According to the official website of the Ministry of Commerce of the People’s Republic of China, on February 24, the Ministry of Commerce issued Announcement No. 11 of 2026, adding 20 Japanese entities to the export control list, which will take effect from the date of the announcement.
According to the announcement, in accordance with the relevant provisions of the Export Control Law of the People’s Republic of China, the Regulations of the People’s Republic of China on Export Control of Dual-Use Items, and other laws and regulations, and for the purposes of safeguarding national security and interests and fulfilling international obligations such as non-proliferation, it is decided to place 20 Japanese entities, including Mitsubishi Shipbuilding Co., Ltd., which are involved in enhancing Japan’s military capabilities, on the export control list, and impose the following measures:
I. Exporters are prohibited from exporting dual-use items to the aforementioned 20 entities, and foreign organizations and individuals are prohibited from transferring or providing dual-use items originating in the People’s Republic of China to the aforementioned 20 entities; any ongoing related activities must cease immediately. II. In special circumstances where export is truly necessary, exporters must submit an application to the Ministry of Commerce.
The Ministry of Commerce’s list of companies subject to export controls includes several shipbuilding and marine enterprises, such as Mitsubishi Heavy Industries Shipbuilding Co., Mitsubishi Heavy Industries Marine Machinery & Equipment Co., Ltd., Mitsubishi Heavy Industries Maritime Systems, Ltd., IHI Power Systems Co., Ltd., and Japan Marine United Corporation.
Export Control List, From February 24, 2026
- Mitsubishi Heavy Industries Shipbuilding Co., Ltd.
- Mitsubishi Heavy Industries Aero Engines, Ltd.
- Mitsubishi Heavy Industries Marine Machinery & Equipment Co., Ltd.
- Mitsubishi Heavy Industries Engine & Turbocharger, Ltd.
- Mitsubishi Heavy Industries Maritime Systems, Ltd.
- Kawasaki Heavy Industries Aerospace Systems Company
- Kawaju Gifu Engineering Co., Ltd.
- Fujitsu Defense & National Security, Ltd.
- IHI Power Systems Co., Ltd.
- IHI Master Metal Co., Ltd.
- IHI Jet Service Co., Ltd.
- IHI Aerospace Co., Ltd.
- IHI Aero Manufacturing Co., Ltd.
- IHI Aerospace Engineering Co., Ltd.
- NEC Aerospace Systems, Ltd.
- Japan Marine United Corporation
- JMU Defense Systems Co., Ltd.
- National Defense Academy of Japan
- Japan Aerospace Exploration Agency
On the same day, the Ministry of Commerce issued Announcement No. 12 of 2026, adding 20 Japanese entities to the list of entities under watch, effective from the date of the announcement.
The announcement disclosed that, in accordance with the relevant provisions of the Export Control Law of the People’s Republic of China and the Regulations on Export Control of Dual-Use Items of the People’s Republic of China, it has been decided to include 20 Japanese entities, including SUBARU Corporation, whose end users and end uses of dual-use items cannot be verified, in the list of entities under watch.
Exporters exporting dual-use items to the aforementioned entities may not apply for a general license or obtain export certificates through registration and information filing. When applying for a single license, they must submit a risk assessment report on the entities on the watch list and provide a written commitment that the dual-use items will not be used for any purpose that would enhance Japan’s military strength. The license review period is not subject to the time limit stipulated in Article 17, Paragraph 1 of the “Regulations of the People’s Republic of China on the Export Control of Dual-Use Items”.
The Ministry of Commerce will implement stricter end-user and end-use reviews on exports of dual-use items by entities on the watch list. Exports involving Japanese military users, military uses, and any other end-user uses that contribute to enhancing Japan’s military strength will not be approved.
Entities on Watch List From February 24, 2026
- SUBARU Corporation
- FUJI Aerospace Technology Co., Ltd.
- ENEOS Corporation
- Yusoki Co., Ltd.
- ITOCHU Aviation Co., Ltd.
- Leda Group Holdings Co., Ltd.
- Institute of Science Tokyo
- Mitsubishi Materials Corporation
- ASPP Co., Ltd.
- Yashima Denki Co., Ltd.
- Sumitomo Heavy Industries, Ltd.
- TDK Corporation
- Mitsui Bussan Aerospace Co., Ltd.
- Hino Motors, Ltd.
- Tokin Corporation
- Nissin Electric Co., Ltd.
- Sun Tectro Co., Ltd.
- Nitto Denko Corporation
- NOF Corporation