Japan METI revises Foreign End-User List — 92 entities added, 5 removed under catch-all export controls

Mechanism

The Foreign End-User List is a non-binding reference list (not an embargo list) that METI publishes to give exporters concrete notice of foreign organisations for which concern about involvement in WMD, missile, or (as of this revision) conventional-weapons development cannot be excluded. Under Japan's catch-all export-control regime (Foreign Exchange and Foreign Trade Act, FEFTA), an exporter shipping goods to a listed entity must apply for a METI export licence unless it is evident the goods will not be used for such development — mirroring the "informed"/"known" triggers in the catch-all framework that METI's broader FEFTA overhaul restructured for the same 9 October 2025 effective date (see 2025-10-09-japan-meti-fefta-catch-all-controls-overhaul).

This revision is the first to add entities flagged specifically for conventional-weapons (rather than only WMD/missile) development concerns, following the conventional-weapons supplementary export-control review that took effect the same day. Net changes:

• +92 entities — China, Hong Kong, North Korea, Russia, Pakistan,

Iran, United Arab Emirates.

• -5 entities — China, Iran, India (delistings; typically

reflect updated corporate status, name/address changes, or resolved concerns rather than a policy loosening).

• Total after revision: 835 entities across 15 countries/regions

(net +87), effective 9 October 2025.

Downstream implications

• Exporters shipping dual-use goods to any of the newly listed

entities in China, Hong Kong, North Korea, Russia, Pakistan, Iran, or the UAE now face a METI licence-application trigger even for items not on Japan's specific control list.

• The addition of conventional-weapons-concern entities (not just

WMD/missile) widens the practical reach of catch-all controls beyond the traditional nonproliferation lens, aligning with the broader FEFTA catch-all restructuring filed separately.

• Routine, recurring instrument: METI periodically revises this list

(this is not a one-off action), so expect further additions/removals as a standing compliance-monitoring item for exporters trading with the listed jurisdictions.

Open questions

• Full entity-level detail (individual company/organisation names) is

published only in the linked PDF annex on METI's site; not extracted here — consult the Japanese-language PDF for the complete list if a specific counterparty needs to be checked.

• Whether any of the 92 additions overlap with entities already on

the US BIS Entity List or EU/UK equivalents is not confirmed.