Since the beginning of 2026, China's Ministry of Commerce has issued a series of announcements, establishing a comprehensive, closed-loop system covering "principle-based control" and "entity-based control" for the export of dual-use items to Japan. A total of 40 Japanese entities have been placed on either the restricted list or the watch list under the system. This move, introduced in accordance with Chinese law, is a legitimate, reasonable and lawful response to Japan's dangerous acts in recent years, including attempting to revise its pacifist constitution, advancing remilitarization and interfering in China's internal affairs. It demonstrates China's firm resolve to safeguard national sovereignty, security and development interests.

China's export control measures against Japan rest on a solid legal basis.

In terms of domestic law, the measures strictly follow China's Export Control Law and relevant requirements of the Regulations on the Export Control of Dual-Use Items, and they are adopted after going through comprehensive risk assessment and rigorous procedural review. Announcement No. 1 issued on Jan 6 established the general principle: a ban on exporting all dualuse items to Japanese military end-users, and for end uses or any purpose that could enhance Japan's military capabilities. Announcements No. 11 and No. 12 issued on Feb 24 identified specific entities, turning a broad policy into targeted actions.

In terms of international law, the measures are concrete steps to fulfill China's non-proliferation obligations under the Treaty on the Non-Proliferation of Nuclear Weapons. They are a direct response to Japan's recent radical moves to relax its export of lethal weapons, and revise the constitution for military buildup, as well as the provocative remarks on China's Taiwan, all of which have severely undermined the regional security architecture. By adopting export control measures to prevent dual-use items from flowing into Japan's military sector, China is not only safeguarding its own security but also fulfilling its international responsibility to uphold regional peace and stability.

It is worth noting that the control measures include a delisting mechanism. In accordance with the Regulations on the Export Control of Dual-Use Items, relevant entities may apply for delisting from the restricted list and the watch list if they cooperate with investigations and cease their illegal acts.

The control measures, featuring precise identification and tiered control, seek to strike a balance between security and trade order.

The 20 entities on the restricted list had undergone strict screening before they were identified as core players directly engaged in Japan's defense industry and weapons production. They cover the key links along the entire military industrial chain. Among them, Mitsubishi Heavy Industries Shipbuilding and Kawasaki Heavy Industries are the main builders of submarines used by the Japanese Self-Defense Forces, while Fujitsu, as one of Japan's largest IT enterprises, has long aided Japan's Self-Defense Forces in software development and hardware R & D services. Imposing control on them will strike right at the heart of Japan's military industry expansion.

The 20 entities on the watch list were designated because their end-users and the end-uses cannot be verified and are thus subject to differentiated measures. They are denied access to facilitation measures such as general license, and must file risk assessment reports and non-military use commitments when applying for individual licenses. In addition, they will also go through more stringent reviews on end users and end uses. This prudent and tiered control approach can effectively prevent dual-use items from being diverted for military purposes, and at the same time keep the channel open for normal economic and trade exchanges by compliant enterprises. Meanwhile, with clearly defined boundaries, these measures target only dual-use items and specific risk entities, without affecting normal China-Japan economic and trade cooperation in the civilian sector and the global industry and supply chains. They strike a good balance between security and openness.

The export control measures have formed a whole-process closed-loop management system where red lines are drawn beforehand, strict reviews are conducted during the process, and accountability through traceability is ensured afterwards. This endows the system with strong efficiency and deterrence.

In terms of policy coordination, the principled announcement of Jan 6 and the announcement on entity lists of Feb 24 are mutually reinforcing. The former provides a macro-level regulation covering all military end-uses, while the latter ensures micro-level precision by identifying specific violators. This creates a comprehensive net: even entities not on the lists still need to comply with the principle if their activities are anyhow military-related. In terms of enforcement, cooperation related to entities on the control list must be immediately suspended, and overseas organizations and individuals are not allowed to transfer or provide dual-use items originating from China to them, forming synergy in supervision at home and abroad. The market has responded accordingly — following the announcements, the stock prices of Japan's defense sector fluctuated sharply, and those of military enterprises such as IHI and Kawasaki Heavy Industries slumped, demonstrating the strong deterrent effect of the measures.

In the long run, the export control measures are not only a powerful move to curb Japan's dangerous attempt at remilitarization, but also an important step to institutionalize and normalize China's export control system. China is committed to peaceful development. If Japan truly hopes to bring China-Japan relations back to the track of sound development, it must take China's concerns seriously, stop military expansion and provocation on issues such as the Taiwan question, honor its commitments under the pacifist constitution, and take concrete actions to safeguard China-Japan relations and regional peace and stability.

The author is an associate researcher at the Institute of Trade and Investment Security, Chinese Academy of International Trade and Economic Cooperation, Ministry of Commerce.

The views don't necessarily reflect those of China Daily.

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