High-performance artificial intelligence (AI) semiconductors and advanced semiconductor manufacturing equipment, including lithography, etching, and deposition tools, will now require export licenses. To reduce administrative burdens on companies, the exporter declaration requirement has been eliminated.
The Ministry of Trade, Industry and Energy announced the implementation of revised regulations on strategic goods exports on September 1. This revision reflects changes to over 80 items and technologies agreed upon by four major international export control regimes: the Wassenaar Arrangement, the Australia Group, the Nuclear Suppliers Group, and the Missile Technology Control Regime. These regimes control the export of items and technologies that could potentially be used for weapons of mass destruction, missiles, and conventional arms. Member countries are required to incorporate agreed changes into their national laws annually.
In particular, there has been a recent trend of tightening controls on advanced dual-use items, such as semiconductors and biotechnology. In response, the Ministry has added high-performance AI integrated circuits and advanced semiconductor manufacturing equipment, which are controlled by the United States, the European Union, and Japan, to the list of strategic goods. The equipment includes lithography, etching, and deposition tools that meet certain criteria. Nucleic acid synthesis equipment has also been newly controlled.
Companies wishing to export these items must obtain export licenses from the Ministry starting today. If the items are classified as strategic goods, exporters must verify the item, end user, and intended use before export. Even non-strategic products may be subject to situational licensing if the exporter is aware or has reason to suspect they could be used for weapons of mass destruction.
Some control criteria have been relaxed or clarified. The control threshold for high-energy secondary batteries has been raised from over 350Wh per kg to over 500Wh. The term 'botulinum toxin' in the control list has been changed to 'botulinum neurotoxin.'
The Ministry will simplify the export license application process for companies. The previously required exporter declaration has been abolished, and the compliance obligations for exporters are now directly specified in the regulations. Forms for professional assessments, comprehensive export license applications, end-user declarations, and import purpose verification requests have also been improved for clarity.
The Ministry plans to inform industry associations about the revisions and will support companies in item classification and export licensing procedures through the Trade Security Management Agency's 'Export Control Issues Desk.'
* This article has been translated by AI.
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