On January 6, 2026, China’s Ministry of Commerce (“MOFCOM”) issued Announcement No. 1 [2026], imposing export controls on dual-use items destined for Japan. The measures took effect immediately, with no wind-down period.

Under the announcement, exports of all dual-use items from China are prohibited where the end user or end use: (i) involves Japanese military users; (ii) supports military end uses; or (iii) otherwise contributes to enhancing Japan’s military capabilities.

The announcement represents a further escalation in China’s use of export controls as a policy tool amid recent heightened tensions with Japan. Several aspects of the measures merit close attention from companies engaged in China-related supply chains.

First, the scope of the restrictions is intentionally broad. The inclusion of end users or end uses that could enhance Japan’s military capabilities expands the controls beyond traditional defense recipients. As a result, exports previously viewed as commercial or civilian in nature may now warrant additional scrutiny.

Second, companies should expect MOFCOM to increase its focus on end-use and end-user due diligence for exports involving Japan. Requests for more detailed certifications, supporting documentation, and transaction-level explanations are likely moving forward. Given the policy sensitivity and ambiguity surrounding the new criteria, exporters should also anticipate longer license review timelines and potential follow-up inquiries.

Third, the scope is not limited to direct exports from China to Japan. The controls also apply extraterritorially, covering transfers of Chinese-origin dual-use items through third countries, as well as in-country transfers, where the end users or end uses fall within the scope of these controls.

Crowell & Moring will continue to monitor developments related to Chinese export controls and their potential impact to industry.