Red Tape in Export Controls, and Where the Burden Falls in Japan and the US

Hello, this is Ryuta Hamamoto from TIMEWELL.

Lately I keep hearing the same sentence from export compliance staff and university administrators: "We know the controls matter for security. But the process is so heavy that it slows down our business, or our research." In English, people bundle this frustration into two words, red tape. It is a figure of speech for bureaucratic clutter, from the ribbon once used to tie up official papers.

This article answers three questions. Is the red-tape argument really a call to scrap export controls? What do primary sources from Japan and the US actually show about where the burden sits? And what can a company do, inside the current rules, to lighten it?

My short answers come first. In the documents I read, the red-tape argument is mostly about how the system is run, not whether it should exist. In both countries the complaints cluster less around the volume of paperwork than around waiting time and the lack of visibility into it. Japan has been simplifying through blanket licenses and a revision in November 2025, and companies can ease their own load by standardizing classification and using blanket licenses where they fit.

One honest note. The phrase "red tape" itself did not appear in any of the government documents or survey reports I read for this piece. They use words like compliance cost, administrative burden, rationalization, processing time and transparency. I use "red tape" here as a lens that lets us look at all of those together. I will not blame the regulators or the regulated. I will stay with what the primary sources can support.

Key terms first, and what "red tape" means

Public administration researchers have studied red tape for decades. The term is generally used for a procedure that costs time or money to comply with but does not serve the purpose the rule was meant to serve. In a 1993 paper, the American scholar Barry Bozeman treated red tape as an organizational pathology and separated rules that were dysfunctional from the start from rules that were once useful and later turned into red tape.¹ Procedures that do serve a clear purpose, but still burden the people who must follow them, are usually called administrative burden, a different thing.

That distinction matters here, because export control procedures have an obvious purpose: keeping dangerous goods and technology from moving where they should not. In the documents I read, almost no one argues that verification should not exist. The argument is about whether the way it is carried out fits the goal.

Think of airport security. Few people object to the screening itself. The grumbling starts when the line is far too long, when nobody explains why you must take your shoes off, when you cannot tell when you will get through, or when you are asked to show the same document at every counter. The export control debate has much the same shape.

Here are the terms I use in this article.

Term	Meaning	Everyday comparison
Red tape	A compliance burden that does not serve the rule's purpose	A security line with no explanation and no sense of the wait
Administrative burden	A purposeful procedure that still costs users time or money	The screening itself
Classification (known in Japan as "gaihi" determination)	Checking whether your goods or technology fall under a control list	Checking for yourself whether your bag holds a prohibited item
Individual license	Government permission for each transaction	Getting a visa for every trip
Blanket license	Permission for a defined range of exports at once	A season pass
Exporter compliance standards	The minimum internal rules every Japanese exporter must follow	The traffic rules every licensed driver follows
Compliance cost	Time and money a company spends to follow a rule	The effort of packing so you clear screening smoothly

Where the burden falls in Japan

Japan's export control process runs in stages. To see where friction builds up, it helps to look at the whole flow first.

Stage	What happens	Where the burden tends to pile up
Classification	Match product specifications against the legal criteria	Requires expertise; METI does not confirm the result
Transaction screening	Check the end use and end user on each deal	Grows with the number of transactions
License application	Apply electronically when a license is needed	Document preparation, corrections, review time
Shipment and records	Verify the goods at shipment and keep records	Retention periods and location tracking

On classification, the government's own position is clear. A guide for small and medium-sized companies published by JETRO, Japan's trade promotion agency, states that METI does not confirm classification results. Procedural questions go to the licensing division, but the determination is the exporter's responsibility. The same guide admits that many small companies have not built internal systems because of limits on knowledge and resources.² So the authorities themselves recognize that a fixed burden weighs more on smaller firms.

How big is the burden? METI writes ex-post evaluations of regulations and estimates what compliance costs. In its March 2025 evaluation of new export controls adopted to implement international agreements, METI put the work of obtaining a license at 10 hours per case, 5 hours for each of 2 people. The pre-introduction estimate came to about 29,500 yen per case in labor cost, and the later estimate to about 26,600 yen.³

Read those numbers with care. They cover the work of obtaining a license only. Classification and the upkeep of internal systems are not line items. The evaluation itself says the burden varies by company size and is hard to quantify because it involves companies' confidential information. And Japan does not publish how many license applications it receives, for security reasons. In the course of my research I found no public statistic that measures the total burden from the outside. That is one reason the red-tape debate leans on survey reports and association petitions.

For the baseline rules every exporter faces, see our guide to the exporter compliance standards, which sets out the two standards that apply to everyone and the extra items for companies handling listed goods.

What industry is asking for

Let me turn to industry voices. The Security Trade Control Committee of the Japan Foreign Trade Council, a trading-company association, files requests with METI every year. I went through its request of July 7, 2025.⁴

The first item concerns electronic-only filing. Since July 2022, export license applications can only be filed electronically. A company that outsources customs clearance and exports a listed item once every few years has no NACCS ID, because it never uses the customs system. To file one application it must register as an applicant and then keep its registration up to date afterward, which the Council says is a heavier workload than the old paper process. The second item is a request to restore face-to-face consultations. Pre-consultations now run mainly by email, answers mostly point to the legal text, and detailed back-and-forth begins only after filing, which forces document swaps and delays.

The third is visibility. After filing, applicants cannot tell whether review is going smoothly, stalled, or waiting for their reply, so the Council asks for a dashboard showing the status of all applications. The fourth is a mismatch between which input fields are marked mandatory and what correction instructions demand. Among continuing requests are limits on how long old controlled equipment must be tracked, and acceptance of electronic signatures on the written pledge attached to applications.

I also read comments that CISTEC, the Center for Information on Security Trade Control, sent to METI on March 1, 2025, about draft amendments to the controlled-items lists. It asks for clearer wording where phrases could be read two ways, and for definitions of terms. One point stood out to me. If Japan's classification thresholds do not line up with the scales used in the US EAR, Japanese manufacturers may need a great deal of time and effort to obtain the information they need from US suppliers.⁵ Part of the burden, in other words, comes from how clear a rule's text is and how well it fits with other countries' rules.

Read together, these requests contain almost nothing like "loosen the controls." What they ask for is predictability of waiting time, a more flexible front door, and clearer screens and clauses. I think that is the real substance of the Japanese red-tape debate. This is only my reading of association petitions, though, not the voice of every company, and I could not confirm how METI responded to each request.

What the government has simplified

The regulators have not stood still. Here is what I could verify.

The center of it is the blanket license. According to METI's handling guideline for blanket licenses (latest revision promulgated November 14, 2025), there are six types. The general blanket license, for instance, covers specified goods exported to the destinations listed in Annex 3 of the Export Trade Control Order, the so-called Group A countries, and is valid for no more than three years. To apply, a company must either register its compliance officers or hold acceptance receipts for its internal compliance program and self-check list. The guideline also gives a processing target. If the officers are registered and nothing is amiss, issuing the license within about a week is the aim. It adds that this is not a guarantee, because time spent answering inquiries counts toward the period.⁶

What about individual licenses? I came across information that METI's introductory guidance says review takes in principle up to 90 days from receipt. I could not read the original, because METI's site restricts automated access, so I treat this as unconfirmed.

The November 2025 revision also points toward lighter burdens. METI's summary says it was promulgated on November 14, 2025 and took effect on February 14, 2026, with some parts earlier. As part of rationalizing licensing, it widened the scope of the special general blanket license "to reduce the burden on applicants." It also made accessories and parts for defense equipment sent to countries with a defense equipment transfer agreement eligible for the specified blanket license, and relaxed a track-record requirement for certain goods. Services under Japan's Official Security Assistance program, and re-supply of an identical program after its storage medium is damaged, no longer need a license.⁷

Here is my own view. A blanket license does cut the number of individual filings. But to obtain one you must first register officers or hold program and checklist receipts. The system asks you to take on one burden, building internal controls, in exchange for removing another. Whether that is a fair trade or a high entrance fee for a small company depends on where you stand. Our article on individual versus blanket licenses lays out the differences among the types and the situations where they cannot be used. It also explains that blanket licenses do not apply to catch-all controls.

The system keeps moving. From October 19 to November 18, 2026, METI is running a public comment period on draft amendments to the Foreign Exchange Order and the Export Trade Control Order, including items added and removed from the lists and a new exclusion from the ban on settling payments before approval.⁸ For the details, see our explainer on the October 2026 public comment draft. A comment period is one of the few official channels through which a company can tell the rule-makers what actually hurts in practice.

In the US, the argument centers on waiting

In the United States, the Commerce Department's Bureau of Industry and Security (BIS) reviews export licenses. Section 750.4 of the EAR sets the clock. The 90-day deadline runs from the day BIS registers an application in its electronic system. Within 9 days of registration BIS does its initial processing, and for cases referred to other agencies, those agencies must give their recommendations within 30 days. But time spent waiting for the applicant, for pre-license checks, and for congressional notification is excluded from the count.⁹ That is one reason the 90 days in the rule and the wait a company feels can differ.

Now the record. A Reuters report from August 2025 gave BIS's average processing time for fiscal 2023 as 38 days, with 2% of 37,943 applications denied.¹⁰ The same report relayed one US official's view that the 2025 backlog was the longest in more than three decades. The president of the US-China Business Council said that in whole sectors there was no sign of whether or when licenses would be issued.

The regulator's side is also on record. A Commerce spokesperson said in the same report that BIS would no longer rubber-stamp applications that raise grave national security questions. The position is that slower review reflects closer scrutiny.

In 2026 a more systematic survey appeared. The US think tank CSIS published it on April 21, 2026. It was fielded from January to March 2026 through semiconductor and technology trade associations, and yielded 31 substantive responses. About two thirds of respondents were in semiconductors, and 94% were large firms with 500 or more employees. Even so, the pattern is worth noting. 56% said their average review time exceeded 180 days, against 22% who said it fell within the statutory period. 78% said times had risen over the last 12 months, and 54% said they had lost business or contracts because of delays. 85% now factor licensing delays into sales planning.¹¹

Caution is needed. The sample is small and the data are self-reported, and the report itself acknowledges possible self-selection bias. Its authors note that licenses for China-related cases may involve more complex review. Respondents' sense of elapsed time may not match the rule's 90-day clock. And small businesses are barely represented. I found no recent figure that measures small-business experience in the US either.

Congress responded. On April 17, 2026, Representatives Meeks (Democrat) and Issa (Republican) introduced a bill that directs BIS to decide licenses within 90 days, adds reporting requirements, and orders an audit of the review process by the Comptroller General.¹² The same day, Representatives Amo (Democrat) and Shreve (Republican) introduced a bill to make BIS's annual conference statutory and to require reports to Congress on industry outreach. Their concern is that BIS dropped its annual conference and training seminars, which hurts businesses without large compliance teams.¹³ Both are bipartisan proposals, which suggests the concern is shared across party lines.

Paperwork deserves a look too. In a Federal Register notice, BIS estimated that completing its application form takes 29.4 minutes per response, across 72,744 respondents a year (June 2023).¹⁴ That cannot be compared directly with Japan's 10 hours, because the two figures measure different things. Still, it fits the picture that the US argument is about waiting more than about filling in forms.

Are security and speed really a trade-off?

Here is how the two countries line up.

Issue	Japan	United States
Where the burden is discussed	Electronic filing front door, consultation channels, clarity of the text	Review waiting time, poor visibility, reduced outreach to industry
Public numbers	Estimated application workload; application counts not published	Procedural clock, plus average processing times
Main industry requests	Status visibility, flexible consultation, clearer definitions	Meeting deadlines, transparency, staffing and expertise
Government and legislative moves	Wider blanket licenses, new exemptions, public comment	Bills in Congress; BIS emphasizes scrutiny

In hard cases, strict review and speed really do pull against each other. The CSIS report itself accepts that China-related reviews may be complex. I would not argue that a doubtful case should be waved through quickly.

What I find interesting is how much the requests overlap. The Japan Foreign Trade Council asks for a dashboard of application status. CSIS recommends automated status updates, explanations for delays, and regular publication of processing-time statistics. Showing applicants where they stand does not loosen the review itself. To my mind it is the first improvement that costs security nothing. Some of the reasoning behind individual decisions surely cannot be disclosed, so how far visibility can go is for each country's authorities to decide.

Let me clear up three common misunderstandings. The first is that the red-tape argument means abolishing controls. From what I read, it is mostly about running them better, and I found no request for abolition. The second is that a license always takes a long time. Japan's general blanket license has a stated target of about a week when all is in order, and BIS averaged 38 days in fiscal 2023. The third is that holding a blanket license ends the checking. Annual checklist submissions and notifications about military end uses continue after you obtain it.

Eight steps to lighten the burden, starting today

Now the practical part. Each step stays within the rules as they stand.

1. Put numbers on your burden. Record the past year's classification counts and hours, transaction screenings, and days from application to license. With no public statistics, your own figures are the only evidence for change. In the CSIS survey, 85% were already building delays into sales plans.
2. Standardize classification. Write a procedure and fix a record format that shows which specification value you checked against which legal clause. Reuse past results for the same model from a ledger. Treat a manufacturer's classification statement as input, then verify it yourself. Our five-step guide to streamlining classification walks through this.
3. Give transaction screening a fixed form. Put the end-use and end-user questions on a checklist and track update dates for repeat customers. The trick is to keep the substance of the check and standardize only how you record it.
4. Test whether a blanket license pays. Count your individual licenses per year, see whether your goods and destinations fall in range, and check whether you can meet the requirements. Catch-all controls are outside its scope.
5. Make application documents reusable. Build templates for technical documents, transaction summaries and the written pledge. The Council's request mentions cases where an electronic signature on the pledge was refused, so confirm the format with the office beforehand.
6. Use the right channel for each question. Procedural questions go to METI's licensing division, while classification support comes from paid services such as CISTEC's. They have different roles.
7. Plan for waiting. I could not confirm the standard period for individual licenses, but time lost to corrections is the easiest loss to avoid. Having a second person review before submission cuts down on replacements.
8. Send your comments in. Public comment periods and association petitions are the official routes for telling the rule-makers where it hurts. Like CISTEC's comments, the most useful ones name the exact clause and the exact word that is unclear.

Most burden reduction, laid out this way, comes down to unglamorous work: keeping classification and screening records tidy. TIMEWELL's export control AI agent, TRAFEED, helps organize candidate classifications and their supporting rationale. The final classification decision always rests with your own export control officer. For a personal conversation, you can reach us on the consultation page.

What I could not confirm, and where to go next

Let me say plainly what I could not establish. I could not read METI's site, so the standard processing period for individual licenses is unconfirmed. I found no METI response to the Council's requests. For the 2025 average processing time at BIS I found no primary figure I could stand behind, so I left it out. And I found no public statistic that breaks the burden down by company size in Japan.

One last thought of my own. The red-tape debate can easily turn into a story of villains, with regulators on one side and complaining companies on the other. After reading the sources, my impression was that both sides want the same thing. They want security protected, and they want to know how long the wait will be.

This week, why not make a one-page inventory of your own burden? Line up the number of classifications, screenings and applications, and the days each takes, and you will see where the red tape is likely to be. If you want to raise your voice on the rules themselves, the public comment period runs until November 18, 2026.

Footnotes

1. Bozeman, B. (1993). A Theory of Government "Red Tape". Journal of Public Administration Research and Theory, 3(3), 273-304 — checked against the publisher's abstract page. The abstract confirms the framing of red tape as pathological and the two types (dysfunctional from the start; useful at first and later transformed). The full text is paywalled and was not read — checked November 7, 2026 ↩

2. Security Trade Control Quick Guide for SMEs (states that METI does not confirm classification results; contact points) — JETRO — January 2024, checked November 6, 2026 ↩

3. Ex-post regulatory evaluation (new export controls implementing international agreements) — METI Trade and Economic Security Bureau, posted by the Ministry of Internal Affairs and Communications — March 2025, checked November 6, 2026 ↩

4. FY2025 Requests on Security Trade Control — Security Trade Control Committee, Japan Foreign Trade Council — July 7, 2025, checked November 6, 2026 ↩

5. Comments on the draft amendments to the Foreign Exchange Order and Export Trade Control Order (critical and emerging items) — CISTEC — March 1, 2025, checked November 6, 2026 ↩

6. Handling Guideline for Blanket Licenses (latest revision: Export Notice 2025 No. 27, promulgated November 14, 2025, effective February 14, 2026), general blanket license requirements, validity and processing — METI Trade and Economic Security Bureau — checked November 6, 2026 ↩

7. Outline of the Revision of the Export Trade Control Order and Related Rules (promulgated November 14, 2025, effective February 14, 2026) — METI Trade and Economic Security Bureau (copy hosted by CISTEC) — November 2025, checked November 6, 2026 ↩

8. Call for public comments on the draft cabinet order amending the Foreign Exchange Order and the Export Trade Control Order — METI Trade Control Division (e-Gov) — October 19, 2026; comment period through November 18, 2026; checked November 6, 2026 ↩

9. 15 CFR 750.4, Procedures for processing license applications — eCFR — current text, checked November 6, 2026 ↩

10. US government turmoil stalls thousands of export approvals — Reuters (reprinted by The Daily Star) — August 3, 2025, checked November 6, 2026 ↩

11. Delays and Uncertainty in the Export Licensing Process: Findings from a CSIS Survey of U.S. Technology Exporters — CSIS, Kate Koren and Philip Luck — April 21, 2026, checked November 6, 2026. The phrase "red tape" does not appear in the report ↩

12. House Foreign Affairs Ranking Member Meeks, Issa Introduce Bipartisan Bill — Office of Rep. Meeks — April 17, 2026, checked November 6, 2026. The release cites the CSIS survey as "58%"; the CSIS report itself says 56% ↩

13. Bipartisan Amo-Shreve Bill Restores Support for US Businesses Navigating Complex Export Rules — Office of Rep. Amo — April 17, 2026, checked November 6, 2026 ↩

14. Agency Information Collection Activities (Simple Network Application Process and Multipurpose Application Form, OMB 0694-0088) — BIS, Federal Register Vol. 88, No. 112 — June 12, 2023, checked November 6, 2026 ↩