1. Introduction
On April 9, 2025, the Ministry of Economy, Trade and Industry ("METI") announced an amendment to the regulations related to the Foreign Exchange and Foreign Trade Act ("FEFTA") to catch-all export controls. The amendment will take effect on October 9, 2025.
The purpose of the amendment is to modify Japan's FEFTA regulations, in particular to revise the catch-all export control measures. The expected impact of the amendment on Japan's export control practices is profound.
2. Details of the Amendment
The most critical aspects of the amendment concern revisions to the catch-all export controls:
- Reclassification of Controlled Items
The items subject to catch-all export controls will be divided into two categories. Items with a high risk of dual use—such as certain semiconductors and machine tools—will be designated as "core items, " while other items will remain under the general catch-all category. - "Know" Conditions will be introduced for the
Catch-All Export Controls of Conventional Arms, including Exports
to General Countries
For exports of specific items to countries other than those classified as Group A countries, i.e., countries participating in the respective multilateral export control regimes and strictly enforcing export controls, "know" conditions will be introduced for the catch-all export control of conventional arms. This requires exporters to confirm the intended use and end-user at the time of shipment. If either condition is met, exporters will be required to obtain an export permit. - "Informed " Conditions will apply to Exports
to Group A Countries
The amendment introduces "informed" conditions to exports destined for Group A countries. If an exporter that plans to export items to Group A countries receives notification from the METI, it will be required to apply for an export permit. This change reflects concerns about circumvention, such as reported transit exports from Group A countries to Russia.
3. Conclusion
This regulatory amendment will increase the compliance burden on exporters, particularly with respect to the objective requirements for certain items destined to general countries, including China. In light of these changes, stakeholders are urged to monitor the developments in export control practices closely, review their internal procedures, and prepare for the evolving regulatory landscape.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
