What Is a "White Country"? Japan's Country Groups A–D vs. EAR Country Group D

Hello, this is Ryuta Hamamoto from TIMEWELL. If you first heard the term "white country" (howaito-koku) during the 2019 coverage of the Japan–South Korea export control dispute, you are not alone. Headlines about "removal from the white country list" ran for days. Yet the phrase appears nowhere in Japan's export control legislation. The legal reference is to "the regions listed in Appended Table 3" of the Export Trade Control Order, and since August 2019 the Ministry of Economy, Trade and Industry (METI) has called that tier "Group A"¹.

So three labels point to the same list: the nickname "white country," the legal reference "Appended Table 3," and the working name "Group A." For this update I pulled the current text from e-Gov, Japan's official legal database, as of October 4, 2026, along with the versions in force before and after the 2019 and 2023 amendments, and compared the country names one by one²³. If you arrived here searching for "Country Group D," one warning up front: the U.S. Export Administration Regulations (EAR) use a different table with the same letters. I cover that in its own section below.

The 30-second version. "White country" is the informal name for the countries in Appended Table 3 of Japan's Export Trade Control Order. METI has called them Group A since August 2019, and there are 27 of them as of October 2026. Group D covers the destinations in Appended Table 3-2 (ten UN arms-embargoed destinations) and Appended Table 4 (Iran, Iraq, North Korea), 11 in total once you remove the overlap. Groups B and C have no list in the legal text. The group decides how catch-all controls apply and whether the general bulk license is available; items on the control list need a license for every destination. Since October 9, 2025, even Group A shipments need a license if METI sends an inform notice. The EAR's Country Group D is a separate table with 47 destinations.

The "White Country" Is Appended Table 3 of the Export Trade Control Order

Start with the legal structure. The parent statute of Japan's export controls is the Foreign Exchange and Foreign Trade Act, usually shortened to FEFTA⁴. Beneath it sits the Export Trade Control Order, a cabinet order that practitioners call "the Export Order"². The concrete rules, meaning what is controlled and which destinations require a license, live in this order and its appended tables. For an overview of the order built around Appended Tables 1 and 2, see what Japan's Export Trade Control Order is and how its tables fit together.

Appended Table 3 is the list behind Group A. METI's guidance describes Group A as countries that participate in the international export control regimes and implement export controls rigorously⁵. Those regimes are the multilateral frameworks (the Wassenaar Arrangement, the Nuclear Suppliers Group, the Australia Group, and the Missile Technology Control Regime) that countries join to prevent the proliferation of weapons of mass destruction and conventional weapons. Countries on the list are treated as partners that control exports to a standard comparable to Japan's, and the regulatory load for shipments to them is one notch lighter. Practitioners have long called them "white countries."

What does being a white country actually mean? CISTEC (the Center for Information on Security Trade Control, a Japanese organization that publishes practical export control guidance⁶) put it plainly in 2019: Japan's white countries are countries exempted from the catch-all controls covering weapons of mass destruction and conventional weapons⁷. I will get to catch-all controls shortly, but that sentence is the core idea. Group A status does not decide whether you may export at all. It decides how the regulatory net is cast.

A note on the renaming. On August 2, 2019, alongside a cabinet decision amending the Export Order, METI revised its country-category labels. Its announcement explains that the "white country" label had covered Appended Table 3 and the destinations classed as "i-region (1)" in METI's operational circular on the Export Order. Those became "Group A," and METI stated in writing that legal treatment follows the country categories in the circular and does not change¹. The name changed; the system did not.

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Japan's Country Groups A, B, C, and D

With the 2019 relabeling, METI sorted countries and regions into four groups. The definitions come from METI's announcement¹⁸. Here they are with the legal basis and the destinations covered as of October 2026.

Group	Definition	Basis	Destinations as of October 2026
Group A	Countries listed in Appended Table 3 of the Export Order (the former white countries)	Appended Table 3	27 countries, including the US, UK, Germany, France, and South Korea
Group B	Countries that participate in the international export control regimes and meet certain requirements, excluding Group A	Country categories in METI's operational circular	No list in the legal text; METI has not published what "certain requirements" means
Group C	Countries and regions in none of A, B, or D	The remainder	Everything not in A, B, or D
Group D	Countries and regions listed in Appended Table 3-2 or Appended Table 4	Appended Tables 3-2 and 4	11 destinations after removing overlap

Group A is the 27 countries in the current Appended Table 3: Argentina, Australia, Austria, Belgium, Bulgaria, Canada, the Czech Republic, Denmark, Finland, France, Germany, Greece, Hungary, Ireland, Italy, the Republic of Korea, Luxembourg, the Netherlands, New Zealand, Norway, Poland, Portugal, Spain, Sweden, Switzerland, the United Kingdom, and the United States². Europe dominates, and South Korea is the only Asian member. When I compared the versions in e-Gov's amendment history, the list has not changed by a single name between the version effective July 21, 2023, when South Korea returned, and the current version effective June 5, 2026³. You will still find web pages saying Group A has 26 countries. That was true only from August 28, 2019 to July 20, 2023.

Keeping the group check with your classification records. The destination group you confirmed is easiest to defend later when it sits in the same file as the classification and catch-all records. We publish a free, Japanese-language template pack: classification and non-applicability certificate forms with a fill-in guide (Word), plus Excel sheets including a catch-all verification sheet and a classification log. Download the classification template pack (company name and work email required).

What Group D means

"Group D" (people in Japan often say "D-koku," a D country) covers the destinations listed in Appended Table 3-2 or Appended Table 4. Appended Table 3-2 is the list of UN arms-embargoed destinations: Afghanistan, the Central African Republic, the Democratic Republic of the Congo, Iraq, Lebanon, Libya, North Korea, Somalia, South Sudan, and Sudan. Appended Table 4 lists Iran, Iraq, and North Korea². Iraq and North Korea appear on both, so Group D comes to 11 destinations. The contents of both tables are the same in the April 2019 version and the current one³.

The two tables do different jobs. Appended Table 3-2 widens what you must check under catch-all controls. As the table in the next section shows, for ordinary destinations some items only trigger a conventional-weapons license if METI sends an inform notice; for Table 3-2 destinations, the exporter's own end-use and end-user findings also trigger it (Article 4, paragraph 1, item 4)². Appended Table 4 matters for the low-value exception. Goods under rows 5 to 13 and 15 of Appended Table 1 worth 1 million yen or less can normally ship without a license, but not to the three Table 4 countries (item 5 of the same paragraph)². The details are in my piece on Japan's low-value and free-of-charge exceptions.

One clarification that matters. Group D is not a list of countries you are barred from trading with, and it is not a verdict on the businesses based there. It sets how widely license requirements reach and which exceptions you can use. Separate measures, based on export approvals under Article 2 of the Export Order, apply to destinations such as North Korea, Russia, and Belarus². Russia and Belarus are not in Group D at all. Treat "is it Group D?" and "is it under an approval measure?" as two separate checks.

Groups B and C

Group B is defined as countries that participate in the international export control regimes and meet certain requirements, excluding Group A¹. Think of it as the tier between A and C. When South Korea was removed from Appended Table 3 in 2019, METI placed it in Group B¹. But METI's announcement gives no list of names and does not spell out the "certain requirements." It only says legal treatment follows the country categories in its operational circular¹. Some private explainers publish lists of Group B countries. Since METI itself has not, I treat those lists as information that can change over time; South Korea sat in Group B for only four years. I am not going to assert Group B names here. If you need them for actual compliance work, go to the current text of METI's circular⁹.

Group C is whatever falls in none of A, B, or D, so there is no list for it either. People ask about this a lot, so let me be concrete: Taiwan, China, Thailand, Vietnam, Singapore, India, and Mexico, all major trading partners for Japan, appear neither in Appended Table 3 nor in Tables 3-2 or 4². They are in B or C. Under catch-all controls the two are treated the same, and this is the layer practitioners call "ordinary destinations."

What the Group Changes: Catch-All Controls and Bulk Licenses

Now the practical question. The group matters in two places: catch-all controls and bulk licenses.

Catch-all controls: Group A is carved out of Item 16

Japan's export controls are easiest to read as two tracks. The first is list control. Goods and technologies on the control list need a license from the Minister of Economy, Trade and Industry whatever the destination. My guide to Appended Table 1 explains how to read that list. The second is catch-all control. Even items not on the list need a license when they may be used to develop weapons of mass destruction or conventional weapons. It looks at end use and end user, and catches what slips through the list.

The legal basis for catch-all controls is Item 16 of Appended Table 1. Its destination column reads "all regions (excluding the regions listed in Appended Table 3)"². That parenthetical is the whole point. Group A sits outside Item 16's territorial scope from the start, which is what CISTEC's "exempted from catch-all controls" refers to.

The October 9, 2025 amendments added an exception to that exemption. A new paragraph 3 in Article 1 requires anyone exporting Item 16 goods to a Group A destination to obtain a license under Article 48, paragraph 2 of FEFTA. A new Article 4, paragraph 2, added at the same time, says that license is not needed unless the exporter has received an inform notice²³. METI explains that the Group A inform requirement applies only where there is a risk of diversion to countries of concern¹⁰. For Group A, the exporter's own end-use and end-user findings do not trigger a catch-all license. Once a notice arrives, though, the shipment cannot go without one.

The same amendments split Item 16 into 16(1), a list of specific goods such as machine tools and integrated circuits, and 16(2), everything else in the covered tariff chapters²¹¹. Laid out from Article 4 of the Export Order, the license triggers look like this².

Destination	Item 16(1): specific goods	Item 16(2): all other goods
Group A (27 countries in Appended Table 3)	No end-use or end-user trigger. License needed only if METI sends an inform notice over diversion risk	Same
UN arms-embargoed destinations (10 in Appended Table 3-2)	WMD and conventional weapons: exporter's end-use and end-user findings, plus inform notices	Same
Ordinary destinations (all others)	WMD and conventional weapons: exporter's end-use and end-user findings, plus inform notices	WMD: end-use and end-user findings plus inform notices. Conventional weapons: inform notices only

The "end-use and end-user findings" trigger (Japanese practice calls it the objective requirement) applies when the exporter's own checks show the goods may be used to develop weapons. The inform trigger applies when METI notifies the exporter that a license application is required. The weight of what you must check steps up with the destination's group. That is the first practical meaning of the classification. For the full history of the change, see my summary of the catch-all amendments; for how list and catch-all controls fit together, see list controls versus catch-all controls.

Bulk licenses: the convenient one is Group A only

The second consequence concerns bulk licenses. Japan offers individual licenses, applied for transaction by transaction, and bulk licenses, which cover a defined range of items and destinations in advance. If you ship the same product to the same country every week, filing one application per shipment is not realistic, so bulk licenses keep day-to-day operations moving. I compare the two in my piece on individual versus bulk export licenses.

There are five types: the general bulk license, the special general bulk license, the specific bulk license, the special bulk license for returned goods, and the specific bulk license for subsidiaries⁵¹². The first two are tied to the groups. The general bulk license covers items of relatively low sensitivity, but only for Appended Table 3 destinations, which is why practitioners call it the "white bulk license." The special general bulk license extends to destination and item combinations beyond Appended Table 3, and in exchange it is granted only to exporters with a more rigorous internal compliance program¹². It is a staircase: the easy license for Group A, and a license backed by a demonstrated compliance program for everywhere else.

One more point that people miss. Bulk licenses exist for list-controlled items and cannot be used for catch-all controls¹². If Item 16 goods bound for a non-Group A destination need a license, you apply individually. So the value of Group A status is two-fold: lighter catch-all checks and access to the general bulk license. Get the destination's group wrong and you either skip a check you needed or burn time on paperwork you did not need.

A brief word about our own work. Checking destination groups, export classification, and counterparty screening are each simple on their own, but the load grows fast with volume. TRAFEED is our AI first-pass analyst for that work. It drafts Japan export classifications against Appended Table 1 and the Foreign Exchange Order table, screens counterparties against METI's End User List and the US Consolidated Screening List, and keeps the evidence on file. The classification logic is covered by Japan Patent No. 7862062. Your export control officer makes the final call; the AI's job is to get the evidence in front of them faster.

What South Korea's Removal and Return Teaches Us

The case that drew the most attention in recent years is South Korea between 2019 and 2023. Following the dates shows how the system moves.

On July 1, 2019, METI announced a review of its export control practice toward South Korea, and from July 4 it moved three items, fluorinated polyimide, photoresists, and hydrogen fluoride, to individual licensing¹³. On August 2, the Cabinet approved an amendment to the Export Order. Promulgated on August 7 as Cabinet Order No. 71 of 2019 and effective August 28, it deleted the Republic of Korea from Appended Table 3¹³. Exports to South Korea lost access to the general bulk license and came under catch-all controls. In e-Gov's version history, Appended Table 3 drops from 27 to 26 countries on that date³.

News reports and social media at the time claimed that "every export to South Korea will now need an individual license." That was wrong. METI's announcement stated that the special general bulk license remained available as before¹, and CISTEC explained that the only bulk license lost on removal was the general bulk license, so the idea that everything becomes an individual license was simply mistaken⁷. Leaving Group A does not mean a blanket tightening. The most lenient path closes and the catch-all net comes down. Honestly, whether an explainer gets this right is a good test of whether to trust the rest of it.

On March 23, 2023, a circular amendment restored the special general bulk license for the three items, and after policy dialogue between the two governments¹³, a further amendment, approved by the Cabinet on June 27, 2023, promulgated on June 30, and effective July 21 as Cabinet Order No. 232 of 2023, returned South Korea to Appended Table 3¹⁴³. The general bulk license became available again, and South Korea moved back outside the scope of catch-all controls. Removal to reinstatement took about four years. CISTEC supported the draft order and asked for continued policy dialogue between the two sides to prevent a repeat of the confusion¹⁵.

I take two lessons from this. First, Group A is not a fixed list. It moves with cabinet order amendments, so do not stop at a "Group A list" in an internal slide deck; check the current text on e-Gov² and METI's Security Export Control pages⁹. Second, Appended Table 3 was not built for South Korea. It is a general country classification with a long operating history, and 2019 was one deletion from it. With the whole framework in your head, the next time a country's status moves you can estimate the operational impact without being pushed around by headlines.

Japan's Group D Is Not the EAR's Country Group D

If you searched for "Country Group D," you were probably looking for the U.S. Export Administration Regulations. The letters overlap with Japan's groups, and that is where the confusion starts. The short answer: these are different tables under different countries' laws, and their contents barely resemble each other.

The EAR's country groups are in Supplement No. 1 to 15 CFR Part 740¹⁶. Country Group A has columns A:1 (Wassenaar Arrangement participating states), A:2 (Missile Technology Control Regime), A:3 (Australia Group), A:4 (Nuclear Suppliers Group), A:5, and A:6. Country Group D is organized by reason for control: D:1 (national security), D:2 (nuclear), D:3 (chemical and biological), D:4 (missile technology), and D:5 (U.S. arms embargoed countries). Country Group E has E:1 (terrorist supporting countries) and E:2 (unilateral embargo), and Country Group C is reserved. In the eCFR current on October 1, 2026, the Country Group D table lists 47 countries and regions, against 11 in Japan's Group D¹⁶. A destination can sit in both A and D; Taiwan, for example, is in A:6 and D:3¹⁶. A D-column entry is a regulatory category that sorts license treatment by reason for control. It is not a judgment on that country or on the companies based there. Japan is in every column from A:1 to A:5 and in none of the D columns.

	Japan's Groups A–D	EAR Country Groups A–E
Legal basis	Export Order Appended Tables 3, 3-2, and 4, plus METI's operational circular	15 CFR Part 740, Supplement No. 1
Structure	Each destination falls into one group	Columns by reason for control; one destination can be in several
Size of Group D	11 destinations	47 countries and regions (eCFR current on October 1, 2026)
Where it bites	Catch-all controls, the general bulk license, the low-value exception	Eligibility for License Exceptions, among other things

There is a second structural difference. Japan's list controls apply to every destination. Under the EAR, whether a license is needed depends on the reason for control and the destination, which you read off the Commerce Country Chart¹². The country groups then decide, among other things, which License Exceptions you can use. They move too. A BIS rule effective July 10, 2026 removed the United Arab Emirates from D:3 and D:4 and added it to A:5, making more License Exceptions available, including STA (Strategic Trade Authorization) for the UAE government and approved commercial entities¹⁷. I wrote about that change in the U.S. easing of export controls on the UAE. If you re-export U.S.-origin items from Japan, you need both maps: Japan's groups for Japanese law and the EAR's groups for U.S. law. For reading ECCNs and the Country Chart, see my ECCN classification guide.

What Changed Since the First Edition (July 2026)

I first published this piece on July 7, 2026. Here is what moved in three months.

Item	First edition (July 7, 2026)	Now (October 4, 2026)
Group A (Appended Table 3)	27 countries	Still 27; unchanged since the version effective July 21, 2023
Group D (Appended Tables 3-2 and 4)	Listed as 10 destinations and 3 countries	Same contents; added the 11-destination total and what each table does
Catch-all controls for Group A	Described only as out of scope	Added: since October 9, 2025, an inform notice triggers a license requirement (Article 1, paragraph 3)
Conventional-weapons catch-all for ordinary destinations	Described as inform notices only	Corrected: inform-only applies to Item 16(2); Item 16(1) goods also trigger on end-use and end-user findings
Current e-Gov version	Not covered	Version effective June 5, 2026, a housekeeping update following the FEFTA amendment; the country tables did not change
Official English translation	Not covered	The Japanese Law Translation database reflects amendments only up to Cabinet Order No. 164 of 2023, and its Appended Table 3 omits South Korea
EAR country groups	Not covered	UAE moved from D:3 and D:4 to A:5 on July 10, 2026

The correction first. The first edition said conventional-weapons catch-all controls for ordinary destinations work through inform notices only. Since the October 9, 2025 amendments, that holds only for Item 16(2) goods. Item 16(1) goods, such as machine tools and integrated circuits, also trigger a license when the exporter's own checks find a risk, even for ordinary destinations²¹¹. I also added the Group A inform requirement. Plenty of explainers still say catch-all controls never apply to Group A.

Next, a trap for anyone reading in English. The English translation of the Export Order in Japan's Ministry of Justice database is current only to Cabinet Order No. 164 of 2023 (effective April 2023). Its Appended Table 3 does not include South Korea, and its Article 1 has no paragraph 3¹⁸. Neither the July 2023 reinstatement nor the October 2025 amendments are in it. Use the translation to understand the structure, and use the Japanese original as your source of record. If your team in the U.S. or elsewhere has been working from the English text, this is worth checking on Monday morning.

What has not changed is the main lesson: the groups move. The 27 countries in Group A and the 11 destinations in Group D can both change with a cabinet order amendment. In my view, a team is better served by a routine for checking the current e-Gov text and its effective date than by memorizing country names. If you want to rebuild your process from destination group checks through export classification, book a consultation and we will map it against your actual transactions. For an overview of the product, download the TRAFEED product catalog (PDF). This article reflects the position as of October 4, 2026, and is not legal advice.

References

Footnotes

1. Cabinet Decision on the Partial Amendment of the Export Trade Control Order, including the renaming of country categories (in Japanese) — Ministry of Economy, Trade and Industry (METI) — August 2, 2019 ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸

2. Export Trade Control Order (Cabinet Order No. 378 of 1949), Articles 1, 2, and 4, Item 16 of Appended Table 1, Appended Tables 3, 3-2, and 4 (in Japanese) — e-Gov Legal Database (Digital Agency) — version effective June 5, 2026, checked October 4, 2026 ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸ ↩⁹ ↩¹⁰ ↩¹¹ ↩¹² ↩¹³ ↩¹⁴

3. Export Trade Control Order amendment history (Cabinet Order No. 71 of 2019: promulgated August 7, effective August 28, 2019; Cabinet Order No. 232 of 2023: promulgated June 30, effective July 21, 2023; Cabinet Order No. 194 of 2026: effective June 5, 2026) and Appended Tables 3, 3-2, and 4 in each version (in Japanese) — e-Gov Legal Database (Digital Agency) — versions compared by TIMEWELL, October 4, 2026 ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷

4. Foreign Exchange and Foreign Trade Act (Act No. 228 of 1949) (in Japanese) — e-Gov Legal Database (Digital Agency) — current text ↩

5. Security Export Control Guidance (Introductory Edition) (in Japanese) — METI — Version 3.0 (March 2026) ↩ ↩²

6. CISTEC — Center for Information on Security Trade Control (official site) ↩

7. Basic Commentary on Japan's Regulatory Practice Relating to the Review of Export Controls Toward South Korea (in Japanese) — CISTEC — August 2, 2019 ↩ ↩²

8. Cabinet Decision on the Bill for the Partial Amendment of the Export Trade Control Order (New Country Categories for Security Export Control) — METI — August 2, 2019 ↩

9. Security Export Control, top page (in Japanese) — METI ↩ ↩²

10. Catch-All Controls (in Japanese) — METI — page last updated December 23, 2025 ↩

11. Review of Catch-All Controls (effective October 9, 2025) (in Japanese) — METI — page last updated April 15, 2026 ↩ ↩²

12. Quick Guide to Security Trade Control: bulk license types, catch-all controls, and the U.S. Commerce Country Chart (in Japanese) — Japan External Trade Organization (JETRO) — January 2024 ↩ ↩² ↩³ ↩⁴

13. Review of Export Control Practice Toward South Korea, chronology page (in Japanese) — METI — last updated August 4, 2023 ↩ ↩²

14. Cabinet Decision on the Partial Amendment of the Export Trade Control Order (in Japanese) — METI — June 27, 2023 ↩

15. Opinion on the Draft Cabinet Order Amending the Export Trade Control Order: South Korea's Return to Group A (in Japanese) — CISTEC — May 29, 2023 ↩

16. 15 CFR Part 740, Supplement No. 1, "Country Groups" — eCFR — checked against the version current on October 1, 2026 ↩ ↩² ↩³

17. Enhanced Favorable Treatment for the United Arab Emirates Under the Export Administration Regulations (91 FR 43034, published July 14, 2026, effective July 10, 2026) — Federal Register ↩

18. Cabinet Order on Export Trade Control (English translation; last version reflected: Cabinet Order No. 164 of 2023) — Japanese Law Translation Database (Ministry of Justice) — checked October 4, 2026 ↩