South Korea MOTIE 31st Strategic Items Notice adds 741 Russia/Belarus situational-licence items

Mechanism

A situational licence (상황허가) makes a government export licence necessary for non-strategic goods judged likely to be diverted to military use. MOTIE pre-announced the 31st amendment of the Strategic Items Export-Import Notice on 24 February 2023 (public comment 2/24-3/16), adding 741 items to the Russia/Belarus-specific situational-licence annex across industrial machinery, petroleum/gas refining equipment, steel, chemicals, automotive goods and quantum computers. The finalised notice was announced 24 April 2023 and took effect 28 April 2023. MOTIE framed the amendment as bringing Korea's Russia/Belarus export-control perimeter closer to US/EU/Japan levels, incorporating 2022 international export-control-regime agreements and reflecting the bulk of the US's 2nd-6th Russia sanctions packages and EU sanctions.

Severity basis

741 items added in one amendment to a single country-pair situational-licence annex is a large, quantified expansion of licence-gated trade — comparable in scale to the 682-item 33rd notice (Feb 2024) and larger than the 243-item 35th notice (Sept 2024), both already in the register. Severity 3 (rather than higher) reflects that these are situational- rather than absolute-prohibition items and that the release discloses no affected-trade-value figure, only the item count.

Downstream implications

• Korean exporters of industrial machinery, refining equipment, steel,

chemicals, automotive goods and quantum-computing hardware face licence review or in-principle prohibition on shipments to Russia and Belarus.

• Sets the pre-2023 baseline that the later 33rd (Feb 2024, +682) and 35th

(Sept 2024, +243) notices build on — the Russia/Belarus situational-licence list's growth path now has three dated points in the register.

Open questions

• The finalised (post-comment) 31st notice's own implementation press

release URL was not independently confirmed — this citation is the pre-announcement (행정예고) reference material, which states the same 741-item content; the announced/effective dates come from GTA and corroborating search results, not from a directly fetched final-notice page.

• No pre-amendment / post-amendment total list count was confirmed for this

notice specifically (unlike the 33rd and 35th filings) — omitted rather than guessed.