On 24 February 2026, the Ministry of Commerce of the People’s Republic of China announced new export control measures affecting a total of 40 Japanese entities under China’s export control regulatory framework. The measures were issued pursuant to the Export Control Law of the People’s Republic of China and related regulations governing dual-use items.
Under the announcement, 20 Japanese entities were added to China’s export control list, resulting in a prohibition on the export of specified dual-use items to those entities. Chinese exporters are not permitted to supply controlled items to listed parties unless a specific exemption applies under law. In parallel, another 20 Japanese entities were placed on a watchlist, triggering heightened regulatory scrutiny. Exports of controlled items to watch-listed entities are not automatically prohibited, but exporters must apply for individual export licenses and provide detailed documentation demonstrating end-use compliance, end-user legitimacy, and risk mitigation.
From a business perspective, these measures directly affect supply chains involving controlled technologies, materials, components, and equipment classified as dual-use. Companies engaging in China-related trade should anticipate longer licensing timelines, increased compliance costs, and potential disruptions to delivery schedules where counterparties are impacted. Contractual commitments, delivery obligations, and pricing arrangements may need to be reassessed to account for regulatory uncertainty and licensing risk.
For trade compliance professionals, immediate priorities include screening counterparties against the updated control lists, reviewing product classifications for export-controlled items, strengthening end-use and end-user due diligence, and updating internal export control procedures. Enterprises should also ensure close coordination between legal, compliance, sales, and logistics teams to manage licensing requirements and avoid inadvertent violations.
Overall, the announcement underscores the growing importance of robust export control compliance frameworks and proactive risk management in cross-border trade involving controlled goods.
Kindly refer to the following official announcement from the Ministry of Commerce:
https://www.mofcom.gov.cn/zwgk/zcfb/art/2026/art_b5159a773124428a9813884015d1b8b3.html