Japan — Export Controls

Japan's export-control regime is based on the Foreign Exchange and Foreign Trade Act (Act No. 228 of 1949, commonly abbreviated FEFTA), which declares that its purpose is "to ensure that international transactions develop normally and that peace and security are maintained in Japan and the international community through the implementation of the minimum necessary controls and coordination for international transactions, under the basic principle of free engagement in foreign exchange, foreign trade, and other such international transactions." The Act grants licensing and enforcement authority to the Minister of Economy, Trade and Industry (METI), who administers Japan's controls on both exports of goods and transfers of technology.

## Dual control tracks: List Controls and Catch-All Controls

Under FEFTA Articles 25 (technology transfers) and 48 (export of goods), Japan enforces two types of controls:

1. List Controls apply to goods and technologies specified in:

• the Export Trade Control Order (Cabinet Order No. 378 of 1949, "ETCO") Appended Table 1 for goods, and
• the Foreign Exchange Order (Cabinet Order No. 260 of 1980, "FEO") Appended Table for technologies.

The detailed technical specifications are set out in the Ministerial Order Specifying Goods and Technologies (Ministerial Order of International Trade and Industry No. 49 of 1991, "MOSGT"). List Controls capture items that are weapons themselves or dual-use goods and technologies that, following agreements reached in international export-control regimes (the Nuclear Suppliers Group, Australia Group, Missile Technology Control Regime, and Wassenaar Arrangement), can be used for the development, production, or use of weapons of mass destruction or conventional weapons.

1. Catch-All Controls apply to non-listed dual-use items and technologies when:

• the exporter knows (or is informed by METI) that the item will be used for WMD or missile development ("informed" or "objective" triggers for WMD Catch-All), or
• the destination is a country or region subject to UN Security Council arms embargoes and the exporter knows the item will be used for conventional-weapon development or production (Conventional Weapon Catch-All).

Any export of goods or transfer of technology subject to List Controls or Catch-All Controls requires a licence from the Minister of METI in advance.

## Deemed-export controls (resident-to-resident technology transfers)

FEFTA's technology-transfer controls apply not only to physical cross-border transfers but also to deemed exports—that is, technology transfers in Japan from a resident to a non-resident. Effective 1 May 2022, METI's clarification extended deemed-export controls to cover technology transfers to a resident who is under the significant influence of a foreign government or entity ("specific categories"). The "specific categories" designation captures three profiles: employees receiving financial support from a foreign government, employees exempted from repayment of a foreign government loan, and employees requested to conduct certain investigations in Japan under instructions from abroad. Regardless of the employee's nationality, a company transferring controlled technology to an employee falling under one of the specific categories must obtain a METI licence before the transfer.

## Policy context

METI has stated that Japan implements these controls "to prevent the proliferation of weapons of mass destruction, prevent the excess accumulation of conventional weapons, and execute treaties and other international agreements," and to "maintain peace and safety in Japan as well as in the international community by exercising the minimum necessary control or coordination measures over free trade." Japan participates actively in the four multilateral export-control regimes and updates its control lists—by Cabinet Order—to reflect agreements concluded at regime plenaries.

Source: Foreign Exchange and Foreign Trade Act, Act No. 228 of 1949 Source: METI Security Export Control — Guidance (tentative translation) Source: METI Trade Control overview

Japan's export-control lists are structured around 16 categories of goods and technologies, specified in the Appended Table 1 of the Export Trade Control Order (ETCO) for goods and in the Appended Table of the Foreign Exchange Order (FEO) for technologies. The detailed technical specifications for each category are set out in the Ministerial Order Specifying Goods and Technologies Pursuant to the Provisions of the Appended Table 1 of the Export Trade Control Order and the Appended Table of the Foreign Exchange Order (Ministerial Order of International Trade and Industry No. 49 of 1991, commonly abbreviated MOSGT).

## Categories 1–15: List Controls (multilateral-regime items)

Categories 1 through 15 capture items subject to List Controls. METI's official guidance states that "the controlled items on both lists are basically identical to those of the international export control regimes (NSG, MTCR, AG, WA) and the Chemical Weapons Convention," reflecting agreements reached in the Nuclear Suppliers Group, Missile Technology Control Regime, Australia Group, and Wassenaar Arrangement. METI further explains that Category 1 covers "weapons and sensitive general purpose goods (items/advanced materials/machine tools related to nuclear/biological/chemical weapons and missiles)," and Categories 2 through 15 cover regime-specific dual-use items.

The ETCO Appended Table 1 and FEO Appended Table provide general item descriptions (for example, "Equipment using superconducting materials"), while the MOSGT narrows each description with precise technical parameters. METI's academic guidance illustrates: "the 'Equipment using superconducting materials' specified as 7-(iv) in Appended Table 1 of the Export Trade Control Order is further limited in the Ministerial Order … to the 'electron devices or electronic circuits with components designed for use at temperatures lower than the critical temperature of the superconductive materials used' that has frequency separation function and the resonant circuits with a cue value exceeding 10,000."

An exporter must first identify the category in the ETCO or FEO Appended Table whose description matches the item, then consult the corresponding section of the MOSGT to determine whether the item's performance or design characteristics meet or exceed the specified thresholds.

## Category 16: Non-listed items subject to Catch-All Controls

Category 16 lists items that do not fall under Categories 1–15 (and therefore are not subject to List Controls) but are nevertheless subject to Catch-All Controls when the exporter knows or is informed by METI that the item will be used for WMD or conventional-weapon development. METI's guidance explains: "Those under Categories 1 through 15 are controlled items subject to the List Control, while others under Category 16 are non-controlled items but are subject to the Catch-All Control."

## Classification workflow per METI guidance

METI directs exporters to follow a screening process:

1. Check whether the item description matches any category in the ETCO Appended Table 1 (for goods) or FEO Appended Table (for technologies).
2. Verify against the MOSGT specifications whether the item's technical parameters meet the control thresholds for that category.
3. If the item is not controlled under Categories 1–15, assess whether it falls under Category 16 and whether any Catch-All trigger applies.

METI states that "the technologies to transfer or goods to export have to be screened if they are subject to the" List Controls or Catch-All Controls, and that exporters must obtain a licence from the Minister of METI in advance when either control applies.

METI updates the MOSGT by Cabinet Order amendment to reflect agreements concluded at the plenaries of the four multilateral regimes. The current category structure and detailed technical parameters are published on METI's Security Export Control website, with periodic tentative English translations of guidance documents.

Source: METI Security Export Control — Guidance (tentative translation) Source: METI Guidance for the Control of Sensitive Technologies for Academic and Research Institutions Source: METI Trade Control — Policy overview

Japan's export-control regime requires a licence from the Minister of Economy, Trade and Industry (METI) in advance for any export of goods or transfer of technology subject to List Controls or Catch-All Controls under Articles 25 and 48 of the Foreign Exchange and Foreign Trade Act (FEFTA). The licensing framework distinguishes between two licence types—individual licences and bulk licences—and applies destination-based rules that vary according to whether the destination is a Group A country, a region subject to a UN Security Council arms embargo, or a General Country.

## Individual licences

An individual licence is the default: a licence issued for each single export transaction or technology transfer. METI's official guidance states that "in principle, the screening period at METI is within 90 days from the receipt of the application," though the period may vary depending on the category number, transaction details, or other factors. If the submitted documents are deficient, the time required to correct them is not included in the 90-day screening period, so exporters are directed to "check and submit your application well in advance."

Applications must be submitted electronically through the NACCS FEFTA-related services (Nippon Automated Cargo and Port Consolidated System). Effective July 1, 2022, only electronic applications are accepted; paper applications by mail are no longer processed.

When applying for an individual licence, exporters must prepare the necessary documents specified by METI, which typically include an application form detailing the exporter, product specifications, end-user, shipping route, and other relevant information, as well as supporting documents such as contracts, purchase orders, and end-user statements. The specific document requirements and the contact office (METI Headquarters or a regional METI bureau) depend on the category number and the destination of the controlled item. For applications based on Catch-All Controls, the contact office is always METI Headquarters in Tokyo.

## Bulk licences

A bulk licence (also referred to as a "general licence" or "comprehensive licence" in METI guidance) is an alternative available to exporters who have established an internal export-control system and are capable of performing export control well under their own management. METI's guidance explains that "the exporter is allowed to get and use a 'bulk license', which is a comprehensive license covering a certain scope without having to apply for separate licenses for each individual contract."

To qualify for a bulk licence, exporters must demonstrate compliance with the Ministerial Order Specifying Compliance Standards for Exporters (Ministerial Order of the Ministry of Economy, Trade and Industry No. 60 of 2009, commonly referred to as the "Exporters' Compliance Standards"). Parties who repeatedly export controlled goods or transfer controlled technologies under FEFTA are obliged to comply with these standards, which establish conditions related to internal compliance systems. Furthermore, as one of the conditions for obtaining specific bulk licences, exporters are required to establish an internal compliance programme (CP) adopting specific processes designated by METI and to file it with METI.

The available types of bulk licences differ depending on the item, the export destination, and other factors. For example, exports of advanced semiconductor manufacturing equipment to certain Group A countries may qualify for a simplified bulk-licence procedure, while exports to other countries (including China and Russia) may require a Specific Bulk Licence (特定包括許可), which permits transactions only with the same counterparty with whom the exporter has an ongoing business relationship.

## Destination-based framework: Group A, UN arms embargo regions, and General Countries

Japan's export-control regulations divide the world into three destination categories, each subject to different Catch-All Control requirements:

1. Group A countries

Group A countries are listed in Appended Table 3 of the Export Trade Control Order (ETCO, Cabinet Order No. 378 of 1949). METI defines Group A as "countries that participate in each multilateral export control regime and strictly enforce export controls." The list comprises 26 countries, including the United States, the United Kingdom, EU member states that participate in the regimes, Australia, Canada, New Zealand, South Korea, and others.

Historically, exports to Group A countries were not subject to Catch-All Controls for either WMD or conventional weapons. However, effective October 9, 2025, a Cabinet Order amendment introduced an "informed" condition for exports to Group A countries. Under this amendment, if METI determines that goods or technologies exported to a Group A country may be used for WMD development or conventional-weapon development—particularly where there is a risk of circumvention export to countries of concern via a Group A intermediary—METI may notify (inform) the exporter that a licence application is required. The exporter must then apply for an individual or bulk licence before proceeding with the export. This change was made "from the perspective of preventing circumvention to regions other than such countries/regions," as METI explained in the April 4, 2025 Cabinet Decision.

2. Regions under UN Security Council arms embargoes

Regions subject to UNSC arms embargoes are listed in Appended Table 3-2 of the ETCO. As of METI's most recent guidance, these include Afghanistan, the Central African Republic, the Democratic Republic of the Congo, Iraq, Lebanon, Libya, North Korea, Somalia, and South Sudan. Exports to these regions are subject to both the informed condition (METI may notify the exporter to apply for a licence) and the objective condition (the exporter must apply for a licence when the exporter knows or has come to know that the item will be used for WMD or conventional-weapon development).

For conventional-weapon Catch-All Controls, exports to UN arms embargo regions require a licence when the exporter knows that the technologies or goods will be used for the development, manufacture, or use of conventional weapons, or when METI so informs the exporter.

3. General Countries

General Countries (also referred to as "General regions" in METI guidance) are all countries other than Group A and the UNSC arms embargo regions. The list includes China, Russia, India, Croatia, Estonia, Iceland, Latvia, Lithuania, Malta, Mexico, Myanmar, Pakistan, Romania, Slovakia, Slovenia, South Africa, Turkey, Ukraine, and many others.

Exports to General Countries are subject to WMD Catch-All Controls under both the informed condition and the objective condition. Under the objective condition, exporters must apply for a licence when they know or have come to know that the technologies or goods will be used for WMD or missile development (the "end-use condition") or when the end-user is or was involved in WMD development (the "end-user condition"). The end-user condition is satisfied, for example, when the end-user is listed on the Foreign End User List published by METI, which contains companies and organizations that have the risk of being involved in WMD development.

Effective October 9, 2025, the conventional-weapon Catch-All Controls for General Countries were expanded. Under the amendment, exports of specified items (designated "core items" such as certain semiconductors and machine tools with high dual-use risk) to General Countries now require a licence not only under the informed condition but also under a new objective condition (the "know" condition). Exporters must verify the end-use and end-user at the time of shipment, and if the item will be used for conventional-weapon development or the end-user is engaged in such development, a licence must be obtained.

## Screening and decision

METI examines the end-user and the end-use of the item being exported based on the application form and attached documents. Under Japanese export-control regulations, the default practice is to grant export licences on a transaction-by-transaction basis (individual licences). METI will issue an export licence if it is confirmed that the item is destined for civilian use and will not interfere with the maintenance of international peace and security. Conditions may be added to export licences—for example, post-shipment monitoring of items or prior consent in case of re-transfer—if necessary.

Source: METI Security Export Control — Guidance (tentative translation) Source: Foreign Exchange and Foreign Trade Act, Act No. 228 of 1949 Source: METI Trade Control overview Source: Cabinet Decision on the Cabinet Order to Partially Amend the Foreign Exchange Order (April 4, 2025)

Violations of Japan's export-control provisions under the Foreign Exchange and Foreign Trade Act (FEFTA) are subject to two parallel enforcement tracks: criminal penalties and administrative sanctions. Both individuals and juridical persons (corporations) face exposure, and METI has publicly stated that export-control violations are treated as matters of national security, not merely trade-rule violations.

## Criminal penalties

The Foreign Exchange and Foreign Trade Act establishes criminal penalties in Chapter IX, Articles 69-6 through 73. The statute distinguishes between ordinary export-control violations and those involving goods or technologies related to weapons of mass destruction (WMD).

Individuals

For WMD-related violations (unlicensed export of goods or transfer of technology controlled under Categories 1–15 when the item is related to WMD development), natural persons face imprisonment for not more than ten years and/or a fine of not more than ¥30 million, or five times the value of the exported goods or transferred technology, whichever is higher.

For other export-control violations (including Catch-All violations and exports to sanctioned destinations), natural persons face imprisonment for not more than seven years and/or a fine of not more than ¥20 million, or five times the value of the exported goods or transferred technology, whichever is higher.

These criminal penalties apply to violations committed with intent. METI's guidance states that the police and public prosecutors investigate and prosecute export-control violations as criminal cases. In practice, METI may provide information to the police or file a criminal complaint when a violation is discovered, triggering the criminal investigation process (METI investigation → police investigation → referral to prosecutors → indictment → trial → verdict).

Juridical persons (corporate liability)

Under Japanese law, if a natural person—such as a representative or employee—commits an export-control violation in connection with the business or assets of a juridical person, both the individual and the juridical person are subject to penalties. For WMD-related violations, the corporation may be fined not more than ¥1 billion or five times the value of the transaction, whichever is higher. For other export-control violations, the maximum corporate fine is lower, though the statute does not specify a separate lower ceiling for non-WMD violations.

This dual-liability provision (Article 76-2) means that a company cannot shield itself from penalties by arguing that only an individual employee acted. Both the violating employee and the employer corporation are liable when the violation occurs in the course of the corporation's business.

## Administrative sanctions

In addition to criminal penalties, METI may impose administrative sanctions on persons who violate export-control or sanctions provisions. Under Article 48(3) of FEFTA (for exports of goods) and Article 25(6) (for technology transfers), the Minister of Economy, Trade and Industry may prohibit all or part of a person's exports or technology transfers for a period not exceeding three years when the person has exported goods or transferred technology without obtaining a required licence.

For violations of sanctions measures (as opposed to export-control licensing), the maximum prohibition period is one year for financial and service transactions, and three years for violations involving goods where the sanctions were unilaterally imposed by Japan (rather than under a UNSC resolution).

When METI imposes an administrative sanction, the company's name is publicly disclosed. The sanction and the identity of the violator are published on METI's website and are typically reported in the press. METI maintains a public record of administrative actions, and companies subject to export bans are prohibited from engaging in the specified export activities during the ban period.

## Enforcement procedure and recent cases

METI conducts on-site inspections and post-shipment audits to identify violations. The agency also receives reports of suspicious transactions from customs authorities under the Customs Act, and from financial institutions under the Act on Prevention of Transfer of Criminal Proceeds. When a violation is detected, METI opens an investigation and requires the exporter to clarify the facts and, if a violation is confirmed, to formulate measures to prevent recurrence.

If the case is deemed serious, METI may refer it for criminal prosecution. For example, in May 2025, METI announced an administrative penalty in connection with the unauthorised export of motorcycles and other goods to Russia via South Korea. The case was prosecuted criminally, and the court imposed a sentence on the individual involved. As an administrative penalty, METI prohibited the Japanese company and its CEO from exporting the sanctioned goods to any region for one year.

In April 2025, the former CEO of a Japanese marine products import company received a one-and-a-half-year prison sentence, suspended for three years, for the unauthorised import of seafood from North Korea. In 2016, a Japanese company was fined ¥3 million, and an employee thereof received a two-and-a-half-year sentence with a four-year suspended sentence in a case where the export of kitchen and daily items to Singapore was judged to be a de facto export to North Korea (valued at approximately ¥12 million). The case underscored that transshipment through an intermediary country—when the exporter knows the ultimate destination is an embargoed country—constitutes a violation under FEFTA.

In one notable case involving three-dimensional measuring equipment found in a Libyan nuclear-development facility in 2007, the company itself was fined ¥45 million, and four executives (including the ex-Vice Chairman) were sentenced to two to three years' imprisonment with suspended sentences of four to five years. METI also imposed an administrative export ban totalling three years: a six-month prohibition on all exports to any destination, plus a two-and-a-half-year prohibition on exports of the specific equipment category.

## Knowledge requirement and defenses

In criminal cases, knowledge or intent is an essential element. The 2018 acquittal of a Japanese trading company and its export-division employee in a case involving fabric exports to China—where the final destination was North Korea—demonstrates that the prosecution must prove the exporter knew or should have known the ultimate destination or end-use. However, METI guidance states unequivocally that "I didn't know" is not accepted as a defense in administrative proceedings, because exporters have a statutory duty to investigate and verify the end-use and end-user under the Compliance Standards for Exporters (Ministerial Order No. 60 of 2009). Negligence—such as a mistake in classification, failure to screen the Foreign End User List, or misinterpretation of a licence exemption—can still trigger administrative sanctions.

## Non-legal consequences

METI's official guidance emphasises that the most severe consequences of an export-control violation are often non-legal: reputational damage, termination of business relationships by customers and suppliers who cannot afford the compliance risk of dealing with a sanctioned party, shareholder litigation, and in the worst case, bankruptcy. A company subject to a multi-year export ban may find that its supply chain partners refuse to continue trading, and that financing sources withdraw. For companies with a high proportion of overseas sales or heavy dependence on specific major customers, an export ban can be fatal to continued operations.

There is no statute of limitations for administrative sanctions under FEFTA. Past violations may be discovered years later—for example, through a post-shipment audit or a foreign government's disclosure—and METI retains the authority to impose administrative sanctions even when the underlying shipment occurred long ago.

Source: Foreign Exchange and Foreign Trade Act, Act No. 228 of 1949, Chapter IX Penal Provisions Source: METI Trade Control — Policy overview

Although exports of controlled goods or transfers of controlled technology ordinarily require a licence from the Minister of Economy, Trade and Industry (METI) under Articles 25 and 48 of the Foreign Exchange and Foreign Trade Act (FEFTA), Japan's export-control framework provides a series of statutory exemptions that dispense with the individual-licence requirement when specific conditions are met. These exemptions are set out in Article 2, paragraph (2) of the Export Trade Control Order (Cabinet Order No. 378 of 1949, "ETCO") and cover categories such as diplomatic and international-organisation goods, personal effects and household goods, and re-export of goods sent without charge for evaluation or repair.

## Exemptions for international organisations, diplomatic missions, and public-use goods

Under ETCO Article 2(2)(iii), a METI export licence is not required for:

(c) Goods sent by international organisations that are exempt from export restrictions under treaties or other international agreements that Japan has signed;

(d) Goods for public use sent to embassies, legations, consulates, and other similar facilities of Japan (Japanese diplomatic missions abroad);

(e) Goods imported without charge on the premise that they will be exported without charge, and which the Minister of Economy, Trade and Industry specifies by public notice (for example, samples sent into Japan for evaluation and returned without charge); and

(f) Goods to be exported without charge on the premise that they will be imported without charge, and which the Minister of Economy, Trade and Industry specifies by public notice (for example, goods sent abroad for repair and returned without charge).

These exemptions ensure that temporary shipments, diplomatic goods, and UN or multilateral-institution shipments are not subject to export-licensing delays, provided they meet the conditions set by METI in public notice.

## Personal effects, occupational tools, and household goods (Appended Table 6)

ETCO Article 2(2)(iv) establishes a personal-effects exemption. When any person listed in the left-hand column of Appended Table 6 of the ETCO departs from Japan and intends to export goods listed in the right-hand column—either by personally carrying the goods or by sending them separately after filing a declaration with Customs—a METI export licence is not required.

Appended Table 6 specifies three categories of persons and corresponding exemptions:

1. Persons departing Japan—whether Japanese nationals or foreign nationals—may export personal effects, occupational tools, and goods to be moved (the exporter's household goods) without a METI licence. The ETCO defines "personal effects" as "baggage, garments, documents, cosmetics, personal ornaments, and other goods intended to be used and considered necessary for an individual's private purposes." The term "goods to be moved" covers household furniture, appliances, and personal property shipped when relocating abroad.

1. Persons entering Japan for the purpose of permanent residence may export personal effects, occupational tools, and goods to be moved without a METI licence.

1. Crew members of vessels or aircraft may export personal effects and occupational tools without a METI licence.

Importantly, the personal-effects exemption does NOT apply to the following categories of controlled goods, even when carried by a departing person:

• Goods listed in the middle column of row 1 of Appended Table 2 of the ETCO (weapons and military goods subject to destination-specific controls, such as firearms, ammunition, and military explosives);
• Goods listed in rows 35-3(i) and (vi) and the middle column of row 35-4 of Appended Table 2 (certain sanctioned goods to specific destinations, including goods subject to Russia/Belarus embargoes, as specified by METI public notice);
• When a person who entered Japan temporarily (for example, on a visitor or business visa) departs and seeks to export goods listed in row 36 of Appended Table 2 (excluding those specified by METI public notice); and
• When crew members of a vessel or aircraft seek to export goods listed in Appended Table 2-2 to North Korea.

The practical effect is that an individual relocating from Japan to the United States and shipping personal effects, household furniture, a laptop computer, and clothing does not require a METI export licence for those items—unless any of the items fall under the weapons or sanctioned-goods carve-outs above, or unless the item itself is a List Control item that meets the technical specifications in the Ministerial Order Specifying Goods and Technologies (MOSGT) and the individual knows (or METI informs the individual) that the item will be used for WMD or conventional-weapon development. In practice, most personal effects and household goods do not meet the MOSGT technical thresholds, and the personal-effects exemption provides a safe harbour for emigration and expatriation shipments.

## De minimis threshold (Appended Table 7)

ETCO Article 2(3) establishes a de minimis value exemption. A person who intends to export goods the total value of which is not more than the amount listed in the right-hand column of Appended Table 7 for the respective categories of goods listed in the middle column of that table does not require a METI export licence under Article 2(1)(i). Appended Table 7 specifies value thresholds by category; historically, this exemption applied to low-value shipments below a yen threshold set by Cabinet Order. However, METI guidance states that controlled goods subject to List Controls or Catch-All Controls are generally not eligible for the de minimis exemption—even when the value is low—if the exporter knows or has been informed by METI that the goods will be used for WMD or conventional-weapon development. Exporters should consult the current Appended Table 7 (as amended by Cabinet Order) and confirm with METI whether a specific controlled item qualifies for the value exemption.

## Exemption for allied armed forces joint-training equipment (effective April 2025)

Effective upon the April 4, 2025 Cabinet Decision on the partial amendment to the Foreign Exchange Order, Japan introduced a new exemption for exports of goods brought into Japan by the armed forces of like-minded countries for the purpose of joint training with the Self-Defense Forces. These goods are now exceptions to export licence requirements. The April 2025 Cabinet Decision states that "exports of goods brought into Japan by the armed forces of like-minded countries for the purpose of joint training with the Self-Defense Forces will be exceptions to export licence requirements."

This exemption recognises that military equipment and technology brought into Japan by U.S. forces, Australian Defence Force units, or other allied forces under joint-training or defence-cooperation agreements should not be subject to individual METI export-licence procedures when the same equipment is re-exported at the conclusion of the training event. The exemption applies only to goods brought into Japan by the allied armed forces and subsequently exported; it does not dispense with the licence requirement for exports of controlled goods to those same allied armed forces when the goods originate in Japan. The scope of "like-minded countries" is not defined by statute; METI's practice is to interpret the term to mean countries with which Japan has defence-cooperation agreements or memoranda of understanding (such as the United States under the Treaty of Mutual Cooperation and Security, Australia under the Acquisition and Cross-Servicing Agreement, and other Group A countries with bilateral defence ties).

## Bulk licences as a form of general permit

In addition to statutory exemptions, Japan's export-control framework offers bulk licences (also referred to as "general licences" or "comprehensive licences" in some METI guidance). As described in the licence-types section of this guide, a bulk licence is not a true exemption—it still requires advance permission from METI—but it permits multiple exports or technology transfers within a defined scope (for example, to a specific end-user, for a specific category of goods, or to a specific Group A destination) without the need to file a separate individual-licence application for each transaction. Exporters who have established an internal compliance programme (CP) meeting the requirements of the Ministerial Order Specifying Compliance Standards for Exporters (Ministerial Order No. 60 of 2009) and who file the CP with METI may qualify for a bulk licence. Once granted, the bulk licence operates as a standing general permit for transactions that fall within its terms.

METI's official guidance states that "the exporter is allowed to get and use a 'bulk license', which is a comprehensive license covering a certain scope without having to apply for separate licenses for each individual contract," and that bulk licences are available to exporters "who repeatedly export controlled goods or transfer controlled technologies" and "are capable of performing export control well under their own management."

## Conditions and limitations on exemptions

Even when an exemption applies, exporters must still comply with Customs Act filing requirements. The ETCO personal-effects exemption, for example, applies only when the departing person files a declaration with Customs for separately shipped goods. Customs will not release the shipment without a declaration, even if METI licensing is not required.

Furthermore, exemptions are subject to withdrawal by METI public notice when necessary "to sincerely fulfill obligations under the treaties and other international agreements Japan has signed" (ETCO Article 2(2) proviso). If the UN Security Council imposes a targeted embargo, or if a multilateral export-control regime adopts a new control measure, METI may amend the Appended Tables by Cabinet Order or issue a public notice narrowing the scope of an exemption, and exporters who previously relied on the exemption may find that a licence is now required.

Exporters should verify the current text of the ETCO Appended Tables and any METI public notices at the time of shipment. The Export Trade Control Order is amended periodically by Cabinet Order (typically once or twice per year) to reflect agreements concluded at the plenaries of the four multilateral export-control regimes (NSG, MTCR, AG, WA) and to implement UN Security Council sanctions resolutions. An exemption that applied in one year may not apply in the next if the Cabinet Order has been amended.

Source: Export Trade Control Order (Cabinet Order No. 378 of 1949), Article 2 Source: Cabinet Decision on the Cabinet Order to Partially Amend the Foreign Exchange Order (April 4, 2025) Source: METI Security Export Control — Guidance (tentative translation)