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On January 6, 2026, the Ministry of Commerce of the People's Republic of China (MOFCOM) issued Announcement No. 1 of 2026, formally declaring strengthened export control measures regarding dual-use items destined for Japan. Effective immediately upon its release, the announcement mandates a prohibition on the export of all dual-use items to Japanese military end-users, for military end-uses, or for any other purposes that contribute to the enhancement of Japan's military capabilities.
The MOFCOM cited the Export Control Law of the People's Republic of China and related regulations as the legal basis for this action. According to the announcement, the decision to tighten controls was made to safeguard national security and interests, as well as to fulfill international obligations regarding non-proliferation.
Scope of Prohibitions
The announcement explicitly bans the export of all dual-use items under the following conditions:
Exports destined for Japanese military users;
Exports intended for Japanese military purposes;
Exports to any other end-users or for end-uses that assist in improving Japan's military strength.
It did not name specific enterprises or individuals subject to the ban. The newest control list, namely Catalogue of Dual-use Items and Technologies Subject to Import and Export Licensing (2026), took effect from January 2026, covering rare earth metals, minerals, nuclear items and related technologies, etc.
Third-Party Liability and Re-export Restrictions
The announcement includes provisions regarding the transfer of controlled goods through third parties. MOFCOM stated that organizations and individuals in any country or region will be held legally liable if they violate these regulations by transferring or providing dual-use items originating from the People's Republic of China to Japanese organizations or individuals. This clause signals strict enforcement regarding the re-export or transshipment of Chinese-origin dual-use items to Japan.
These measures were officially implemented on January 6, 2026. Companies involved in the trade of dual-use items originating from China are expected to comply with these restrictions immediately to avoid legal repercussions.
