This is Ryuta Hamamoto from TIMEWELL.
"Customs clearance was halted because a non-controlled certificate for our counterparty was delayed." "A sudden regulatory change forced us to reconsider our suppliers." "Semiconductor shortages are causing major delivery delays." — For companies operating globally, supply chain management has become the single most critical business issue.
As of 2026, the intensification of U.S.-China decoupling, rising geopolitical risks, and the full-scale operation of Japan's Economic Security Promotion Act mean that every company involved in import/export is facing supply chain risk.
This article explains the most problematic issues in supply chain management — non-controlled certificate-related troubles, sudden regulatory changes, and delivery delays from contingency events — and introduces the low-cost, high-quality solutions provided by the AI-native tool TRAFEED (formerly ZEROCK ExCHECK).
What You Will Learn from This Article
- The three most common supply chain troubles and their causes
- The serious impact of non-controlled certificate delays and how to address them
- The impact of the October 2025 regulatory amendments on companies
- How to build supply chain resilience in preparation for geopolitical risk and contingency events
- AI-native alternatives to expensive traditional solutions
1. The Current State of Supply Chain Management and Its Challenges
Globalization and Increasingly Complex Risks
Supply chains were once relatively straightforward. Roles were clear: "design in the U.S., foundry in Taiwan, manufacturing equipment from Japan/U.S./Netherlands, components from Japan."
But from 2022 onward, a rapid shift in the environment changed everything.
| Change factor | Impact on companies |
|---|---|
| U.S.-China decoupling | Reviewing procurement sources, building dual supply chains |
| Semiconductor regulation tightening | New management obligations via HS codes, responding to re-export controls |
| Economic Security Promotion Act | Building management frameworks for specified critical goods, due diligence obligations |
| Geopolitical risk | Taiwan contingency risk, logistics delays from the Red Sea crisis |
According to an EY Japan report, some Japanese companies are already reviewing their semiconductor procurement strategies with an eye on Taiwan contingency risk, and restructuring supply chains has emerged as a pressing management challenge.
Compliance Demands Reaching SMEs Too
"We're not a large corporation, so it doesn't apply to us" — is that your thinking?
In fact, with the implementation of Germany's Supply Chain Due Diligence Act (LkSG), the era has arrived where Japanese SMEs with business relationships with German companies are also required to address supply chain due diligence.
According to a PwC report, covered companies can require human rights and environmental due diligence from companies with which they have direct or indirect business relationships, meaning that SMEs upstream in supply chains are also being affected.
How to solve export compliance challenges?
Learn about TRAFEED (formerly ZEROCK ExCHECK) features and implementation benefits in our materials.
2. Non-Controlled Certificate Troubles and How to Address Them
What Is a Non-Controlled Certificate?
A non-controlled certificate is a document certifying that a product or technology you intend to export does not fall under the regulated items in Appended Table 1 of the Export Trade Control Order.
According to the JETRO guide, when customs requests the basis for a non-controlled determination, it is necessary to present a classification record or non-controlled certificate along with the specification sheet.
Troubles That Often Arise with Non-Controlled Certificates
Trouble 1: Customs Holds Due to Issuance Delays
Common scenarios:
- Delays in obtaining non-controlled certificates from suppliers cause export schedule delays
- Specialized knowledge is required to confirm product specifications, and in-house classification is not possible
- Confirming compliance with each country's regulations for exports to multiple countries cannot keep pace
Impact:
- Penalties from delivery delays
- Decline in customer trust
- Increased warehouse storage costs
Trouble 2: Insufficient Classification Basis
Following the October 2025 regulatory amendments, more detailed explanation of the basis and content required for non-controlled determinations will be required.
According to commentary from Boueki.com, companies that have been preparing non-controlled certificates based solely on "self-determination" may face additional questions and confirmation requests at customs.
Trouble 3: Expansion of Catch-All Control Coverage
The October 2025 regulatory amendments expanded catch-all controls to cover not only weapons of mass destruction-related items but also conventional weapons-related items. With specific items now designated by HS code, the number of cases requiring non-controlled certificates has increased substantially.
Streamlining Non-Controlled Certificate Operations with AI
TRAFEED (formerly ZEROCK ExCHECK) can streamline non-controlled certificate operations through the following functions:
Automatic report generation with evidence
- Explicitly shows reasoning and source URLs
- Can be presented directly at customs
Batch processing capability
- Handles 100–200 cases at once
- Completes large-scale counterparty checks in a short time
Automatic regulatory updates
- Reflects latest regulations within two weeks
- Reduces risk of missed changes
3. Responding to Sudden Regulatory Changes
Major Regulatory Changes in 2025–2026
| Effective date | Regulatory content | Impact on companies |
|---|---|---|
| October 2025 | Catch-all control amendments | HS code-based management obligations, expansion of covered items |
| February 2026 | Expanded coverage for item-specific comparison tables | Increased need for ongoing classification management |
| November 2026 | U.S. EAR Affiliate Rule | Need to make visible capital relationships of subsidiaries and affiliated companies |
The Impact of the Affiliate Rule
Of particular importance is the U.S. EAR Affiliate Rule, which comes into full effect in November 2026.
This new rule makes subsidiaries 50% or more owned by Entity List-designated companies also subject to regulation, and Japanese companies will also be affected when re-exporting products containing U.S.-origin technology.
Risks if violated:
- Fines of up to $1 million
- Export prohibition measures
- Suspension of transactions
TRAFEED (formerly ZEROCK ExCHECK) plans to provide a capital relationship chain analysis function timed to the full implementation in November 2026.
Building a Framework That Can Keep Pace with Regulatory Changes
Under conventional manual management, responding to regulatory changes could take weeks to months. Using AI can dramatically shorten this response time.
TRAFEED (formerly ZEROCK ExCHECK) response flow:
- Detection of regulatory changes (automated monitoring)
- Immediate notification to customers
- System update within two weeks
- Automatic identification of affected counterparties
4. Measures for Geopolitical Risk and Delivery Delays
Supply Chain Chokepoints in 2026
According to Deloitte's forecast, the following areas are expected to become new supply chain chokepoints in 2026:
- Semiconductor manufacturing technology (etching, GAA technology)
- EDA (electronic design automation) tools
- Chiplets (an estimated $100–110 billion market)
Delivery Delays That Are Already Occurring
According to Z2Data's analysis, Nexperia of the Netherlands halting wafer shipments to China has resulted in price increases for discrete components and lead time extensions of 6–8 weeks.
Some automakers are reverting to COVID-era planning methods and building up component inventories.
Building Supply Chain Resilience in Preparation for Contingency Events
A three-phase approach:
| Phase | Measure | Application of TRAFEED (formerly ZEROCK ExCHECK) |
|---|---|---|
| Short-term | Build up inventories of critical components | Visualize concern levels of counterparties |
| Medium-term | Diversify procurement sources | Screen alternative suppliers |
| Long-term | Redesign supply chain | Regional risk mapping |
What TRAFEED (formerly ZEROCK ExCHECK) makes possible:
- Visualizing counterparties' country of location, industry, and concern level
- Pre-emptive understanding of vulnerabilities based on geopolitical risk
- Use as material for considering alternative procurement sources
5. Differences from Traditional Solutions: Why AI-Native Is Superior
Characteristics of Traditional Supply Chain Management Tools
Traditional supply chain management has been dominated by comprehensive solutions from major ERP vendors. These tools have the following characteristics:
Characteristics of traditional solutions:
- Automatic assignment of export classification numbers
- Management of preferential trade agreements
- Full integration with ERP
Points to Consider When Choosing Traditional Solutions
When introducing traditional solutions, the following points need to be considered:
| Consideration | Traditional solutions | TRAFEED (formerly ZEROCK ExCHECK) |
|---|---|---|
| Implementation cost | Tends to be high | Low cost (contact for pricing) |
| Implementation period | Months to long-term | As early as the next business day |
| Customizability | May have constraints | Flexible response |
| Optimization for Japanese regulations | Global general-purpose | Specialized for FEFTA and economic security |
| AI utilization | Traditional-type centered | AI-native design |
For mid-sized companies in particular, implementation and operating costs can be a significant burden.
Advantages of TRAFEED (formerly ZEROCK ExCHECK)
1. AI-native design
- Multi-LLM cross-checking
- Continuous accuracy improvement
- Evidence-based determination
2. Outstanding cost performance
- A fraction of the price of major ERP solutions
- Special pricing under the Design Partner Plan available (contact for details)
- Clear pricing from zero initial cost, with additional fees of 5,000 yen per 500 cases
3. Optimized for Japanese companies
- Fully compliant with FEFTA and catch-all controls
- Conforms to METI designated formats
- Explanation of basis in Japanese
4. Fast implementation
- Available for use as early as the next business day
- Accessible immediately from a web browser
- No complex system integration required
6. TRAFEED (formerly ZEROCK ExCHECK) as a Choice for Overseas Import/Export Operations
Recommended for These Companies
- Manufacturers: Import/export management of components and finished goods, regular checks on suppliers
- Trading companies: Batch screening of large numbers of counterparties, M&A due diligence
- Research institutions: Background checks on joint research partners, risk assessment of technology transfers
- IT companies: Export control of software and technology, information sharing with overseas offices
What TRAFEED (formerly ZEROCK ExCHECK) Can Deliver
Functions currently available:
- Concern level scoring (S/A/B/C)
- Report output with evidence
- Batch processing (100–200 cases)
- Multi-language support (English, Chinese, etc.)
- METI format compliance
Functions planned for future expansion:
- Supply chain risk investigation
- Delivery delay risk visualization
- Procurement diversification proposals based on geopolitical risk
- Capital relationship chain analysis (planned for November 2026)
- Item-specific comparison table support (planned for February 2026)
Summary: Use TRAFEED (formerly ZEROCK ExCHECK) for Import/Export Operations
Supply chain management is no longer a challenge only for large corporations. Every company doing business globally faces the following risks:
- Customs holds due to non-controlled certificate delays
- Lag in responding to sudden regulatory changes
- Uncertainty in procurement and delivery from geopolitical risk
TRAFEED (formerly ZEROCK ExCHECK) addresses these challenges with:
- Low cost implementation (special pricing available under the Design Partner Plan)
- High-quality AI determination (accuracy of 95% or higher)
- Fast response (available as early as the next business day)
Please feel free to get in touch.
For import from overseas or export abroad, leave it to TRAFEED (formerly ZEROCK ExCHECK).
References
- EY Japan, "The Future of Semiconductor Procurement: Economic Security and Redefining the Supply Chain"
- PwC Japan, "Q&A on Germany's Supply Chain Due Diligence Act"
- JETRO, "How to Confirm Whether Export Items Fall Under Security Trade Control Regulations"
- Boueki.com, "2025 Latest: Strengthening of the Export Trade Control Order and Actions Companies Should Take"
- Z2Data, "22 Critical Supply Chain Risks to Watch for in 2026"
- Deloitte, "New technologies and familiar challenges could make semiconductor supply chains more fragile"
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