MOFCOM Announcement No. 1 (2026) strengthens dual-use export controls to Japan (end-use/end-user restrictions; extraterritorial liability)

MOFCOM Announcement No. 1 (2026) announces strengthened export controls on dual-use items destined for Japan. The measure prohibits exports of dual-use items to Japan for military end users, military end use, and other end users/end uses that help enhance Japan’s military capability. It also asserts liability for any organization/person in any country/region that transfers PRC-origin dual-use items to Japanese entities in violation. For PRC critical minerals compliance programs, this increases required end-use/end-user screening and diversion risk management for shipments involving Japan where controlled or potentially dual-use mineral products (including rare-earth/critical-mineral related items) may be implicated under PRC export control frameworks.