every amendment is not realistic. Here is a working decision table.

Your situation	Re-classification / re-issuance
You export modules, assemblies, or equipment incorporating FPGAs (FPLDs)	Mandatory. The new Item 7 (10-2) can change the result. Check the total LUT input count
You handle peptide synthesizers or related chemical/bio equipment	Mandatory. Check applicability to the added items
You handle high-entropy alloy or refractory metal powders or their processed products	Mandatory. Check the materials-related additions
Other products, and your records state the referenced regulation version and classification date	Generally not required, but re-issue if a counterparty requests a certificate based on the current regulations
Your records do not state the referenced regulation version or classification date	Regardless of product, use this occasion to revise the format and re-issue

The amendment also touched the bulk license regime. Special general bulk licenses had their scope widened, and specific bulk licenses now cover parts and accessories for defense equipment exported to countries with a defense equipment transfer agreement⁶. Both changes cut paperwork rather than add it, but this is a good moment to check whether the scope of the bulk license your company relies on has shifted.

At customs, there is also a real risk that classification records referencing the old regulations will not be accepted. CISTEC's item-specific comparison table and parameter sheets are now available in the February 2026 edition aligned with the amended ordinances, and it is safest to standardize your classification work on that edition⁴.

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What Is Export Classification? Why Is It Necessary?

Definition of Export Classification

Export classification (gaihi-hantei) is the process of confirming whether goods you intend to export, or technology you intend to provide, fall under regulation by law. The exporter themselves is the one who determines whether the product requires an export license. Stated that way it sounds simple, but a wrong call here is a violation of the Foreign Exchange and Foreign Trade Act (FEFTA).

Legal Basis

Export classification is conducted pursuant to the following regulations⁵.

Regulation	Coverage
Appended Table 1 of the Export Trade Control Order	Goods (Items 1 to 15)
Appended Table of the Foreign Exchange Order	Technology (Items 1 to 15)

When goods or technology fall under the items and specifications defined in these regulations, approval from the Minister of Economy, Trade and Industry is required for export.

Why Is It Necessary?

Boiled down, there are four reasons.

Reason	Explanation
Legal obligation	FEFTA imposes a duty on exporters to verify
Avoiding penalties	Unlicensed export is subject to criminal penalties and administrative sanctions
Customs compliance	Customs may demand a documented basis for the classification
Counterparty requirements	Overseas counterparties frequently require this documentation

A Critical Point

METI does not perform export classification. The exporter must perform the classification on their own responsibility.

This is something I cannot repeat too often. I still meet practitioners who assume "we can just ask METI." The agency will explain how the law is interpreted, but it will not tell you whether your specific product falls under it. That decision sits squarely with the exporter.

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Certificates of Non-Applicability, Classification Records, and Parameter Sheets in Detail

The Relationship Between the Four Documents

Documents in export control go by several different names, and the terminology trips people up at first. Let me expand on the comparison table from the opening.

Name	Content
Classification record	A general term for documents that record the result of export classification
Certificate of non-applicability	A document certifying that an item does not fall under regulation
Parameter sheet	A checklist for entering product specifications and determining classification
Item-specific comparison table	A checklist in CISTEC's format

Described as a flow: first you use a parameter sheet or item-specific comparison table, the working tools, to match specifications against regulatory thresholds. The compiled result of that matching is the classification record. When the result is non-controlled and you shape it into a document for counterparties or customs, that is the certificate of non-applicability. Tool, record, certificate: a three-layer structure.

What Is a Parameter Sheet?

A parameter sheet is a checklist for entering product specifications and matching them against regulatory thresholds.

The three things to remember:

• They are organized by field (computers, telecommunications, electronics, etc.)
• They have entry fields for product specifications
• They allow you to compare specs against regulatory thresholds and reach a controlled / non-controlled determination

The volume structure and the latest editions are summarized in a table later in this article.

What Is an Item-Specific Comparison Table?

An item-specific comparison table is a form provided by CISTEC (Center for Information on Security Trade Control) that lets you check every item in Appended Table 1 of the Export Trade Control Order and the Appended Table of the Foreign Exchange Order³.

Its strengths:

• Covers all product categories
• Lets you check every potentially applicable item number
• Works for product categories that have no parameter sheet

For a step-by-step walkthrough of the comparison table itself, see the companion article: How to fill out the item-specific comparison table. Here we focus on positioning and when to use which tool.

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The Difference Between "Non-Controlled" and "Outside the Scope"

This is the pair of terms practitioners confuse most often. Both appear to reach the same conclusion, namely that no export license is required, but they mean different things.

Non-controlled (non-applicable) means that you examined a candidate item number and the product's specifications fall short of the regulatory threshold. For example, you checked a machine tool against the Item 6 thresholds (positioning accuracy and so on) and it did not meet them. The evidence of the classification work remains: which item numbers were checked and against which specifications.

Outside the scope means the product does not fit the definition of any listed item in the first place. Think of ordinary office supplies or clothing, which have no plausible connection to any item number. The product falls out at the definition stage, before any specification matching is needed.

Category	Meaning	How to write it in the record
Controlled	Fits a listed item's definition and meets or exceeds the threshold	State the applicable item number and supporting specs, then proceed to a license application
Non-controlled	Fits a listed item's definition but falls below the threshold	State the item numbers checked, the thresholds, and your product's specs side by side
Outside the scope	Does not fit the definition of any listed item	State that the product does not fall under any item of Appended Table 1

Why does the distinction matter? Because it causes friction with counterparties. If someone asks for a certificate of non-applicability and you send a document that only says "outside the scope," you will get it bounced back with "which item numbers did you check?" Conversely, some counterparties demand parameter sheets even for products that are plainly outside the scope. Define the three categories (controlled, non-controlled, outside the scope) in your internal format, and write every record so that the verification process is visible regardless of category. That alone eliminates a lot of rework.

Note that even when a product is non-controlled or outside the scope under list controls, Catch-All verification is still a separate requirement. We cover that in a later section.

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Required Fields and a Filled-In Sample

A blank page with no prescribed format is harder than a strict template. So here are the fields that get a certificate accepted, and a filled-in example.

The nine fields

#	Field	What matters
1	Addressee	The receiving company. "To whom it may concern" works for internal filing
2	Document title	Certificate of Non-Applicability
3	Product name	Something that identifies the product, not the marketing name
4	Model or type number	Including the revision suffix. Revisions can change the result
5	Conclusion	State non-applicability to Items 1 through 15 of Appended Table 1 and of the Foreign Exchange Order appended table
6	Reasoning	The item numbers you checked and your specs against the control threshold. Thin reasoning is what gets certificates bounced
7	Effective date of the regulations	"Based on the regulations effective February 14, 2026." This is what lets you judge re-issuance at the next amendment
8	Classification date	The date the work was actually done
9	Issuer and contact	Company, department, responsible person, phone. A certificate nobody can follow up on carries less weight

Customs officers are not specialists in your product. A certificate that lists item numbers and nothing else does not explain why the goods are non-applicable, and the questions come back. One line of reasoning usually settles it.

Filled-in sample

                                   CERTIFICATE OF NON-APPLICABILITY

                                                        Date of issue: August 3, 2026
                                                        Document No.: TW-EXP-2026-0142

To: XX Corporation

                                                        OO Seiki Co., Ltd.
                                                        Export Control Section,
                                                        Quality Assurance Department
                                                        Taro Yamada, Manager
                                                        Tel: +81-3-0000-0000

We hereby certify the result of the export classification conducted under the
Foreign Exchange and Foreign Trade Act of Japan for the goods described below.

[Goods]
  Product name : Horizontal machining center
  Model        : WM-5000 (Rev. C)
  Quantity     : 1 unit

[Conclusion]
  The goods fall under none of Items 1 through 15 of Appended Table 1 of the
  Export Trade Control Order.
  The goods fall under none of Items 1 through 15 of the Appended Table of the
  Foreign Exchange Order.

[Basis]
  Item 6 (1) of Appended Table 1 was reviewed.
  Positioning accuracy is 8.0 micrometers against a control threshold of
  6.0 micrometers or finer, so the threshold is not met.
  For all other items, the goods do not meet the definition of the controlled
  goods and are therefore outside the scope.

[Regulations applied]
  Export Trade Control Order, as amended effective February 14, 2026
  Ministerial Ordinance on Goods and Technologies, same

[Classification date] August 3, 2026
[Classified by] Ichiro Suzuki, Export Control Section

Note: The goods fall under Item 16 of Appended Table 1 of the Export Trade
Control Order. Please confirm the end-use and the end-user prior to export.

Keep that closing note. It is the Item 16 point from earlier, and METI asks manufacturers to pass it along to exporters¹.

When the goods are simply outside the scope

For stationery or ordinary clothing, where nothing in the list defines the goods at all, the basis section reads like this.

[Basis]
  The goods do not meet the definition of any goods specified in Items 1
  through 15 of Appended Table 1 of the Export Trade Control Order.

The distinction between non-controlled and outside the scope is covered in the previous section. Either way, keep the Item 16 note.

If you issue in Japanese and English

Japanese counterparties will want the Japanese wording, overseas customers will want English. Since neither is a statutory form, the safe arrangement is to treat the Japanese text as the original and the English as a reference translation, so there is somewhere to go back to when a reading is disputed.

Does your team redo this every time?

Classifying by model, transcribing results onto certificates, reissuing after each amendment. The volume grows with your product count, and it eats the export control team's week. TRAFEED ingests product specifications, proposes the item numbers that may apply with the supporting basis, and keeps the classification history in one place.

Book a free TRAFEED consultation

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Validity Periods and When Re-Issuance Becomes Necessary

Another frequent question: "Does a certificate of non-applicability expire?" The answer is that there is no statutory expiration date. Neither FEFTA nor the Export Trade Control Order sets a validity period. In practice, however, re-issuance becomes necessary at three moments.

1. When the Regulations Are Amended

This is the most important trigger. A classification is performed against the regulations as they stood on the classification date, so once the referenced regulations are amended, the old classification proves nothing about the amended ones. When Appended Table 1 gains new items, as it did on February 14, 2026, any product that could relate to the added items needs re-classification. Conversely, if the amendment has nothing to do with your products, re-classification is logically unnecessary; but you still need a process for reviewing each amendment to make that call.

This is where the habit of stating the referenced regulation version and effective date on every record pays off. With it, anyone can see at a glance that "this certificate is based on the ordinances effective February 14, 2026," and the re-issuance decision at the next amendment takes minutes. Without it, nobody can tell whether a certificate reflects current law, and the document ends up being redone anyway.

2. When the Product's Specifications Change

Even with an unchanged model number, a component change or firmware update that adds functionality breaks the premise of the original classification. If design-change information does not flow to the export control team, the accident of continuing to use an outdated certificate becomes very easy to have. The reliable fix is to tie certificate versions to product revisions.

3. When a Counterparty Requires It

Some trading companies and overseas counterparties have internal rules requiring a certificate "dated within the past year." That is a compliance requirement of the counterparty, not of the law, so whether to comply is a commercial decision; but running a periodic re-issuance cycle (annually, for example) makes these requests painless.

To sum up: a certificate of non-applicability is not a "issue once and forget" document. It is a document you maintain against three moving targets: the law, the product, and the counterparty. That maintenance cost is, frankly, what export classification work actually is.

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How to Request Documents from a Manufacturer (Sample Email)

If you are a trading company or a finished-product manufacturer, the starting point is obtaining classification information for components and embedded products from their manufacturers. What I often see, though, is a one-line email saying "please send a certificate of non-applicability," which rarely brings back the information actually needed. Three points matter when making the request.

• Identify the target product down to the model number ("all of your products" gives the recipient nothing to act on)
• State explicitly whether you need the supporting basis (parameter sheets and the like) in addition to the result
• Specify the reference date of the regulations (i.e., a classification performed under the regulations effective February 14, 2026 or later)

Here is a sample request email you can adapt.

Subject: Request for export classification documents
         (your product: [product name / model number])

Dear [Manufacturer] Sales Department,

We are planning to export equipment incorporating your product and are
conducting export classification under Japan's Foreign Exchange and
Foreign Trade Act. Could you kindly provide the following documents?

1. Classification record (results against Appended Table 1 of the Export
   Trade Control Order and the Appended Table of the Foreign Exchange Order)
2. Parameter sheet, item-specific comparison table, or other material
   showing the basis for the classification

Please provide the latest version, based on the regulations in force on
or after February 14, 2026 (the amendment adding FPGA-embedded equipment,
among others). Kindly state the classification date and the effective
date of the referenced regulations on the document.

[Target product]
- Product name:
- Model number:
- Our intended use: incorporation into our product [XX]

[Requested by]
[Date] (calculated back from our planned shipping date)

Thank you very much for your assistance.

When the Manufacturer Cannot Provide a Record

With overseas or smaller manufacturers, you will sometimes hear "we have no such document" or "we cannot issue a certificate of non-applicability." The exporter's classification duty does not disappear, so you switch to classifying in-house. The procedure:

1. Extract the specifications needed for classification from catalogs, datasheets, and specification documents
2. Use the item-specific comparison table to review all items and narrow down candidate item numbers
3. For missing specifications, ask the manufacturer a technical question rather than requesting a certificate (manufacturers who refuse to issue certificates will usually still answer questions about LUT counts or the presence of encryption functions)
4. If gaps remain, treat the item as undeterminable: consult a specialist, or err on the safe side and consider a license application

Point 3 is a technique that genuinely works. A manufacturer that will not respond to "please send a certificate" will respond to "please tell us the encryption specifications of this product." What classification needs is not a piece of paper called a certificate, but the facts called specifications.

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The 4 Steps of Export Classification

From here on, this is the classification workflow itself.

Step 1: Identify the Classification Target

First, clearly identify the goods or technology to be classified.

Things to confirm:

• Product name, model number
• Specifications
• Design drawings, specifications, manuals
• Whether technical information is involved

A surprisingly common omission here is the treatment of accompanying technical information. You may intend to ship hardware only, but if design drawings or software are attached, that technology has to be classified separately as a technology export.

Step 2: Select Potentially Applicable Item Numbers

Next, narrow down which regulatory items the product might fall under.

The main item numbers in Appended Table 1 of the Export Trade Control Order are⁵:

Item No.	Coverage
Item 1	Weapons
Item 2	Nuclear
Item 3	Chemical weapons
Item 3-2	Biological weapons
Item 4	Missiles
Item 5	Advanced materials (carbon fiber, etc.)
Item 6	Materials processing (machine tools, etc.)
Item 7	Electronics (semiconductors, etc.)
Item 8	Computers
Item 9	Communications
Item 10	Sensors and lasers
Item 11	Navigation
Item 12	Marine
Item 13	Propulsion systems
Item 14	Other
Item 15	Sensitive items (cryptography, etc.)

Because the amendment effective February 14, 2026 created Item 7 (10-2), anything in the electronics line, including FPGA-equipped products, warrants a fresh look².

Step 3: Verify Specifications

Confirm whether the product's specifications meet the regulatory thresholds.

Information you will need:

• Technical specification sheets
• Catalogs
• Test reports
• Responses from the manufacturer

Catalog values and measured values often diverge. Decide internally whether you classify on design values or on measured values; if you do not, every classification will be a fresh debate.

Step 4: Classification and Documentation

Compare specifications against regulatory thresholds and record the result.

There are three possible outcomes.

Result	Response
Controlled	License application to the Minister of METI is required
Non-controlled	No license required (Catch-All control verification still required)
Unable to determine	Collect additional information or consult a specialist

A non-controlled finding is not the end of the work. You only close the record once you have completed the Catch-All checks on intended use and end-user as well.

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The Six Parameter Sheet Volumes and How to Fill Them Out

CISTEC Parameter Sheet Volumes (as of August 2026)

CISTEC's parameter sheets are organized into field-specific volumes. The latest editions listed on CISTEC's official website as of August 2026 are as follows⁴.

Volume	Name	Main field covered	Latest edition
B02	Parameter Sheet: Computers	Computer-related items	February 2026
B03	Parameter Sheet: Telecommunications and Information Security	Communications equipment and cryptography-related items	February 2026
B04	Parameter Sheet: Electronics	Semiconductor and electronic component items	February 2026
B05	Parameter Sheet: Acoustic Sensors and Radar	Sensor and radar-related items	February 2026
B06	Parameter Sheet: Advanced Materials	Advanced material items	February 2026
B07	Parameter Sheet: Chemical Agent Precursors	Chemical and precursor items	February 2026

A separate parameter sheet for Appended Table 2 of the Export Trade Control Order (B08, June 2026 edition) is also available. For the exact item-number coverage of each volume, check the product descriptions on CISTEC's website before purchasing. All six volumes B02 through B07 have been revised into the February 2026 edition aligned with the ordinances effective February 14, 2026. If the volumes on your shelf are from 2025 or earlier, it is time to replace them.

If your product does not fit any volume, use the item-specific comparison table (next section) to review all items instead. As I repeat in the common-mistakes section, the absence of a parameter sheet never implies a non-controlled result.

Other Sources

Provider	Content
CISTEC	Paid; member pricing available
JMC (Japan Machinery Center for Trade and Investment)	Paid
METI	Some items published free of charge
Manufacturers	Sometimes attached to the product

If your company is not yet a CISTEC member, I would recommend joining even if the annual cost runs into hundreds of thousands of yen. Honestly, just being able to get the latest forms and the consolidated commentary on amendments is enough to pay for itself.

Structure of a Parameter Sheet

A typical parameter sheet has this structure.

1. Product information field (product name, model number, manufacturer)
2. Specification entry field (enter the product's specifications)
3. Regulatory standards field (the regulatory thresholds specified by law)
4. Classification result field (enter controlled or non-controlled)
5. Classifier information (date of classification, classifier's name)

Key Points for Drafting

1. Enter accurate specifications

Use the manufacturer's official documentation. Be careful when catalog values and measured values differ.

2. Do not make unit errors

When the units of the regulatory threshold and the product specifications differ, conversion is needed. Mixing up μm (micrometers) and mm (millimeters) is a mistake I still see in practice.

3. Pay attention to "or less" vs. "less than"

If the threshold is "500 or less," 500 is included. If it is "less than 500," 500 is not. Always check that the everyday phrasing matches the legal definition.

4. Check every applicable item

Being non-controlled under one item does not preclude being controlled under another.

Example Entry

[Product information]
Product name: Machine tool Model-X
Model number: WM-5000
Manufacturer: XX Seiki Co., Ltd.

[Specifications]
Positioning accuracy: 8 μm
Number of controlled axes: 5 axes

[Classification]
Appended Table 1, Export Trade Control Order, Item 6(1): Non-controlled
Reason: Positioning accuracy exceeds the regulatory threshold (6 μm or less)
Referenced regulations: ordinances effective February 14, 2026

Date of classification: July 10, 2026
Classifier: Export Control Dept., Taro Yamada

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[Are you repeating this work by hand?] Automating parameter sheet matching and record drafting

Selecting the right volume, matching specs against thresholds, transcribing results into a record, and re-classifying after every amendment, multiplied by your entire product lineup: that is the reality of classification work. TRAFEED is an export-control-specialized AI agent that ingests product specifications, proposes candidate item numbers with the supporting basis, and manages classification history in one place. Regulatory changes are tracked on the system side, which sharply reduces the re-classification load at moments like February 2026.

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Using the Item-Specific Comparison Table and the Latest CISTEC Editions

What Is an Item-Specific Comparison Table?

An item-specific comparison table is a form that lets you check controlled / non-controlled status for every item (Items 1 through 15) in Appended Table 1 of the Export Trade Control Order. If the parameter sheet is the tool for going deep in your own field, the comparison table is the tool for covering every field without gaps.

Current CISTEC Forms (as of August 2026)

Given how many amendments have landed recently, here is the edition to use and what it costs, as confirmed on CISTEC's official website on August 1, 2026⁴.

Form	Current edition	Member price	List price
Item-specific comparison table	February 2026	JPY 4,400	JPY 8,800
Parameter sheet: Computers	February 2026	JPY 1,650	JPY 3,300
Parameter sheet: Telecommunications and information security	February 2026	JPY 1,650	JPY 3,300
Parameter sheet: Electronics	February 2026	JPY 1,650	JPY 3,300
Parameter sheet: Acoustic sensors and radar	February 2026	JPY 1,650	JPY 3,300
Parameter sheet: Advanced materials	February 2026	JPY 1,650	JPY 3,300
Parameter sheet: Chemical precursors	February 2026	JPY 440	JPY 880
Parameter sheet: Appended Table 2 chemicals	June 2026	JPY 440	JPY 880

The edition date is shown on the cover and in the product name. If your copy is the October 2025 edition (the Catch-All revision version) or older, it does not reflect the February 14, 2026 changes and cannot be used to classify the added items, FPGA-related ones first among them.

Choosing Between Parameter Sheets and the Comparison Table

Situation	Form to use
Product for which a parameter sheet exists	Parameter sheet
Product for which no parameter sheet exists	Item-specific comparison table
First-time classification of a product	Use the item-specific comparison table to confirm the overall picture first

Procedure for Use

1. Review every item

Go through Items 1 to 15 without skipping.

2. Exclude items that are clearly inapplicable

For a generic electronic component, for example, Items 1 (weapons), 2 (nuclear) and 3 (chemical weapons) clearly do not apply.

3. Detailed review of items with potential applicability

For the remaining items, check the detailed provisions of the ministerial ordinance (the Goods and Technology Ministerial Ordinance).

4. Record classification results

Record the result and the basis for each item.

For an item-by-item walkthrough with worked examples, see How to fill out the item-specific comparison table.

A Word of Caution

The absence of a parameter sheet does not mean the product is non-controlled. All items must be checked using the item-specific comparison table.

Parameter sheets are prepared for the major product categories; they do not cover everything. Misunderstanding this point leads directly to missed classifications.

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Latest Operations of the Catch-All Controls

What Was Revised on October 9, 2025

Even when an item is non-controlled under list controls, you cannot relax. That is exactly what the supplementary export controls (the Catch-All controls) are for. On October 9, 2025, the operations were significantly revised⁷⁸.

There are two main changes.

1. Strengthening the Conventional Weapons Catch-All

Even for items outside the list controls, when an exporter ships dual-use goods of high security concern (machine tools, integrated circuits, drone parts, and so on), and the exporter themselves judges that there is a high risk of the goods being used to develop conventional weapons, a license application to the Minister of METI is now required. This shift, placing weight on the exporter's own judgment, is a meaningful change. For how to read the objective criteria known as the "Akiraka (evident) Guideline," see the companion article: Explaining the Catch-All "Akiraka Guideline".

2. Changes to handling of shipments to Group A countries

Until now, shipments to Group A countries (the former White Countries) enjoyed a substantially relaxed Catch-All regime. Under this revision, even when the destination is a Group A country, if the exporter receives an "Inform notice" from the Minister of METI requiring a license application, for the purpose of preventing diversion, a license application is now required.

What to Prepare

In practical terms, expect to do the following.

• Inventory existing export cases involving dual-use goods bound for Group A countries
• Convert your end-use and end-user verification process into a checklist
• Establish an internal escalation flow for when an "Inform" arrives
• Move up the timing at which sales hands information over to the export control team

The era when "non-controlled under the list = safe" is over. Before issuing a certificate of non-applicability, document the end-use and end-user verification too; otherwise the exporter is the one left exposed.

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[METI statistics] 52% of FY2024 foreign exchange law violations stem from classification work

According to METI's December 2025 publication "Analysis of Foreign Exchange Act Violations (FY2024)," 52% of export control violations trace back to classification, and within that, "no classification performed" or "assumed non-controlled" accounts for 32%⁹. A further 36% of violations were caused by "weaknesses in the management framework (lack of FEFTA awareness or knowledge)." Roughly nine in ten violations come down to the same two issues: how classification is run, and how the internal control system is built.

Building parameter sheet drafting and item-specific comparison table operations into a process that does not depend on one person is, right now, the single most urgent issue on the ground.

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Classification in the Era of Economic Security

China's Export Controls on Dual-Use Items Bound for Japan

On January 6, 2026, China's Ministry of Commerce issued a public notice prohibiting exports of dual-use items to Japan when the end-user is a military user, the end-use is military, or the use contributes to enhancing military capability. The notice took effect the same day¹⁰.

Then on February 24, twenty Japanese companies and universities were placed on China's "Export Control List," and dual-use exports to those entities are now in principle prohibited¹¹. From the Japanese side, this means supply chains that depended on raw materials and intermediate goods from China can suddenly become inaccessible.

For the full picture, see the related article: The Impact of China's Strengthened Export Controls on Dual-Use Items Bound for Japan.

US EAR and the Entity List

On the US side, the centerpiece is the Export Administration Regulations (EAR) administered by the Bureau of Industry and Security (BIS) at the Department of Commerce. For companies on the Entity List, controls extend not only to US-origin items but also to certain foreign-produced items via the re-export rule and the Foreign Direct Product Rule¹².

For Japanese companies, the implication is straightforward: if your product contains US-origin technology or components, you have to satisfy not only Japanese law but also the EAR. Classification work no longer ends at the boundary of Japanese law. For the EAR-side classification workflow, see the practical guide to EAR compliance; for the structure of ECCN numbers, see the ECCN number list and category cheat sheet. Plenty of teams conflate Japan's classification records with EAR's ECCN determinations; keep the two frameworks separate in your head.

The Wassenaar Arrangement and Domestic Law

As noted in the section on the February 14, 2026 amendment, much of Japan's list controls are translations of agreements reached at the Wassenaar Arrangement (the international framework for export controls on conventional weapons and related dual-use goods and technologies)¹³. Newly agreed controls at Wassenaar typically appear in Japan's Export Trade Control Order within several months to a year. The FPGA-embedded equipment addition followed exactly this route.

If you watch the moves at Wassenaar and the related regimes (NSG, AG, MTCR), you can read ahead reasonably well as to where the next wave of tightening will hit.

Amendment of the Three Principles on Defense Equipment Transfer

On April 21, 2026, the operational guidelines for the Three Principles on Defense Equipment Transfer were amended, removing the "five categories" that had previously constrained the export of equipment with lethal capability¹⁴. With the seventeen countries that have signed defense equipment and technology transfer agreements with Japan, finished items such as fighter aircraft and escort ships can now in principle be transferred.

For the classification frontline, the change means that the handling of gray-zone defense-related items, products that are not weapons themselves but could be diverted for military use, will be scrutinized more closely than ever. See Amendment of the Three Principles on Defense Equipment Transfer for the details.

Middle East Risk and the Supply Chain

Shifts in the Middle East situation, including the risk of a Strait of Hormuz blockade, also indirectly affect classification work on the ground. When shipping routes change, so do the methods of verifying the final destination. From the supply-chain angle on export control, The Impact of a Strait of Hormuz Blockade on Japan's Economy is worth reading alongside this article.

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Common Mistakes and Points to Watch

Mistake 1: Checking only some items

Problem: Thinking "this product is a communications device, so I only need to look at Item 9" and skipping the rest.

Correct approach: A communications device may also fall under Item 7 (electronics), Item 8 (computers), or Item 15 (cryptography). Check every item.

Mistake 2: Classifying based on outdated specifications

Problem: Reusing an old parameter sheet after the product has been upgraded.

Correct approach: When the product's specifications change, re-classification is required. Even with the same model number, if a firmware update has added functionality, it is safer to classify again.

Mistake 3: Accepting the manufacturer's classification without verification

Problem: The manufacturer said "non-controlled," and the product was exported on that basis.

Correct approach: Even when you receive a classification record from the manufacturer, the exporter has to verify the contents. The responsibility for classification lies with the exporter. I cannot say this enough.

Mistake 4: Forgetting Catch-All controls

Problem: The product was non-controlled under list controls, so it was exported.

Correct approach: Even non-controlled items can fall under Catch-All controls depending on the end-use and end-user. From October 2025 onward, an Inform notice can be issued even for shipments to Group A countries⁷.

Mistake 5: Forgetting to classify technology

Problem: Goods classification was performed, but no classification was done for technology (design drawings, manuals, etc.).

Correct approach: When technology information is provided alongside goods, the technology has to be classified separately.

Mistake 6: Assuming "civilian product means safe"

Problem: Assuming that because a product is commercially available, it is not subject to regulation.

Correct approach: Even commercially available products can be controlled depending on their specifications. The line between civilian and military is especially fuzzy for semiconductors, measurement instruments, and cryptography. The general-purpose FPGA board that became controlled in February 2026 is exactly this pattern. Always classify.

Mistake 7: Letting your tracking of amendments lapse

Problem: Reviewing the law only once a year.

Correct approach: The Catch-All revision landed in October 2025 and the list-control amendment in February 2026, in quick succession. Wassenaar agreements are typically reached at the December plenary and reflected in Japanese law thereafter; knowing that rhythm helps you anticipate the next wave.

Mistake 8: Writing "non-controlled" and "outside the scope" interchangeably

Problem: The record just says "not subject to regulation," with no item numbers checked and no category stated.

Correct approach: As explained earlier, non-controlled (item numbers checked, below threshold) and outside the scope (does not fit any item's definition) mean different things. If the record does not show which category applies and which item numbers were reviewed, inquiries from counterparties or customs will force the work to be redone.

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Automating Classification with TRAFEED

The Pain Points on the Ground

If you have read this far, you will see that export classification is not "just a check." The challenges practitioners face look like this.

Challenge	Detail
Specialized knowledge required	Both legal understanding and technical knowledge are needed
Time-consuming	A single classification can take hours to days
Risk of errors	A wrong classification can become a legal violation
Keeping up with regulatory changes	Amendments like February 2026 trigger re-classification across the lineup
Personnel shortage	The number of people who can classify is limited

The personnel issue, in particular, is severe. I have seen several companies where the export control function effectively reset to zero the moment the senior practitioner retired.

How TRAFEED (formerly ZEROCK ExCHECK) Helps

Of FY2024 FEFTA violations, 52% stem from classification work⁹. Companies that violated the law cluster around the same patterns: classification not performed, items assumed to be non-controlled, item-specific comparison tables out of date. TRAFEED was designed specifically to address these root causes, over-reliance on individual experts and gaps in institutional knowledge, by absorbing them into the AI layer.

TRAFEED (formerly ZEROCK ExCHECK) is an export-control-specialized AI agent provided by TIMEWELL. It embeds classification logic aligned with both METI and CISTEC standards, and is designed for multilingual use so that overseas sites can use it as well. In Japan's security export control field, it is the first AI agent of its kind, as of March 2026 and based on our own research, and the classification technology is patented (Japanese Patent No. 7862062).

In a joint validation with Okayama University, a national university corporation, TRAFEED achieved an AI classification accuracy of 95 percent or higher against roughly 30,000 past screening records (based on our own research). It is currently in use at more than 20 organizations across universities and companies. It covers same-day reflection of regulatory changes across jurisdictions, internal approval workflows, and advance due diligence on international students and new counterparties. Even so, the final classification decision belongs to your company's export control officer. I have said this before in this article, and it bears repeating: that premise does not move.

Function	Content
Classification support	Suggests applicable item numbers from product specifications
Basis for classification	Shows the reasoning behind each controlled / non-controlled call
Automatic regulatory updates	Picks up amendments to the law automatically
Management of classification history	Centralized management of past results
Multilingual support	Usable at overseas sites and by non-Japanese-speaking staff

Implementation Effects (Benchmarks)

Metric	Effect
Classification time	Roughly 70 percent reduction
Classification accuracy	Practical-grade quality, with reviewer in the loop
Missed regulatory changes	Substantially reduced through automatic updates

These figures are benchmarks based on feedback from companies using the system. Naturally, the actual impact varies with product complexity and existing workflows.

The Division of Roles Between AI and Humans

Task	AI (TRAFEED)	Human
Extracting candidate item numbers	Automated	Verification
Comparing specifications against regulatory values	Automated	Verification
Drafting the classification basis	Automated	Verification and approval
Final classification	Proposal	Decision
Detecting regulatory changes	Automated	Decide on response

AI is a support tool. Final responsibility for the classification rests with the human, that is, the exporter. That is a legal point that cannot move, and TRAFEED is designed on exactly that premise.

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[Who this is for]

• Classification work is concentrated in one or two specialists, and the process is highly person-dependent
• Re-classification of FPGA-equipped products after the February 2026 amendment is not yet finished
• Every time the law is amended, tracking the diffs in the item-specific comparison table consumes significant time
• Trade documents in English or Chinese cannot be used as-is at overseas sites, and every classification involves a translation step
• During an audit, you have struggled to reproduce the basis of past classifications

If even one of these applies, a 30-minute TRAFEED consultation can typically map out a path forward.

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Start with a Free Consultation

We get a steady stream of requests like "I want to know how far it could be applied to our classification work" or "I want a diagnostic of our current workflow." In a 30-minute online consultation, we can talk through your current operations and walk through how TRAFEED would apply.

Book a free TRAFEED consultation

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TRAFEED Resources

Link	Content
Classification record and certificate templates (2026 edition)	Certificate form, item-specific comparison sheet, catch-all check sheet, and classification log. The forms are in Japanese, since that is what Japanese customs and counterparties expect
TRAFEED product catalog (PDF)	Service document covering functions and rollout flow
TRAFEED individual consultation (30 min)	Our team listens to your classification operations and proposes how to apply TRAFEED
TRAFEED service details	Functions, case studies, and pricing plans
Free export compliance diagnostic	A 3-minute self-check to score your own internal control framework

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Summary

Key Takeaways

• No legal format exists for a certificate of non-applicability. Nine fields, addressee through issuer, will carry you through customs and counterparty review
• Clearing Items 1 through 15 still leaves Item 16. Issuers should add the note; recipients should move on to the end-use and end-user check
• A classification record documents the work; a certificate of non-applicability declares the non-controlled result externally. Keep the roles separate
• "Non-controlled" and "outside the scope" also mean different things. Write records so that the category and the item numbers checked are visible
• There is no statutory format. Obtain CISTEC's item-specific comparison table and parameter sheets (February 2026 edition) from the official website and re-shape them into your internal format
• The amendment effective February 14, 2026 added FPGA-embedded equipment (Item 7 (10-2), total LUT input count of 1,800,000 or more), peptide synthesizers, and high-entropy alloy powders. Potentially affected products must be re-classified
• Certificates of non-applicability have no statutory expiration date, but amendments, specification changes, and counterparty requirements trigger re-issuance. Always state the referenced regulation version and classification date
• When requesting documents from manufacturers, specify the model number, whether you need the supporting basis, and the regulation reference date. If no record is available, ask for the specifications and classify in-house
• Even when non-controlled under list controls, Catch-All end-use and end-user verification remains a separate requirement
• TRAFEED can substantially cut classification time, but the final responsibility stays with humans

The Iron Rules of Export Classification

1. METI does not classify. You bear the responsibility for classifying yourself
2. Check every item. Do not conclude based on a partial review
3. Keep records. Make the basis and the referenced regulation version clear
4. Review periodically. Keep up with both regulatory and product changes
5. Consult specialists on unclear points. Do not force a call in gray areas

A Note from the Author

To put it plainly: export control is the kind of area where "we did the work" rarely gets celebrated, but "we should have done the work" hits all at once. The reputational damage when a violation surfaces is incomparable to the cost of running classifications quietly inside the company. One incident can chain into export suspensions, public disclosure, and lost trust with counterparties.

The February 2026 amendment pulled products like general-purpose FPGA boards, which never needed classification before, into the controlled list. The next amendment will do the same to something else. It is unglamorous work, but patiently building up classifications, with the referenced regulation version recorded each time, is the realistic path. A major amendment is exactly the moment to revisit your own classification flow.

What prompted this rewrite was a single question from a reader: "My certificate says Item 16 applies. Does that mean we cannot ship?" METI answers it on one sheet of A4. The catch is that you have to know to go looking for it. Wherever the explanation of a rule fails to reach the people applying it, that is where the work jams up.

Book a free TRAFEED consultation

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Related Articles

• Complete Guide to the Export Trade Control Order Amendment Effective February 2026: FPGA-Embedded Equipment and the International Regime Additions
• How to Fill Out the Item-Specific Comparison Table: Checking Appended Table 1 Item by Item
• Explaining the Catch-All "Akiraka Guideline": Reading the Objective Criteria in Practice
• Complete Guide to China's Export Controls Against Japan: 40-Company Blacklist, Dual-Use Restrictions, and Practical Responses
• 52% of FY2024 FEFTA Violations Stem from Classification Work: Lessons from METI Statistics
• ECCN Number List and Category Cheat Sheet: Categories 0-9, Product Groups A-E, and How to Read Reasons for Control
• Practical Guide to EAR Compliance: ECCN and EAR99 Classification Steps

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Footnotes (Primary Sources)

Footnotes

1. Ministry of Economy, Trade and Industry, "Points on Issuing a Certificate of Non-Applicability" https://www.meti.go.jp/policy/anpo/2022053002.pdf (retrieved August 1, 2026) ↩ ↩² ↩³ ↩⁴

2. METI, "Cabinet decision on a partial amendment to the Export Trade Control Order" (November 11, 2025) https://www.meti.go.jp/press/2025/11/20251111001/20251111001.html ↩ ↩² ↩³

3. CISTEC (Center for Information on Security Trade Control), official website https://www.cistec.or.jp/ ↩ ↩²

4. CISTEC, "Classification materials (item-specific comparison table and parameter sheets)" https://www.cistec.or.jp/publication/gaihi.html (February 2026 editions of the item-specific comparison table and the six parameter sheet volumes; confirmed on August 1, 2026) ↩ ↩² ↩³ ↩⁴

5. Export Trade Control Order (Cabinet Order No. 378 of 1949), e-Gov law search https://laws.e-gov.go.jp/law/324CO0000000378/ (Article 1, paragraph 3 and Article 4, paragraph 1, items 3 and 4 cover Item 16 of Appended Table 1. Retrieved August 1, 2026) ↩ ↩² ↩³

6. METI, "Overview of the Amendments to the Export Trade Control Order and Related Regulations" (November 2025) https://www.meti.go.jp/policy/anpo/law_document/seirei/20251114_gaiyo01.pdf ↩ ↩²

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

8. METI, "Related Laws and Amendment Information (Security Trade Control)" https://www.meti.go.jp/policy/anpo/law00.html ↩

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

10. CISTEC, "Strengthening of China's Export Controls on Dual-Use Items Bound for Japan (Flash Report)" (January 6, 2026) https://www.cistec.or.jp/service/keizai_anzenhosho/china/data/20260106-2.pdf ↩

11. CISTEC, "Chinese Authorities Place Japanese Companies and Universities on the 'Export Control List' (20 entities) and 'Watch List' (20 entities) (Flash Report)" (February 25, 2026) https://www.cistec.or.jp/service/keizai_anzenhosho/china/data/20260225.pdf ↩

12. US Department of Commerce, Bureau of Industry and Security (BIS), "Lists of Parties of Concern" https://www.bis.doc.gov/index.php/policy-guidance/lists-of-parties-of-concern ↩

13. Wassenaar Arrangement, official website https://www.wassenaar.org/ ↩

14. METI, "Partial Amendment of the 'Three Principles on Defense Equipment Transfer' and Related Documents" (April 21, 2026) https://www.meti.go.jp/press/2026/04/20260421003/20260421003.html ↩