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On 2 October 2026, the Japanese government announced further sanctions against the Russian Federation under the Foreign Exchange and Foreign Trade Act in line with measures adopted by other major countries. The additional measures, based on the Cabinet Understanding of “Asset Freeze Measures for Parties of the Russian Federation, etc.,” designate parties subject to asset freeze measures and export prohibitions and vessels subject to service and capital transaction restrictions while also prohibiting the export of goods, etc. that contribute to strengthening the industrial base of the Russian Federation. The measures have been implemented in light of the current international situation surrounding Ukraine and to contribute to international efforts aimed at resolving this issue and maintaining international peace.

In addition, on 6 October 2026, the Japanese government announced an expansion of its Russia-related export restrictions, adding a broad range of industrial goods (designated by HS Codes) to its list of items prohibited for export to Russia. The newly controlled items include certain minerals, chemicals, plastics, steel and non-ferrous metal products, machinery and measuring and medical instruments. The amendments were approved by the Cabinet on 6 October 2026, promulgated on 9 October 2026 and entered into force on 16 October 2026.

Sanctioned parties

1. Additional asset freezes: The Japanese Ministry of Foreign Affairs designated 33 entities and nine individuals affiliated with the Russian Federation for asset freeze measures.

2. Export prohibitions: A prohibition was introduced on exports to four military-related entities in countries other than Russia and Belarus.

3. Restrictions on specified vessels: Restrictions were introduced on service and capital transactions (including loan and guarantee agreements) in connection with 35 newly specified vessels. These measures will take effect on 2 October 2026. However, they will not apply to the performance of obligations or the provision of labor or benefits pursuant to contracts concluded before that date, provided that such performance or provision occurs before 1 November 2026.

Overview of additional goods subject to export restrictions

The new restrictions cover 102 industrial goods, nine chemical and biological weapons-related substances, as well as certain machine-tool software. Export of goods subject to these restrictions would require an export approval from the Minister of the Economy, Trade and Industry pursuant to Article 48, Paragraph 3 of the Foreign Exchange and Foreign Trade Act. As a general rule, the approval will not be granted, subject to limited exceptions specified in the applicable administrative guidance including for humanitarian reasons.

Goods subject to the newly expanded Russia-related export restrictions are summarized below.

  • Salt, sulfur, earths and stone, plastering materials, lime and cement under HS Chapter 25, such as dolomite, vermiculite, perlite and chlorites
  • Ores, slag and ash under HS Chapter 26, such as chromium ores, molybdenum ores and zirconium ores
  • Mineral fuels, mineral oils and products of their distillation, bituminous substances and mineral waxes under HS Chapter 27, such as benzol (benzene), toluol (toluene) and naphthalene
  • Inorganic chemicals, organic or inorganic compounds of precious metals, rare-earth metals and radioactive elements or isotopes under HS Chapter 28, such as chlorine, sublimed sulfur, precipitated sulfur, colloidal sulfur, iron oxides and hydroxides
  • Tanning or dyeing extracts, tannins and their derivatives, dyes, pigments and other coloring matter, paints and varnishes, putty and other mastics and inks under HS Chapter 32, such as pigments and preparations based on titanium dioxide
  • Plastics and articles thereof under HS Chapter 39, such as synthetic monofilaments of plastics, plastic rods and plastic profiles
  • Articles of iron or steel under HS Chapter 73, such as wire cloth, wire grills and skid chains
  • Copper and articles thereof under HS Chapter 74, such as unrefined copper and copper anodes for electrolytic refining, nails, tacks, drawing pins and similar articles
  • Aluminum and articles thereof under HS Chapter 76, such as unwrought aluminum, aluminum waste and scrap and aluminum powders and flakes
  • Other base metals, cermet and articles thereof under HS Chapter 81, such as tungsten and articles thereof, sized turnings and magnesium granules and powders
  • Tools, implements, cutlery, spoons and forks of base metal and parts thereof under HS Chapter 82, such as chainsaw blades, pipe cutters and bolt cutters
  • Miscellaneous articles of base metal under HS Chapter 83, such as castors, hat racks, and brackets
  • Nuclear reactors, boilers, machinery and mechanical appliances and parts thereof under HS Chapter 84, such as gas turbines and sealed biological safety cabinets
  • Optical, photographic, cinematographic, measuring, checking, precision, medical or surgical instruments and apparatuses and parts and accessories thereof under HS Chapter 90, such as drafting tables and drafting machines and thermometers and pyrometers

We will continue to monitor and provide updates on any further developments in Japanese sanctions and export controls applicable to Russia.

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Tokyo