Guidance forInternational Students and Researchers on
Security Export Control
Simultaneous pursuit ofPreventing goods/technologies from its
conversion to military use andEnhancement of global collaboration

Office of Security Export Control
Kobe University

1. What is Security Export Control? ··················································································· P2
2. What is Legal Status of International Students and Researchers? ································· P4
3. What is Security Export Control Rule of Kobe University? ············································· P6

4. How to comply with Security Export Control Rule. ························································· P7

11. What is Security Export Control?
The purpose of this guidance is to explain Security Export Control in Kobe
University to international students and researchers. This guidance affords theperspective of Security Export Control, e.g. what, how and who is regulated fromviewpoint of international students and researchers.
In order to maintain both national and international peace and security, theJapanese Government strictly regulates not only weapons but also military-sensitive
goods and technologies that are convertible to military use. The Foreign Exchange
and Foreign Trade Act prohibits exporters or suppliers, including universities andindividual(s) regardless of Japanese and foreigners, from exporting any sensitive
goods and providing any sensitive technologies controlled by the list regulation
and/or catch-all regulation. Regulated export and supply is available only after
Government licence. Any export/supply of controlled goods or technologies without
licence constitutes a crime with legal penalty applied not only to individual(s) but also
to the university involved.
Any university has to comply carefully with the Foreign Exchange and Foreign
Trade Act in order to avoid possible “security holes” that could emerge as a result of
the university’s openness.
Kobe University declares to enhance its globalization complying with Security
Export Control. Therefore all members of Kobe University including international
students and researchers are required to act subject to the Foreign Exchange andForeign Trade Act.
Security Export Control is performed in two steps. The first step is List Control
while the second step is Catch-all Control.
1.List Control
Any sensitive goods and technologies are regulated subject to “List ofControlled Goods and Technologies” described in the next page.
2. Catch-all Control
Even though export of goods and supply of technologies are not controlled
by List Control, they shall be checked according to Catch-all Control procedure.
The purpose of Catch-all Control is to prevent diversion of sensitive goods
and technologies not controlled by List Control from civil use to military use bychecking its end-use, end-user, type of Weapon(s) of Mass Destruction (WMD)
or designated countries.
2

List of Controlled Goods and Technologies
Some goods may be controlled by more than one classification. For details or
the latest information on Security Export Control, visit the following METI website.
https://www.meti.go.jp/policy/anpo/englishpage.html
Examples in the following list only show the broad concept of controlled goods
and technologies. Belonging to any category of the list does not decisively mean toconstitute “controlled”. Therefore it is necessary to judge if the specific goods ortechnologies satisfy or not the detailed specifications in the list.
Export Licence Controlled Goods/Technologies
Classifications

Examples

1. Weapon

Firearm, Explosive, Military equipment, Bacterial agent, Biopolymer,
Biocatalyst, DNA, Vector, Virus etc.

2. Atomic energy(Nuclear weapon)

Nuclear fuel, Reactor, Radioactive substance, Numerical control
machine, Oscillator, Nuclear-related equipment etc.

3. Chemical weapon

Raw material/equipment for production of chemical weapon

3-2. Biological weapon(BW)

Organism/toxin/gene usable for BW, Virus, Bacillus, DNA,
Equipment for production of BW etc.

4. Missile

Rocket, Unmanned aerial vehicle (UAV), Propellant, Engine,
Composite, Equipment for production/test/guidance/control ofrocket/UAV, Flight controller etc.

5. Advanced material

Fluorine compound, Definitive polymer, Definitive alloy, Composite,
Organic fiber, Carbon fiber etc.

6. Material processing/manufacturing

Bearing, Robot, Machine tool/component/controller forcoating/measuring/feedback equipment etc.

7. Electronics

IC, LSI, Power device, Semiconductor substrate, Microwave, Solar
battery, Magnetic recorder, Signal analyzer, Oscilloscope, Signal
generator etc.

8. Computer

Computer, Printer, HDD, Component/accessory

9.Telecommunications/Information security

Transmission equipment, Electronic changer, Phased array
antenna, Encryption/jamming equipment etc.

10. Sensor/Laser

Optical detector, Camera, Laser oscillator, Radar etc.

11. Navigation/Avionics

Accelerator, Gyroscope, Inertial navigation system etc.

12. Marine

Submersible/hydrofoil vessel, Salvage system, Underwater
robot/vision system, Sonar navigation etc.

13. Propulsion system

Space vehicle, Gas turbine engine, Satellite etc.

14. Miscellaneous

Powder metal fuel, Diesel engine, Robot, Controller, Tear gas,
Explosive detection equipment etc.

15. Sensitive
goods/equipment

Inorganic fiber, Conductive polymer, Digital transmitter, Radar,Engine etc.

3

2. What is Legal Status of International
Students and Researchers?
Regardless of Resident or Non-Resident, when you send/carry sensitive goods to foreigncountries or provide sensitive technologies to Non-Residents or Residents belonging to a
specific category (see the following) in Japan or elsewhere, you are requested to consult youradvising professors or the like whether or not such actions have legal problem of Security
Export Control.

What is Resident and Non-Resident?
Each member of Kobe University is requested to recognize the transition of
his/her legal status, e.g. “Resident or Non-Resident”, subject to the Foreign
Exchange and Foreign Trade Act in Japan. “Resident or Non-Resident” does notdepend on nationality but is defined as follows.
A Non-Resident is an individual staying in Japan for less than 6 months, while
Resident is an individual residing in Japan for more than 6 months.
Resident status will change into Non-Resident if you are staying abroad formore than 2 years. If you, as Resident, stay abroad for study or research keeping
your residence in Japan, you are still classified as Resident.
A Resident belonging to a specific category is a person to which one of the following
definitions apply;(1) Person under the control of a foreign government, corporation or university by contract,(2) Person under the control of a foreign government by economic interests, or(3) Person under the instruction of a foreign government.

(a) International Student
If you stay in Japan for less than 6 months, you are classified as Non-Resident,
who is in a position of receiving goods and technologies from Resident. Exporting or
supplying sensitive goods/technologies received in Japan is under strict regulations.
If you stay for more than 6 months, you are classified as Resident (or Resident belonging
to a specific category for some international students). It is also under strict regulations toexport of provide sensitive goods/technologies. If you work in Japan after your graduation,
you will be classified as Resident (or Resident belonging to a specific category in somecases). After your graduation, your action will be regulated subject to the Foreign Exchange
and Foreign Trade Act while the University Rule ceases to apply.

(b) International Researcher
If you don’t have an employment relationship, your legal status is the same asthat of (a).
If you have an employment relationship with Kobe University, you are classified
as Resident (or Resident belonging to a specific category in some cases) as of hire date.
Necessary procedure for Security Export Control is the same as (c).

(c) Foreign Professor
You are classified as Resident (or Resident belonging to a specific category in somecases) as of hire date.
When you export sensitive goods or provide sensitive technologies to NonResidents, please consult with Security Export Control Advisor through theadministrative office of your graduate schools, institutes or centers.

4

Table of Legal Status
Classifications
JapanesecitizenResident
1) lives in Japan2) works for a
Japanese
Embassy/
ConsulateabroadNon- Resident
1) has left Japan to work for an office in aforeign country and stays in a foreigncountry2) has left Japan to stay in a foreigncountry for 2 years or longer and stays
in a foreign country3) stays in a foreign country for 2 years or
longer since leaving Japan4) falls under the aforementioned 1) to
3), temporarily returns to Japan andstays in Japan for less than 6 months

Alien1) works for an
office in Japan2) stays in Japanfor more than 6months after
entry into Japan

Corporation

1) lives in a foreign country2) engages in official tasks of a foreign
government or an internationalorganization
3) is a diplomat, consular, or attache orservant of a diplomat or consular(However, needs to be appointed or hired
in a foreign country)

1) a Japanese firm
located in Japan1) a foreign firm located in a foreigncountry2) a foreign firm's
branch office,local office orother officelocated in Japan2) a Japanese firm's branch office, local
office or other office located in a foreigncountry3) a foreign Embassy/Consulate located inJapan3) Japanese
Embassy/
Consulateabroad5

3. What is Security Export Control Rule of
Kobe University?
Security Export Control Rule is included in Rules and Regulations of Kobe
University.
The following actions are controlled subject to security regulations:
1) send/carry sensitive goods or technologies to foreign countries including
your home country; or2) supply sensitive technologies to Non-Resident and Resident belonging to a
specific category in any country including Japan.
While you are a student in Kobe University, you have to consult your advisingprofessor or the like prior to the export of sensitive goods or the supply of sensitivetechnologies related to activity in Kobe University. The professor will check according
to the Prior-Check Flowchart. Based on its result, if necessary, Security Export
Control Office will judge whether or not the export licence is required.

Framework of Security Export Control
at Kobe University

President
2nd Examination

recheck

reportOffice ofSecurity Export Control
noticereport
1st Examination

Administrative Office ofGraduate Schools,
Institutes and Centers
noticesubmission
Prior-Check

review/judge

review/judge

check

Advising Professor
noticeconsult

International Students and Researchers64. How to comply with Security Export
Control Rule at Kobe University?
Typical goods and technologies are exemplified as follows:
Goods (Items)• Equipment, sample, prototype and specially designed component oraccessories for the equipment
Technologies (Service)• Information, data, know-how, manuale.g. HDD, flash memory, software program for developing/improving fordesign or evaluation, manufacturing know-how, quality assessment data,
user manual, blueprint, specifications, technical guidance and operational
know-how
Typical actions controlled are exemplified as follows:
Export• Sending goods or taking goods with you abroad (including bringing back fromabroad)Supply• Oral transfer by phone, sending by e-mail, paper, CD-ROM, flash memory andother storage media, disclosure at a private gathering or discussion, disclosure
to visitors during a tour of the facility.
• Presentation at the open conference and disclosure in journal papers are NOT
regulated, even if providing sensitive technologies EXCEPT severely sensitive
ones (e.g. nuclear weapons.)• The difference between the above two cases is that, in the former therecipient(s) is definite, while in the latter the recipients are indefinite.
What to do?
① Please check each sensitive goods/technologies according to Prior-Check
Flowchart on page 8 with your advising professor or the like.
② Personal belongings not related to the activity of the university are exemptedfrom the rules of the university. However, you should comply with the regulations
under the Foreign Exchange and Foreign Trade Act.

7

Prior-Check FlowchartA)
Providingtechnologies to NonResident

B)
Accepting aninternational student,
researcher or a visitor

C)
Taking or sending
goods abroad

Submitting a paper; orGiving a presentation
at a conference/public
symposium etc.

He/she is employed by afirm/institution in Japan;orhas been staying inJapan for more than 6monthsTaking a laptop
computer, which isavailable on the
consumer market, out of
the country for self-use
and returning with it

Yes

No

No

Yes
Providingundisclosed databy e-mail etc.;
orDiscussing on
undisclosed dataetc.;
orProvidingundisclosed data tooverseas
researchers
No

Yes

Disclosure
to theindefinite
recipientsNo

Check completed

No

Providing undisclosed dataor exhibiting undisclosed
laboratory etc.
No

Yes

Technology is alreadypublicly known;orTechnology is for patentapplication only;or
Research is in the basic
science fields(researching principles
of phenomena in naturalscience fields throughtheories or experiments)③

Ask youradvising
professor
Nofor further
procedures

Yes

Yes

①

Yes

②

Consult Security Export Control
Advisor through your advisingprofessor8Frequently Asked and Answered Questions*Answer to personnel not hired by Kobe University

Q1 - What are the points to consider when taking a laptop computer or a massstorage device such as a USB abroad?
A1 - When you are only taking the laptop computer or a USB for self-use and notproviding technologies, such actions are not regulated. However if thetechnologies are provided to an end-user who intends to use the technologies todevelop WMD, you have to consult your advising professor to obtain a licence.
Q2 - What are the points to consider when taking sensitive goods abroad?
A2 - When taking sensitive goods (trial sample, chemical substance, apparatus
and sample of bacillus/bacterium etc.) listed as Export Licence Controlled Goods(see page 3), a licence may be required even if there is no plan to provide themto anyone. Please consult with your advising professor for Prior-Check to clarify
whether export of such goods is controlled or not.
Q3 - What are the points to consider when giving a presentation at an academic
conference?
A3 - Academic conferences and the like, which are open to the general public,
qualify for licence exceptions. However, presentations at closed meetings andpersonal information exchanges at receptions do not qualify for exception.
Q4 - My research area is indicated in the List of Controlled Goods andTechnologies as requiring a licence. Would I need a licence to send a relatedscientific information by e-mail or telephone conversation to my colleague in myhome institution?
A4 - Yes. Transmitting regulated technologies by e-mail, websites or phone to
Non-Resident may require a licence. Please consult with your advising professor
for further procedure.

9Frequently Asked and Answered Questions*Answer to personnel not hired by Kobe University

Q5 -The manufacturer of the goods I plan to take abroad tells me that it is incompliance with Foreign Exchange and Foreign Trade Act. Can I skip theprocess of consultation with my advising professor?
A5 - It is the responsibility of the University to determine whether or not the
goods are controlled. Please consult with your advising professor in order toreceive confirmation document from the manufacturer stating that the goods are
not controlled.
Q6 - Whom should I ask if I think Security Export Control Rule may apply to myfuture action?
A6 - If you suspect your actions may be controlled by Security Export Control
Rule, please consult your advising professor first. Consultation with Security
Export Control Advisor is available through your advising professor.
Q7 - What are the points to consider when temporarily going back to my homecountry?
A7 - If you return to your home country keeping your residence in Japan, yourstatus Resident/Non-Resident will remain unchanged. You are requested not toprovide any sensitive technologies to Non-Resident wherever such supply isdone. Please note that the goods which not related to the activities of theuniversity, such as souvenirs or personal belongings, are exempted fromSecurity Export Control Rule of Kobe University. Therefore you should
individually follow the regulations under the Foreign Exchange and Foreign
Trade Act .
Q8 - Approximately how long does it take to obtain a licence for regulatedsensitive goods or technologies?
A8 - It takes basically 90 days after the submission of the licence application. It
may be necessary to obtain the licence beyond 90 days in the complicated case.
You had better consult your advising professor well in advance.

10Concept of Security Export Control
in Kobe University (6S)

Suitable for Kobe University
Simple Procedure
Satisfactory Legal Requirements
Self Check First
Supervised by Expert& Sustainable Management

Office of Security Export Control
Kobe University

1-1 Rokkodai-cho, Nada-ku, Kobe 657-8501 JAPANphone: +81-78-803-6682/6690
e-mail: osec-anzen@office.kobe-u.ac.jp
https://www.kobe-u.ac.jp/en/index.html
3rd edition (October 2022)