On the Revision to the Application of Export Controls Dated August 7(Preliminary Report)
August 7, 2019
Center for Information on Security Trade Control(CISTEC)
1. Key points of the today’s revision to the application of export controls
Japan’s application of export controls has been revised today in accordance with therevised ordinance for excluding the ROK from the list of “white countries” (hereafterreferred to as the “Group A countries”), which was approved by the Cabinet on August 2
and promulgated today.
The key points of the update are as follows.
(1) Besides the three items (fluorinated polyimide, photoresists and hydrogen fluoride)that have been designated as requiring individual licenses for the export to theROK, no other items have been added as “controlled items the export of which
would require the individual license”.
(2) The ROK’s exclusion from the conventional list of “white countries” now renders
exporters unable to take advantage of the “general bulk export license,” but the“special general bulk export license” system (*1) may be used. The scope of items
that fall under the “special general bulk export license” is basically the same as the“general bulk export license.”(3) Even in cases where only the “special bulk export license”(*2) may be used forexports to other countries that are participants in the multilateral export control
regimes, the “special general bulk export license” may be used for exports of a large
number of item categories to the ROK.
*1 Special general bulk export license: A license that is granted to exporting companies which arejudged as implementing strict voluntary controls and may be used for exports to both “whitecountries” and non-white countries.
*2 Special bulk export license: A license that is granted to companies which export items to customers
with whom they have a continuous relationship (on the premise that strict voluntary controls areimplemented).

In sum, the ROK is removed from the list of white countries, but it is still entitled togreater preferential treatment compared to other countries that are participants in themultilateral export control regimes with regard to the application of export controls.

2. Details(Note): The English translation is omitted.
3. Examples of wrong reports by major media
Among the reports about the recent revision to the application of export controls bymajor media both in Japan and the ROK, some speculate that many other items will
require individual licenses in addition to the three items that have already been designated.
However, as mentioned above, the recent revision does not in fact designate any otheritems for individual license application.
Reports such as the following that have been circulated by major media in Japan
immediately following the official announcement of today’s revision to the application ofexport controls are grossly misleading. The first sentence of the below-mentioned report
is not described in the recent revision at all. The fact that the special general bulk export
license can be used for exports to the ROK has been expressly stated in the News Release
issued by METI on August 2, and has also been clarified in detail in the recent revision.
The second sentence of the below-mentioned report is apparently about the catch-all
control, however, as for the export of items outside the control list, license requirements
apply only in extremely limited instances where there is specific information that createscause for concern that the items may be used for the development of weapons of mass
destruction or for military purposes. This means that individual licenses will not berequired on a widespread basis.
[An example of misleading reports]:“On and after Aug. 28, exporting companies in Japan will be required to acquire
individual license per each export contract, in principle, to export items to ROK suchas machine tools and carbon fiber that are strictly regulated as items that present aconcern of being diverted for military purposes.
Furthermore, a wide range of item categories aside from foodstuffs and lumber may
also require individual licenses if METI judges that they may be used in weapons.”
This report has also been cited by overseas major media and has amplified a large
misunderstanding outside of Japan as well.
Media coverage that is based on extreme misunderstanding and misconception doesnothing but harm. It spreads unnecessary confusion and friction within the Japan-ROK
relationship as well as throughout the international community. Indeed, such reports arecreating unnecessary confusion in businesses between Japan and the ROK. Media
coverage based on accurate understanding of the facts is thus desired.
The site below provides materials that explain the various misunderstandings by themedia. Please refer to them.
♦ “On the Update of the Application of Export Controls to the Republic of Korea:
Interpretation Regarding the Implementation of Japan’s System of Export Controls”
http://www.cistec.or.jp/service/kankoku.html