Several updates were made to Japan’s export controls in November. Companies are advised to consider the relevance of the new regulations and ensure that appropriate steps are taken to comply with them.
1. Addition of certain items related to peptide, refractory metal powders and field-programmable logic devices, etc. to the List Control items
To reflect agreements reached at the international export control regime meetings, the following items have been added to Appended Table 1 of the Export Trade Control Order:
- Equipment for peptide synthesis [Item 3-2(2)10]
- Powders of alloys composed of multiple elements in approximately equal proportions or powders of refractory metals or their alloys [Item 5(20)]
- Modules, assemblies or devices incorporating field-programmable logic devices [Item 7(10-2)]
Promulgated on 14 November 2025, this addition will be effective 14 February 2026.
2. Removal of “glass eel” from export control list (to avoid overlap)
Effective 1 December 2025, “glass eel” will be subject to export control under the Act on Proper Distribution of Specified Aquatic Animals and Plants (administered by the Ministry of Agriculture, Forestry and Fisheries). To avoid duplication, “glass eel” will be deleted from Item 33 of Appended Table 2 of the Export Trade Control Order. Promulgated on 14 November 2025, this deletion went into effect on 1 December 2025.
3. Exemption for temporary export of bulletproof vests for VIP protection
To allow temporary exports of equipment that is clearly expected to be re-imported — such as bulletproof vests used by the National Police Agency protect dignitaries during foreign visits — the proviso of Article 4(1) of the Export Trade Control Order has been amended to exclude such exports from the licensing requirement under Article 48(1) of the Foreign Exchange and Foreign Trade Act. Promulgated on 14 November 2025, this amendment went into effect on 15 November 2025
4. Amendment to export control in line with amendment to London Protocol
A 2009 amendment to the 1996 Protocol to the 1972 Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter (“London Protocol”) — to which Japan is a party — introduced measures allowing the export of gas containing carbon dioxide captured for carbon dioxide sequestration under certain conditions.
Following the Japanese Diet’s acceptance of this amendment in May 2024, a Cabinet Order was adopted to amend the Export Trade Control Order to add gas containing CO₂ for CCS purposes to Appended Table 2. Promulgated on 19 November 2025, this amendment will allow the export of gas containing CO₂ for CCS purposes upon approval by the Minister of Economy, Trade, and Industry of Japan, effective 19 January 2026.
5. Addition of technologies subject to prior notification of transfer
Quantum dot, TADF material (next-generation OLED emissive material), phase difference film, and flexible endoscope were added as the technologies that require prior notification of transfer, to the Minister of Economy, Trade, and Industry, in accordance with “Technology Management Scheme through Public-Private Dialogue” which was established in December 2024.
In cases where diversion risks cannot be dispelled from the perspective of national security, the Minister of Economy, Trade, Industry may “inform” the exporter to submit a license application. As a general principle, the aim is to resolve issues through dialogue based on mutual trust. There are already 15 types of technologies subject to this prior notification requirement, and this addition will cover 4 more types of technologies. Promulgated on 14 November 2025, this addition will be effective on 14 January 2026.
