China Adds 40 Japanese Firms to Export Control and Watch Lists

On February 24, 2026, China's Ministry of Commerce announced the inclusion of 20 Japanese entities on its export control list and an additional 20 entities on a watch list, citing national security and international non-proliferation obligations. The measures affect major corporations, including Mitsubishi Materials Corporation.

Under the Export Control Law of the People's Republic of China and the Regulations on Export Control of Dual-Use Items, China stated that the 20 entities on the export control list, involved in activities that enhance Japan's military capabilities, are now subject to strict restrictions. These measures include:

• A ban on exporting dual-use items to the listed entities, and a prohibition for foreign organizations and individuals from transferring or providing Chinese-origin dual-use items to them. Ongoing activities must cease immediately.

• In special cases, exporters may apply to the Ministry of Commerce for permission to proceed.

The export control list includes prominent companies such as:

1. Mitsubishi Heavy Industries Shipbuilding Co.

2. Mitsubishi Heavy Industries Aero Engines, Ltd.

3. Mitsubishi Heavy Industries Marine Machinery & Equipment Co., Ltd.

4. Kawasaki Heavy Industries Aerospace Systems Company

5. Fujitsu Defense & National Security, Ltd.

6. IHI Aerospace Co., Ltd.

7. NEC Aerospace Systems, Ltd.

8. Japan Marine United Corporation

9. National Defense Academy of Japan

10. Japan Aerospace Exploration Agency

Simultaneously, China added another 20 Japanese entities to a watch list due to uncertainty over the ultimate users and end-use of dual-use items. Exporters to these entities must submit detailed risk assessments and written commitments confirming that items will not be used to strengthen Japanese military capabilities. Standard licensing procedures may not apply, and review periods are not limited by normal regulatory deadlines.

The watch list includes:

1. SUBARU Corporation

2. FUJI Aerospace Technology Co., Ltd.

3. ENEOS Corporation

4. ITOCHU Aviation Co., Ltd.

5. Mitsubishi Materials Corporation

6. TDK Corporation

7. Mitsui Bussan Aerospace Co., Ltd.

8. Hino Motors, Ltd.

9. Nitto Denko Corporation

10. Nacalai Tesque, Inc.

The Ministry of Commerce emphasized that exports to military users or for military purposes will not be approved. Entities on the watch list may be removed after cooperating with verification procedures under Chinese regulations.

Both the export control and watch list measures are effective immediately upon announcement.