MOFCOM BJT
Q: On June 29, 2026, MOFCOM released a restricted namelist and a watch list. What are the considerations behind this move?
A: On February 24, 2026, China added 20 Japanese entities, including Mitsubishi Heavy Industries Shipbuilding Co., to its Export Restricted Namelist, and another 20 Japanese entities, including SUBARU Corporation, to the watch list, to curb Japan’s attempts at “remilitarization” and possession of nuclear weapons. Regrettably, over time, the Japanese side instead of reflecting on and correcting its wrongdoings, has gone further down the wrong path, accelerating its neo-militarism and remilitarization, deploying offensive weapons, and launching offensive missiles overseas. In view of the above, in accordance with the Export Control Law of the People’s Republic of China, the Regulations of the People’s Republic of China on Export Control of Dual-Use Items, and other applicable laws and regulations, the Chinese side has decided to:
First, add 20 Japanese entities that participate in activities enhancing Japan’s military capabilities, including the National Institute for Defense Studies, to the restricted namelist. Once listed, they are mainly subject to the following two measures: Exporters are prohibited from exporting dual-use items to these entities, and overseas organizations and individuals are prohibited from transferring or providing dual-use items originating from the People’s Republic of China to these entities. All ongoing relevant activities shall cease immediately; and
Second, 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. Exporters may not apply for general licenses, or obtain export certificates by filling in information when exporting dual-use items to the listed entities. For individual licenses, exporters shall submit a risk assessment report of the listed entity and provide a written commitment that the duel-use items will not be used for any purpose that contributes to enhancing Japan’s military capabilities. The review period for such licenses is not subject to the time limits specified in Paragraph 1, Article 17 of the Regulations on Export Control of Dual-Use Items. MOFCOM will conduct stricter reviews of the end users and end uses for exported dual-use items involving entities on the watch list. Export applications involving Japanese military users, military uses, or any other end users and uses that may contribute to enhancing Japan’s military capabilities will not be approved. Entities on the watch list may apply for removal from the list after fulfilling relevant obligations in support of the review under Article 26 of the Regulations on Export Control of Dual-Use Items, and MOFCOM may remove them after verification.
These measures by China are entirely legitimate, justified, and lawful, and are intended to firmly stop the rise of Japanese neo-militarism. It is hoped that the Japanese side will turn back from the wrong path, correct its wrong practice, do serious soul-searching, and return to the right track. The listing in accordance with law by China targets only a small number of Japanese entities and the relevant measures apply solely to dual-use items. It will not affect normal economic and trade exchanges between China and Japan. Japanese entities that operate in good faith and comply with laws have absolutely nothing to worry about. (Released on June 29)