China Strengthens Export Controls on Dual-Use Items to Japan

The Ministry of Commerce of the People’s Republic of China has issued Announcement No. 1 of 2026, effective immediately, to strengthen export controls on dual-use items destined for Japan. This measure is aimed at safeguarding national security, protecting national interests and fulfilling international obligations such as nonproliferation.

Key Provisions

• Scope of Restriction:
  All dual-use items are prohibited from being exported to:
  • Japanese military users, for military purposes; and
  • Any end-user applications that contribute to Japan’s military capabilities
• Third-Party Liability:
  Organizations and individuals in any country or region that transfer or provide dual-use items originating in China to Japan in violation of these provisions will be held legally responsible under Chinese law.
• Effective Date:
  This announcement is effective Jan. 6, 2026.

Japanese Reaction

• As a reaction to China’s announcement, Japan has filed a formal protest with the Chinese Embassy in Tokyo. Japan claims that the Chinese action targets only Japan – deviating from international practice – and demands that the Chinese action be withdrawn.

Implications for Businesses

• Companies engaged in the export of dual-use items should immediately review their compliance programs to ensure adherence to these new restrictions.
• Supply chain partners should be notified to prevent indirect transfers to prohibited end users in Japan.
• Violations may result in significant legal consequences under China’s Export Control Law.

For further details or assistance in assessing the impact of these measures on your operations, please contact our Global Risk, Trade and Investment team.

THIS DOCUMENT IS INTENDED TO PROVIDE YOU WITH GENERAL INFORMATION REGARDING CHINESE EXPORT RESTRICTIONS ON JAPAN. THE CONTENTS OF THIS DOCUMENT ARE NOT INTENDED TO PROVIDE SPECIFIC LEGAL ADVICE. IF YOU HAVE ANY QUESTIONS ABOUT THE CONTENTS OF THIS DOCUMENT OR IF YOU NEED LEGAL ADVICE AS TO AN ISSUE, PLEASE CONTACT THE ATTORNEYS LISTED OR YOUR REGULAR BROWNSTEIN HYATT FARBER SCHRECK, LLP ATTORNEY. THIS COMMUNICATION MAY BE CONSIDERED ADVERTISING IN SOME JURISDICTIONS.