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MOFCOM Announces Tiered Listing of 40 Japanese Entities, Significantly Tightening Japan-Related Export Compliance
On 24 February 2026, the Ministry of Commerce of the People's Republic of China ("MOFCOM") issued Announcement No.11 and Announcement No.12 of 2026, simultaneously adding a total of 40 Japanese entities to the Export Control List and the Watch List, respectively. Earlier, on 6 January 2026, MOFCOM had already issued Announcement No.1 of 2026, which imposed broader export control rules on exports of dual-use items to Japan involving Japanese military end users, military end uses, and other end users/end uses that may contribute to enhancing Japan's military capabilities. With these
three regulatory measures now in effect concurrently, compliance standards applicable to China-based companies' exports to Japan have become materially more stringent, and regulatory scrutiny has tightened further. In this context, relevant companies face more severe compliance challenges and should strengthen compliance management to ensure that Japan-related export business is conducted in strict accordance with applicable laws and regulations.
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