MOFCOM Places 20 Japanese Entities on Export Control Watch List, Tightening License Review

On June 29, 2026, the Ministry of Commerce (MOFCOM), through its Bureau of Industry Security and Import & Export Control, issued Announcement No. 28 of 2026. Pursuant to the Export Control Law of the People's Republic of China and the Regulation of the People's Republic of China on the Export Control of Dual-use Items, MOFCOM decided to place 20 Japanese entities whose end-users and end-uses of dual-use items cannot be verified — including MITSUI E&S Co., Ltd. — on the Watch List, effective upon publication. Unlike Announcement No. 27, issued the same day (which imposes a comprehensive ban on the export of dual-use items via the Control List), the Watch List adopts a stricter licensing review mechanism rather than an outright prohibition.

The announcement specifies that, when exporting dual-use items to the above 20 entities, exporters may not apply for a general license, nor may they obtain an export certificate by way of registration filing. When applying for an individual license, the exporter must submit a risk assessment report on the listed entity and provide a written undertaking that the dual-use items will not be used for any purpose that contributes to enhancing Japan's military capabilities. The license review period is not subject to the time limit prescribed in Paragraph 1, Article 17 of the Regulation on the Export Control of Dual-Use Items.

In addition, MOFCOM will apply more stringent end-user and end-use review to exports of dual-use items to the entities on the Watch List. Exports involving Japanese military end-users or military end-uses, or any other end-user/end-use that contributes to enhancing Japan's military capabilities, will not be approved. An entity placed on the Watch List may apply for removal after fulfilling the cooperation-with-inspection obligation set out in Article 26 of the Regulation on the Export Control of Dual-Use Items; MOFCOM may remove it from the Watch List upon verification.

The 20 Japanese entities placed on the Watch List include a number of aerospace, nuclear fuel, drone, telecommunications, and advanced-manufacturing enterprises such as MITSUI E&S, Mitsubishi Nuclear Fuel, Japan Nuclear Fuel Limited, Fujitsu, Hitachi, Komatsu, and OKI. Exporters of relevant dual-use items should pay close attention. The full list is as follows:

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The Watch List measures take immediate effect. Companies exporting dual-use items to Japan are advised to immediately screen their customers and transactions to determine whether any of the 20 listed entities are involved. Where export to these entities is genuinely necessary, exporters should prepare individual license applications in advance — including preparing a risk assessment report and a written undertaking that the items will not be used for purposes of enhancing Japan's military capabilities — and allow for a longer review period to avoid delivery disruptions caused by the tightened review.

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