China has announced stricter export control measures on dual-use items exported to Japan, reinforcing its national security framework and international non-proliferation commitments.

The measures were formally issued by the Ministry of Commerce of the People’s Republic of China (MOFCOM) through Announcement No. 1 of 2026, published on January 6, 2026.

Scope of the New Export Control Measures

Under the announcement, China will tighten oversight of dual-use items—products and technologies with both civilian and military applications—when exported to Japan.

The regulation explicitly restricts exports involving:

  • Japanese military users
  • Military end-uses
  • End users or purposes that may enhance Japan’s military capabilities

These controls apply regardless of whether the exporter is located inside or outside China.

Legal Basis and Regulatory Authority

The announcement is issued in accordance with:

  • The Export Control Law of the People’s Republic of China
  • Relevant administrative regulations on export control of dual-use items

MOFCOM emphasized that any organization or individual violating these requirements may face legal liability under Chinese law, including those engaged in indirect transfers or re-exports.

Immediate Implementation

The strengthened export controls took effect immediately on January 6, 2026. Companies involved in the manufacture, trade, or transfer of controlled dual-use items must ensure compliance without transition periods.

Policy Rationale and Strategic Context

According to MOFCOM, the measures aim to:

  • Safeguard China’s national security and development interests
  • Fulfil international non-proliferation obligations
  • Prevent sensitive technologies from being used for military escalation

The announcement reflects China’s broader use of export control mechanisms as part of its strategic and security policy framework.

Implications for Businesses and Supply Chains

Companies engaged in cross-border trade involving dual-use goods, components, software, or technologies should:

  • Re-evaluate export screening and end-use verification procedures
  • Strengthen compliance checks for Japan-related transactions
  • Monitor future updates to China’s export control catalogues and enforcement practices

Source: China Tightens Exports to Japan

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