China places 20 Japanese entities on export control watch list

China's Ministry of Commerce announced on June 29 that it has added 20 Japanese entities to a watchlist for dual-use items, effective immediately. The move follows the Ministry's inability to verify the end-users and end-uses of dual-use items involving these entities, including Mitsui E&S Co., Ltd. and others.

Under the new measures, export operators shipping dual-use items to the listed entities are prohibited from applying for general export licenses or obtaining export clearance through registered declaration filings. For individual license applications, exporters must submit a risk assessment report on the listed entity and provide a written commitment that the dual-use items will not be used in any manner that contributes to enhancing Japan's military capabilities. Additionally, the review period for such license applications is not subject to the time limits stipulated in Article 17, Paragraph 1 of the PRC Export Control Law on Dual-Use Items.

The Ministry will subject exports of dual-use items to listed entities to stricter end-user and end-use verification procedures. Export applications involving Japanese military end-users, military end-uses, or any other end-uses that could enhance Japan's military capabilities will not be approved.

Entities included on the watchlist may apply for removal under Article 26 of the PRC Export Control Law on Dual-Use Items, provided they fulfill their cooperation obligations in relation to compliance verification. Upon verification, the Ministry may remove them from the list.

The entities placed on the watch list include MITSUI E&S Co., Ltd., Mitsui Bussan Aerospace Co., Ltd. Maintenance Center, Terra Drone Corporation, ACSL Ltd., Mitsubishi Nuclear Fuel Co., Ltd., Japan Nuclear Fuel Limited, Fujitsu Network Solutions Limited, Hitachi Advanced Systems Corporation, Komatsu Industries Corporation, Komatsu NTC Ltd., OKI Electric Industry Co., Ltd., OKI Com-Echoes Co., Ltd., OKI Circuit Technology Co., Ltd.,OKI Nextech Co., Ltd., OKI Engineering Co., Ltd., YDK Technologies Co., Ltd., Nihon Denji Sokki Co., Ltd, Howa Machinery, Ltd., Hosoya Pyro-Engineering Co., Ltd. and The Fujikura Parachute Co., Ltd.