China: Ministry of Commerce adopted export control concern list including 20 Japanese entities under enhanced dual-use export scrutiny (Announcement No. 12 of 2026)

On 24 February 2026, the Ministry of Commerce (MOFCOM) adopted Announcement No. 12 of 2026, adding 20 Japanese entities to the export control concern list due to the inability to verify the end users and end uses of dual-use items. Listed entities, including Subaru Corporation and TDK Corporation, are subject to stricter export procedures. Export operators may not apply for general licences or obtain export certificates through information registration mechanisms. For individual licence applications, exporters must submit a risk assessment report and provide a written commitment that the dual-use items will not be used for military purposes or otherwise contribute to enhancing Japan’s military capabilities. MOFCOM will conduct enhanced scrutiny of end users and end uses, and exports involving Japanese military end users, military end uses, or other uses supporting military capability will not be approved. The statutory review period under the Dual-Use Export Control Regulations does not apply to such licence applications. Entities may apply for removal from the concern list after fulfilling cooperation and verification obligations under the applicable regulations. The Announcement entered into force on the date of publication.