On February 24, 2026, the Ministry of Commerce of the People’s Republic of China (MOFCOM) issued Announcements No. 11 and No. 12 of 2026. In accordance with the Export Control Law of the People’s Republic of China and related regulations, 40 Japanese entities have been added to the Export Control List and, for the first time, a newly established “Watch List.”
As your international logistics partner, we understand that compliance is the lifeline for smooth customs clearance. This policy update not only represents an upgrade in export controls targeting Japan but also marks a new phase of “precise and tiered governance” in China’s export control system. To ensure that your business with Japan remains unaffected, we have summarized the key changes and operational points for your reference.
I. Two Lists, Two Outcomes
| Announcement | List Type | Number of Entities | Representative Entities | Legal Consequences |
| Announcement No. 11 | Export Control List | 20 | Mitsubishi Shipbuilding, Kawasaki Heavy Industries, National Defense Academy of Japan, etc. | Strictly Prohibited: Export of any dual-use items to these entities is banned. Any ongoing transactions must be halted immediately. |
| Announcement No. 12 | Watch List | 20 | Subaru, Tokyo University of Science, Fuji Airlines, Mitsubishi Materials, etc. | Strict Review: General export licenses are not permitted. A single-use license must be applied for, and the review period will be extended. |
This marks the first implementation of the “Watch List” mechanism, signaling a more refined and stringent compliance review process for exports to Japan.
II. Practical Impact on Export Operations
Export Control List (Red Line)
● Absolute prohibition on exporting any dual-use items to entities on this list.
● Prohibition on transferring or supplying dual-use items originating from China to listed entities.
● Logistics Impact: If the consignee or end user is on this list, shipments cannot be accepted.
Watch List (Yellow Light)
● General licenses are not allowed; a single-use export license must be obtained.
● Application materials must include: end-use statement, risk assessment report, and written commitment.
● Logistics Impact: Extended review periods and increased uncertainty in customs clearance.
III. Four Compliance Recommendations for Logistics
1. Immediately Screen Your Customers and Consignees
Please verify your contracts and orders for exports to Japan to confirm whether the consignee or end user is on either of the two lists.
How to check: Visit the MOFCOM official website or contact our customer service for assistance.
● Beware of “Deemed Exports” and “Transshipment Risks”
⚠️ It is strictly prohibited to ship goods to a third country (e.g., South Korea, Vietnam) for subsequent transshipment to sanctioned entities. Such actions are considered circumvention of controls and may lead to criminal investigation.
● For Dual-Use Items, Declare Accurately
✅ Dual-use items include but are not limited to: rare earth materials, high-performance materials, precision equipment, sensors, aviation and marine components.
✅ Do not misdeclare the final destination or split shipments to evade regulation. Violations may result in fines up to ten times the illegal income or even criminal liability.
● For Watch List Clients: Follow the “Special Channel”
✅ Being on the Watch List does not mean business is impossible, but the following steps are mandatory:
● Cooperate with MOFCOM investigations and provide end-use certifications.
● Apply for a single-use license; do not conceal information or attempt to ship without approval.
● Companies that meet requirements may later apply for removal from the Watch List.
IV Our Service Commitment
To ensure the security and smooth flow of your trade, we have upgraded our compliance procedures:
✅ New automated name screening in our system
✅ Pre-clearance compliance review for Japan-bound shipments
✅ Professional advisory support for dual-use exports
✅ Full-process risk alerts and emergency response mechanisms
The era of “ignorance as an excuse” is over. As export controls become increasingly stringent, logistics companies must fulfill their duty of careful document review and compliance scrutiny.
If you have any questions about whether an HS code is sensitive or whether a consignee is restricted, please feel free to contact your dedicated logistics advisor. We will strictly uphold compliance standards and ensure your cargo is safely delivered.
合规先行，稳行致远 / Compliance First, Steady Progress!
Post time: Feb-28-2026