China’s Ministry of Commerce said on June 29 that it had added 20 Japanese entities to an export control list and another 20 to a watch list for dual-use trade, with both measures taking effect immediately.
Under Announcement No. 27, Chinese exporters are barred from exporting dual-use items to the 20 listed entities, and overseas organizations and individuals are barred from transferring or providing China-origin dual-use items to those entities. Applications may still be submitted to the ministry in special cases.
The control-list entities include the National Institute for Defense Studies, the Ground Systems Research Center, the Naval Systems Research Center, the Air Systems Research Center, Mitsubishi Electric Defense and Space Technologies Corporation, Mitsubishi Electric Software Corporation, Mitsubishi Precision Company, several Mitsubishi Heavy Industries units, NIPPI Corporation and Aoki Seimitsu Kogyo.
Under Announcement No. 28, exports of dual-use items to the 20 watch-list entities cannot use general licenses or registration-based export documentation, and single-case license applications must include a risk assessment report and a written undertaking on end use. The ministry said these cases will face stricter end-user and end-use review, and the usual review time limit will not apply. Watch-list entities include MITSUI E&S, Mitsui Bussan Aerospace’s maintenance center, Terra Drone, ACSL, Mitsubishi Nuclear Fuel, Japan Nuclear Fuel, Fujitsu Network Solutions, Hitachi Advanced Systems, Komatsu Industries, OKI Electric and Howa Machinery. The ministry also said entities on the watch list may apply for removal after cooperating with verification procedures. The June 29 actions follow China’s January 6 restrictions on exports of dual-use items to Japanese military users or for military-related end uses and a February 24 round that placed 20 Japanese entities on the export control list and 20 on the watch list.