China updates export control list including 20 Japanese entities under dual-use export controls
Date of publication: February 27, 2026
The Ministry of Commerce of the People's Republic of China (MOFCOM), pursuant to the Export Control Law of the PRC and the Regulations of the PRC on Export Control of Dual-Use Items, has issued Announcement No. 12 of 2026 to place 20 Japanese entities on a monitoring (attention) list in relation to exports of dual-use items.
The new measures
- Inclusion of 20 Japanese entities, for which the end-users and end-uses of dual-use items cannot be verified, in a monitoring list annexed to the announcement.
- A prohibition on export operators applying general licenses or using registration-and-filing procedures to obtain export certificates for dual-use item exports to the listed entities.
- A requirement, when applying for single (case-by-case) export licenses, to submit a risk assessment report on the relevant listed entity and to provide a written undertaking that the dual-use items will not be used for any purpose that could enhance Japan's military capabilities.
- Removal of the standard license review time limit prescribed in Article 17(1) of the Regulations on Export Control of Dual-Use Items for such export license applications.
- Stricter end-user and end-use examinations by MOFCOM for exports of dual-use items to the entities on the monitoring list.
- Non-approval of exports of dual-use items involving Japanese military end-users, military end-uses, or any other end-uses that could help enhance Japan's military strength.
- The possibility for entities on the monitoring list to apply for removal from the list if they fulfil their verification cooperation obligations under Article 26 of the Regulations on Export Control of Dual-Use Items, subject to MOFCOM's verification.
Since at least December 2025, China had continued regularly shipping rare earths to Japan, and Japanese companies are known to maintain stockpiles; however, the new measures mark an escalation in trade and security tensions, with Japan's government describing the actions as "completely unacceptable and deeply regrettable" and formally demanding their withdrawal.
Conclusion
The measures significantly tighten China's export control posture toward selected Japanese defence-linked entities, particularly in relation to dual-use technologies and critical rare earth materials. Companies should carefully review their supply chains, end-users and end-uses involving Chinese-origin dual-use items and Japanese counterparties, and ensure robust licensing, screening and documentation processes are in place to comply with the new controls.
These changes have been updated in ONESOURCE Global Trade Content.
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