Hello, this is Ryuta Hamamoto from TIMEWELL. Export-control teams keep asking: “Taiwan added new controls. What exactly was listed?” I organize the 18 new SHTC items for that audience.
On 17 November 2025, Taiwan’s International Trade Administration (ITA) opened a 60-day public comment. On 11 February 2026 the amendment took effect the same day.1 The add covered three categories and 18 items: advanced 3D printers, advanced semiconductor manufacturing/inspection tools, and quantum computers. Squarely next-generation dual-use technology.
Alongside China’s Japan-facing dual-use measures, the U.S. BIS September 2024 IFR, and the EU 2025/2003 update, Taiwan’s package is a key early-2026 export-control piece. Below is a neutral, primary-source-oriented map from terms to practice.
What you will learn
- The 18 SHTC items effective February 2026, in three categories
- Parallel comparison with U.S. EAR (ECCN) and EU dual-use list 2025/2003
- Three direct impacts on Japanese supply chains
- Five practical steps for export-control officers
- FAQ and takeaways
Three terms first
SHTC (Strategic High-Tech Commodities)
Taiwan’s strategic goods list. Japan’s Appended Table 1 counterpart. Administered by ITA (formerly BOFT). Legal bases include the Foreign Trade Act and the Regulations Governing Export and Import of Strategic High-Tech Commodities.
GAAFET (Gate-All-Around FET)
Transistor architecture for ~3nm-class and beyond advanced logic, with the gate fully surrounding the channel. Also central to the U.S. BIS September 2024 IFR thresholds that Taiwan’s package tracks.
EUV pellicles / EUV masks
Photomasks for EUV (13.5 nm) lithography and protective pellicle films. Pre-mask substrates are mask blanks. Taiwan foundry supply chains (including mask sites such as Photronics Taiwan and TOPPAN Photomask Taiwan) make licensing for Taiwan-origin EUV masks a practical control point.
Timeline: notice to effective date
| Date | Event |
|---|---|
| 6 Sep 2024 | U.S. BIS advanced-tech IFR (adds 2B001, 3B904, 4A906, etc.) |
| 15 Nov 2025 | EU Delegated Regulation 2025/2003 effective (dual-use list update) |
| 17 Nov 2025 | Taiwan ITA publishes SHTC draft; 60-day comment opens |
| Mid-Jan 2026 | Comment closes; final text reflects industry feedback |
| 11 Feb 2026 | Amendment effective immediately; short transition, even open orders need licenses |
Shipments without a license as of 11 February 2026 need applications.2 Force-majeure clauses and sailing dates may need re-cuts even for booked cargo. Transition was short. That is the operational point people under-estimate.
Taiwan is not a formal WA member, but continues voluntary alignment. This package is an alignment-style update reflecting WA/NSG 2024 plenary outcomes and EU 2025/2003.
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The 18 items in three categories
Category A: Advanced 3D printing equipment
Metal powder bed fusion (PBF) and directed energy deposition (DED) systems using high-energy beams (laser, e-beam), plus related high-performance powders and components. WA Category 2 heritage. Maps roughly to EAR ECCN 2B001 (including hybrid CNC+AM) and EU 1B001 / 1C001 / 1C513.
Illustrative control parameters (WA 2024 basis):
- Positioning / repeatability below set thresholds
- Refractory metals (titanium, nickel superalloys, rhenium, tungsten)
- Multi-beam build rate / resolution above thresholds
- Material-side items such as inoculators for microstructure control
Regime literature discusses dual-use end-use categories such as rocket combustion chambers, turbine blades, UAV structures, and hypersonic thermal components. Those are end-use categories, not judgments about specific commercial customers.
Category B: Advanced semiconductor manufacturing, inspection, and related tools
Largest category:
| Sub-item | Indicative ECCN / EU entry |
|---|---|
| CMOS ICs (logic/memory/quantum-sensor uses above thresholds) | U.S. 3A001; EU 3A001 |
| Cryogenic cooling systems (quantum compute/sensing) | U.S. ~3B904; EU 3B001.g |
| SEM (low-kV high-resolution / pattern inspection) | U.S. 3B002; EU 3B002 |
| Cryogenic wafer probers / test tools | U.S. ~3B904; EU 3B001 |
| EUV photomasks (13.5 nm) and mask blanks | U.S. 3B001.f; EU 3B001 |
| EUV mask inspection / repair tools | U.S. ~3B002 / 3B901 |
| Parametric signal amplifiers (quantum readout) | U.S. ~3A001.b; EU 3A001 |
| Advanced packaging tools (e.g., hybrid bonding) | U.S. 3B001; EU 3B001 |
EUV masks and blanks deserve special attention. Supply routes into advanced foundries often pass Taiwan mask sites. Making Taiwan-origin EUV mask exports license-required adds a new control node in the chain. If I had to pick one subcategory for Japanese materials desks to re-map first, it would be this one.
Category C: Quantum computers and components
Aligned with WA 2024 and the BIS September 2024 IFR:
- Quantum computers (qubit count, gate error, coherence thresholds)
- Superconducting qubit circuits (Josephson junctions, resonators)
- Ion-trap vacuum and laser optics
- Dedicated control electronics (FPGA / AWG / digitizer)
- Related software and technology
The U.S. uses entries such as 3A901, 3D901, 3E901, 4A906, 4D906, 4E906. Taiwan’s package adopts a similar architecture inside its own system.
International comparison
| Point | Taiwan SHTC +18 | U.S. EAR (BIS Sep 2024 IFR) | EU dual-use 2025 update |
|---|---|---|---|
| Effective | 11 Feb 2026 | 6 Sep 2024 | 15 Nov 2025 |
| 3D printers | Refractory metal PBF/DED + powders | ECCN 2B001 (incl. hybrid) | 1B001, 1C001, 1C513 |
| Quantum | Full stack incl. cryogenics/readout | 3A901, 4A906, 3B904, etc. | 3A001, 3B001 (+ 500 series) |
| Semiconductor tools | CMOS, SEM, EUV masks, cryo probers | 3B001, 3B002, 3B904 (GAAFET) | 3B001, 3B002 |
| Multilateral base | WA, NSG, MTCR, AG, CWC | WA + autonomous add-ons | WA + autonomous 500 series |
| Extraterritoriality | Generally none (Taiwan persons/products) | Strong (incl. FDPR) | EU export/licensing duties |
| Licensing authority | ITA | BIS | Member-state authorities |
EU “500 series” means autonomous items beyond multilateral consensus. Taiwan does not formally join that numbering, but content-wise this is an alignment package.
Absence of U.S.-style FDPR is a practical difference: third-country rework is not broadly pulled in the same way. Taiwan-routed trade is, however, more trackable than before.
Penalties
Under Foreign Trade Act Article 27 and related rules:
- Export suspension / license revocation
- 1–3 year export bans
- Fines up to about NT$3 million (~¥14 million, FX-dependent)
- Imprisonment up to 7 years
Japanese FEFTA or U.S. EAR exposure can also arise on linked facts. Keep records for at least 5–7 years across the chain.
Three direct impacts on Japanese companies
Impact 1: Taiwan-origin EUV masks / blanks
Japanese materials makers (Shin-Etsu, JSR, TOK, and others) may supply blanks in Taiwan that are finished as EUV masks and shipped abroad. Previously low-friction routes now insert licensing. Expect ~10–30 business days standard; complex cases 60+ days. Re-commit customer LTAs before sales promises outrun the clock.
Impact 2: Japanese equipment makers’ Taiwan entities shipping offshore
Tokyo Electron, SCREEN, Advantest, and peers with Taiwan local entities shipping SEM / inspection / cryo probers offshore become SHTC license subjects. “Japan FEFTA alone is enough” ends here. HQ–Taiwan compliance linkage matters more.
Impact 3: Metal AM powders reexported via Taiwan
Daido Steel, Sanyo Special Steel, and others supplying refractory powders to Taiwanese processors face Taiwan-origin export licenses when those powders reexport. Destinations such as China, Russia, Belarus, North Korea, and Iran are often treated as high denial-risk under regime practice.
Additional chain points:
- Re-price lead times for Taiwan-routed third-country trade
- Pre-collect end-user certificates / IIC / DVC
- Revisit high-risk destinations under Taiwan rules
- Assume triple-check with Japanese FEFTA and U.S. EAR catch-all/list controls
Opportunities also exist: onshore Japan substitutes for powders/blanks, higher demand for compliance tools, and bulk licenses for trusted destinations including Japan.
Five practical steps
Step 1: Cross-check products against the 18 items
Quantify parameters per SKU (qubits, laser power, beam accuracy, CMOS node, temperature). Combine ITA electronic self-assessment, specialist counsel, and AI agents.
Step 2: Inventory contract impact at the effective date
List open orders without licenses as of 11 February 2026. Revisit force majeure and sail dates; notify customers; prioritize filings. Treat transition as nearly none.
Step 3: Strengthen HQ–Taiwan entity information links
Align screening standards and yes/no decision rules across HQ, Taiwan, and third-country subsidiaries with shared procedures and training.
Step 4: Build end-user certificate and license workflows
Expect application packs: form, invoice/packing list, End-User Statement, IIC or written assurance, specs, contract. Plan 1–2 weeks for document collection + 10–30 business days review. Consider bulk licenses for trusted destinations early.
Step 5: Consider automated multi-regime screening
Global manufacturers with tens of thousands of annual transactions cannot hand-update masters for U.S. EAR + EU 2025/2003 + China MOFCOM Announcement 91 + Taiwan SHTC at once. Automation is becoming baseline in H1 2026.
FAQ
Q1. Are Japanese companies’ Taiwan entities covered?
Yes. All Taiwan-origin exports are in scope, including returns/repairs to Japan parents when SHTC applies.
Q2. How do we decide if we match the 18 items?
Combine (1) ITA self-assessment tools, (2) specialist counsel, (3) AI-assisted classification, parameter by parameter.
Q3. Are all China-group deals denied?
Depends on end use and end user. CMOS design IP, quantum computers, and EUV-related items face high practical denial risk; general dual-use SEM/ICs may still clear case-by-case.
Q4. Did public comment change the package?
Core item set and thresholds largely held; some thresholds and descriptions were clarified after industry feedback.
Q5. Biggest difference vs U.S. EAR?
Extraterritorial reach. EAR/FDPR can cover foreign-made items; Taiwan SHTC principally covers Taiwan-origin exports. Still, Taiwan routing is more visible than before.
Latest developments as of July 2026
After publication, economic-security frameworks kept moving. The 16th Japan–India summit on 2 July 2026 produced cooperation and ~¥2 trillion investment language across semiconductors, rare earths, clean energy, ICT (subsea cables), and pharmaceuticals (Prime Minister’s Office of Japan, July 2026). Advanced semiconductors and materials newly controlled under SHTC sit on the same map as supply-chain diversification. See Japan–India Summit and economic security.
Key takeaways
On 11 February 2026 Taiwan SHTC added three categories / 18 items: advanced 3D printers; advanced semiconductor tools (CMOS / EUV masks / SEM / cryo probers / parametric amplifiers); quantum computers. The package aligns with WA, NSG, MTCR, AG, CWC, plus the BIS Sep-2024 IFR and EU 2025/2003. Penalties include export bans, up to about NT$3M, and up to 7 years’ imprisonment.
Japanese impact is concrete: licensing for Taiwan-origin EUV masks, tools, and special metal powders, with multi-week to two-month lead times. Simultaneous tracking of U.S., EU, China, and Taiwan regimes is now normal desk work, not a special project.
Export control is no longer “watch only your counterparty country’s list.” Taiwan’s package is one national implementation of multilateral consensus. Japanese companies need to read regimes as a connected line, not isolated dots.
Related articles
- China dual-use catalog 2026
- U.S.–China–EU three-regime simultaneous response
- China–Japan export controls complete guide
- Japan–U.S. semiconductor export controls
- Japan export control spring 2026 updates
When headcount alone cannot keep up
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If you want to check Taiwan SHTC +18 exposure or unify U.S./China/EU/Taiwan screening, book a TRAFEED consultation or see the TRAFEED page.
References
- ITA English Export Control Laws: https://www.trade.gov.tw/english/Pages/List.aspx?nodeID=298
- MOEA law system: SHTC export/import regulations: https://law.moea.gov.tw/LawContent.aspx?id=GL000885
- CNA 17 Nov 2025; CNA 11 Feb 2026; Taipei Times 18 Nov 2025; Taiwan News; TechNews; JETRO Taiwan trade system notes; U.S. BIS Sep 2024 IFR; EU Delegated Regulation 2025/2003
Footnotes
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CNA, “MOEA announces strategic high-tech commodities list amendment” (17 Nov 2025) https://www.cna.com.tw/news/afe/202511170111.aspx ↩
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TechNews, “High-Tech Products: Taiwan Export Controls” (12 Feb 2026) https://technews.tw/2026/02/12/high-tech-products-taiwan-export-controls ↩
