![[2026-May Update] What Is a Certificate of Non-Applicability? Classification Steps, Parameter Sheet Drafting, and the Latest Catch-All Control Operations Explained for Practitioners](/images/columns/default-column.png)
[2026-May Update] What Is a Certificate of Non-Applicability? Classification Steps, Parameter Sheet Drafting, and the Latest Catch-All Control Operations Explained for Practitioners
Hello, this is Ryuta Hamamoto from TIMEWELL.
On November 11, 2025, an amendment to the Export Trade Control Order was approved by the Cabinet, adding modules incorporating Field Programmable Gate Arrays (FPGAs) to Appended Table 1[^1]. Just before that, on October 9, the supplementary export controls (commonly called the Catch-All controls) were also revised[^2]. In January 2026, China issued a notice that effectively prohibits exports of dual-use items to Japan[^3], and in April the operational guidelines for the Three Principles on Defense Equipment Transfer were also amended[^4].
Since the November 2025 amendment in particular, I have been getting roughly three times as many questions from practitioners as before, asking things like "How do we draft a certificate of non-applicability that will pass internal review?" or "Should we re-classify our products from scratch?" Export control is a quiet area, but it is moving fast.
I have rewritten the original article to reflect the latest operations and practical workflows. It is long, but if you read through to the end you should have a clear sense of what to revisit inside your own company.
Summary (What You Will Learn from This Article)
- Export classification is the exporter's own responsibility — METI does not classify on your behalf
- A certificate of non-applicability is the document used to demonstrate, internally and externally, that an item is not subject to controls
- The November 11, 2025 amendment added FPGA-related items to Appended Table 1 of the Export Trade Control Order
- The October 9, 2025 Catch-All revision means license applications can now be required even for shipments to Group A countries under certain conditions
- A combination of parameter sheets and item-specific comparison tables is the working baseline for practitioners
- Using TRAFEED, practitioners typically report cutting classification time by more than 70 percent
Table of Contents
- What Is Export Classification? Why Is It Necessary?
- Differences Between Certificates of Non-Applicability, Classification Records, and Parameter Sheets
- What Changed in the November 11, 2025 Amendment to the Export Trade Control Order
- Latest Operations of the Catch-All Control (Supplementary Export Restrictions)
- Classification in the Era of Economic Security: Connections with China's Countermove, US EAR, and Wassenaar
- The 4 Steps of Export Classification
- How to Obtain and Fill Out Parameter Sheets
- How to Use Item-Specific Comparison Tables (CISTEC Format)
- Common Mistakes and Points to Watch
- Automating Classification with TRAFEED
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 regulations[^5].
| 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.
Replace siloed classification work with AI.
METI's FY2024 data shows 52% of foreign exchange law violations stem from classification errors. TRAFEED cuts determination time by ~70% and stores structured rationale for every decision.
Differences Between Certificates of Non-Applicability, Classification Records, and Parameter Sheets
The Relationship Between the Documents
Documents in export control go by several different names, and the terminology trips people up at first. Let me organize them.
| 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 |
Classification Record vs. Certificate of Non-Applicability
| Category | Classification record | Certificate of non-applicability |
|---|---|---|
| Meaning | Record of the classification process | Proof of non-applicable status |
| Classification result | Either controlled or non-controlled | Non-controlled only |
| Uses | Internal records, attached to license applications | Submitted to customs and counterparties |
In short, a "classification record" documents the classification process itself, while a "certificate of non-applicability" is the outward-facing document issued when the result is non-controlled. Holding that distinction in mind will keep you out of trouble.
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 (communications, computers, machine tools, etc.)
- They have entry fields for product specifications
- They allow you to compare specs against regulatory thresholds and reach a controlled / non-controlled determination
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[^6].
Its strengths:
- Covers all product categories
- Lets you check every potentially applicable item number
- Works for product categories that have no parameter sheet
CISTEC also released an updated version of the item-specific comparison table aligned with the October 2025 Catch-All revision[^7]. If your team is still using older forms, this is a good moment to refresh.
What Changed in the November 11, 2025 Amendment to the Export Trade Control Order
On November 11, 2025, the Cabinet approved a partial amendment to the Export Trade Control Order, which was promulgated on November 14[^1]. The effective dates differ by provision: November 15, 2025 (Reiwa 7) and February 14, 2026 (Reiwa 8) are scheduled.
Main Points of the Amendment
Reading through METI's overview materials, the amendment has three pillars[^8].
1. Additions to controlled goods (FPGA-related)
Reflecting agreements reached at the international export control regimes (the Wassenaar Arrangement, NSG, AG, and MTCR), modules, assemblies and equipment incorporating FPGAs (Field Programmable Gate Arrays) have been added to Appended Table 1. In effect, the perimeter around semiconductors has tightened by another notch.
2. Removing duplicate regulation
"Eel fry" is being newly regulated under the Act on Ensuring the Proper Domestic Distribution of Specific Aquatic Animals and Plants from December 1, 2025 (Reiwa 7), and was therefore removed from Appended Table 2 of the Export Trade Control Order. A small change, but a signal that overlapping controls are being tidied up.
3. Special exception for temporary weapons exports
Items such as bulletproof vests carried abroad by the National Police Agency for VIP protection during foreign visits, where the items are obviously expected to be brought back, no longer require an export license.
Implications for Practitioners
Honestly, point 1 is the one with the broadest impact. FPGAs sit inside industrial machinery, measurement instruments, communications equipment, and defense-related hardware — pretty much every category. If you build finished products, this is the moment to look across your bill of materials and answer two questions: does our equipment contain FPGAs, and if so, which part numbers?
Amendments based on international regime agreements may look like minor textual additions on the surface, but they tend to ripple widely. Pulling the BOM is the practical first step.
Latest Operations of the Catch-All Control (Supplementary Export Restrictions)
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 revised[^2][^9].
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 subjective judgment — is a meaningful change.
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.
[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 (該非判定) — and within that, "no classification performed" or "assumed non-controlled" accounts for 32%[^meti2024]. 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.
Classification in the Era of Economic Security: Connections with China's Countermove, US EAR, and Wassenaar
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 day[^3].
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 prohibited[^10]. 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 on Japan's Economy and Industry.
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 Rule[^11].
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.
The Wassenaar Arrangement and Domestic Law
As I touched on in the November 11 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)[^12]. Newly agreed controls at Wassenaar typically appear in Japan's Export Trade Control Order within several months to a year.
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 capability[^4]. 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: How the Removal of the Five Categories Affects Japan's Security and Industry 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 to broaden the perspective.
The 4 Steps of Export Classification
From here on, this is the practitioner workflow. The base is unchanged from the previous version, with notes added to align with the latest operations.
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 are[^5]:
| 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.) |
Note that the November 2025 amendment added FPGA-related items under Item 7, so anything in the electronics line warrants a fresh look[^1].
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.
How to Obtain and Fill Out Parameter Sheets
How to Obtain
Parameter sheets can be obtained from the following sources.
| Provider | Content |
|---|---|
| CISTEC | Paid; free for members |
| 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 item-specific comparison table and the consolidated commentary on amendments is enough to pay for itself.
Structure of a Parameter Sheet
A typical parameter sheet has this structure.
- Product information field (product name, model number, manufacturer)
- Specification entry field (enter the product's specifications)
- Regulatory standards field (the regulatory thresholds specified by law)
- Classification result field (enter controlled or non-controlled)
- 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 Japanese (or English) 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)
Date of classification: May 2, 2026
Classifier: Export Control Dept., Taro Yamada
[For practitioners who want a working template] Internal templates for parameter sheets and classification records
The item-specific comparison table and parameter sheets that CISTEC publishes are hard to use as-is on the floor — in practice, most teams re-shape them into internal approval formats. If you are looking to build a company-specific template, or to redesign your classification record form, a 30-minute TRAFEED consultation can walk through real examples and help you organize a draft.
How to Use Item-Specific Comparison Tables (CISTEC Format)
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. CISTEC has released a version updated for the October 2025 amendment[^7].
Choosing Between Parameter Sheets and Item-Specific Comparison Tables
| 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 non-controlled
For a generic electronic component, for example, Items 1 (weapons), 2 (nuclear) and 3 (chemical weapons) are clearly non-controlled.
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.
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.
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 countries[^2].
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 becomes especially fuzzy for semiconductors, measurement instruments, and cryptography. Always classify.
Mistake 7: Letting your tracking of amendments lapse
Problem: Reviewing the law only once a year.
Correct approach: 2025 saw two major amendments back to back, in October and November. Wassenaar agreements are typically reached at the December plenary, and they tend to be reflected in Japanese law from the following spring onward — knowing that rhythm helps you anticipate the next wave.
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 must be tracked continuously |
| 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 work[^meti2024]. 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.
| 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.
[Who this is for]
- Classification work is concentrated in one or two specialists, and the process is highly person-dependent
- 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
- You have not yet finished checking your own exposure to China's 40-entity sanctions list against Japan, or the 835 entities on the Foreign User List
If even one of these applies, a 30-minute TRAFEED consultation can typically map out a path forward.
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
TRAFEED Resources
| Link | Content |
|---|---|
| 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 |
Summary
Key Takeaways
- Export classification is the exporter's own responsibility. METI does not classify
- A certificate of non-applicability is the document used to demonstrate non-controlled status, and is generally meant to be shown externally
- The November 11, 2025 amendment added FPGA-related items to Appended Table 1
- The October 9, 2025 Catch-All revision means license applications can be required even for shipments to Group A countries
- Foreign laws — China's countermove, the US EAR, Wassenaar — can no longer be ignored
- A combination of parameter sheets and item-specific comparison tables is the practitioner baseline
- TRAFEED can substantially cut classification time, but the final responsibility stays with humans
The Iron Rules of Export Classification
- METI does not classify. You bear the responsibility for classifying yourself
- Check every item. Do not conclude based on a partial review
- Keep records. Make the basis for each classification clear
- Review periodically. Keep up with both regulatory and product changes
- 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.
It is unglamorous work, but doing it patiently is the realistic path. In a period this thick with amendments, this is exactly the moment to revisit your own classification flow.
Book a free TRAFEED consultation
Related Articles
- Complete Guide to China's Export Controls Against Japan: 40-Company Blacklist, Dual-Use Restrictions, and Practical Responses for Japanese Companies
- What Are the Three Principles on Defense Equipment Transfer? What Changed in the April 21, 2026 Amendment? Five Practical Points for Export Control Practitioners
- 52% of FY2024 FEFTA Violations Stem from Classification Work — The Top 5 Fatal Failures in Export Control and Prevention Strategies, Read from METI Statistics
- The Impact of a Strait of Hormuz Blockade on Japan's Economy
Footnotes (Primary Sources)
[^1]: 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]: METI, "Revision of the Supplementary Export Controls (effective October 9, 2025)" https://www.meti.go.jp/policy/anpo/apply-01/20251009_catchminaoshi/20251009catchall.html
[^3]: 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
[^4]: 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
[^5]: Export Trade Control Order (e-Gov Laws and Regulations Search) https://laws.e-gov.go.jp/law/324CO0000000378/
[^6]: CISTEC (Center for Information on Security Trade Control), official website https://www.cistec.or.jp/
[^7]: CISTEC, "Item-Specific Comparison Table 2025 Revised Edition Accompanying the Partial Amendment of Catch-All Controls" https://www.cistec.or.jp/publication/251010kaisei_taihihyo.html
[^8]: 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
[^9]: METI, "Related Laws and Amendment Information (Security Trade Control)" https://www.meti.go.jp/policy/anpo/law00.html
[^10]: 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
[^11]: 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
[^12]: Wassenaar Arrangement, official website https://www.wassenaar.org/
[^13]: METI, "Security Trade Control" https://www.meti.go.jp/policy/anpo/
[^meti2024]: METI, "Analysis of Foreign Exchange Act Violations (Security Trade Control) (FY2024)" (December 2025) https://www.meti.go.jp/policy/anpo/gaitameho_document/ihanjireigaitamehou6.pdf