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Japanese Export Controls

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Introduction During September 2023, the US, UK, and EU, and Japan, updated their Common High Priority Items Lists (“the List(s)”), with seven new Harmonized System (“HS”) codes. These coordinated Lists are composed of items identified as critical to Russia’s war effort, weapons systems and military development. The Lists highlight to businesses that there is a particularly high risk these sanctioned items may be the target of sanctions circumvention and possible diversion to Russia. Companies can…

On May 23, 2023, Japanese government announced an amendment of the export control regulations on the additional semiconductor related items, which will go into effect on July 23, 2023. The overview of the amendment of the Products and Technologies Specifications Ministry Order (“Ministry Order”), to which specific products and technologies were added to the controlled items, is as follows: From the international peace keeping and security point of view, items related with advanced semiconductor manufacturing…

On March 31, 2023, the Japanese Ministry of Economy, Trade and Industry (“METI”) initiated a public comment procedure for the Draft Amendment to Ministerial Ordinance and the Draft Amendment to Circular that is intended to impose new export control requirements on certain sensitive semiconductor manufacturing equipment from Japan. The public comment period is from March 31st, 2023 to April 29, 2023. Anyone can submit a comment through either (i) the Japanese government’s website, (ii) email,…

On May 1, 2022, the amendment to the Ministerial Ordinance for Exporter Standards and relevant administrative notices (the “Amendment”) came into force. Upon enforcement of the Amendments, so-called “Deemed Exports” will be interpreted in a more restrictive manner than previously. Although export licenses were not required for the provision of technology information between Japan residents, pursuant to the Amendment, if certain conditions are met, such provision may be regarded as a “Deemed Export” and subject…