Japan METI Export Trade Control Order Cabinet Order Amendment: Peptide Synthesizers, Refractory Metal Powders, and FPGA Modules (Appended Table 1, Items 5(20) + 7(10-2))

Mechanism

On 11 November 2025 Japan's Cabinet adopted — and on 14 November 2025 promulgated — a Cabinet Order partially amending the Export Trade Control Order (輸出貿易管理令, Cabinet Order No. 378 of 1949 as repeatedly amended). The amendment adds three new item clusters to Appended Table 1, which lists the goods and technologies requiring prior-approval export licences from METI under the Foreign Exchange and Foreign Trade Act (FEFTA, 外国為替及び外国貿易法):

Item 5(20) — Refractory metal and multi-principal-element alloy powders

Powders of refractory metals (tungsten, molybdenum, niobium, tantalum, rhenium) or their alloys, and powders of alloys composed of multiple elements in approximately equal proportions (high-entropy alloys / multi-principal-element alloys), when below specified particle-size and purity thresholds. These feedstocks are used in metal additive manufacturing (laser-powder-bed fusion, binder jetting) to produce turbine blades, hypersonic vehicle structures, nuclear-reactor components, and advanced military hardware. The control implements a Wassenaar Arrangement plenary outcome on metal- powder dual-use additive-manufacturing feedstocks — the same outcome that BIS addressed in the September 2024 advanced-manufacturing controls package.

Peptide synthesizers and components

Automated peptide synthesis equipment and related components (flow reactors, amino-acid activators) mapped to the Australia Group (AG) dual-use biotechnology list as updated at the 2023 and 2024 AG plenary sessions. These items can be repurposed to synthesize peptide-based biological agents. Japan's adoption aligns the Export Trade Control Order with the US BIS implementation enacted in December 2024 (2024-12-23-us-bis-australia-group-implementation-2023-2024-plenary), closing the transatlantic AG-alignment gap that had persisted for approximately 12 months post-plenary.

Item 7(10-2) — FPGA modules, assemblies, and devices

Modules, assemblies, or devices that incorporate field-programmable logic devices (FPGAs) above specified gate-count and process-node thresholds. High-gate-count FPGAs on advanced process nodes (7 nm and below) are increasingly deployed as AI inference accelerators, radar signal processors, and electronic-warfare platforms. The new control extends Japan's semiconductor-component AI-compute perimeter — initiated with the March 2023 semiconductor equipment controls (2023-03-31-japan-meti-semi-equipment-export-controls) — downstream to finished FPGA- incorporating assemblies, closing a gap where the underlying FPGA die was controlled but the assembled module was not.

Architecture fit

This is the first discrete Appended Table 1 list-control amendment promulgated under the post-October-2025 FEFTA catch-all-controls architecture (2025-10-09-japan-meti-fefta-catch-all- controls-overhaul). That overhaul, effective April 2025, restructured FEFTA's catch-all controls and delegated annual list-control review to a METI-led process. The November 2025 Cabinet Order is the first output of that process: a focused, multilateral-regime-driven Appended Table 1 update rather than a strategic-competitor-targeted measure. This is structurally distinct from the catch- all overhaul itself and from the TMS-PPD List 1 amendment (2025-11-11-japan-meti-etco-tms-ppd- amendment) promulgated on the same date, which added quantum-dot materials, TADF emitters, phase- difference film, and flexible endoscopes via the TMS-PPD industry-dialogue track.

Downstream implications

• Australia Group alignment: Japan joins the US as the second major AG member to formally

implement the 2023–2024 plenary peptide-synthesizer outcomes; expect EU dual-use regulation and UK Export Control Order equivalents within 6–18 months.

• Wassenaar metal-powder convergence: The refractory-metal-powder item closes a gap between

Japan's national list and Wassenaar Arrangement List 1C117 / 1C116 updates; South Korean and Australian export-control lists lag by a similar interval and should be monitored.

• FPGA supply-chain impact: Intel (Altera), Xilinx/AMD, Lattice, Microchip (Microsemi) FPGA

products assembled into modules before Japanese export now require METI prior-approval licences for designated destinations; affects Japanese EMS / contract-electronics manufacturers with China-export lines.

• Periodicity signal: Two Appended Table 1 amendments on the same promulgation date (this

action + TMS-PPD List 1) establishes an emerging annual cadence — METI is consolidating Wassenaar/AG regime outcomes into a single annual Cabinet Order cycle rather than filing them individually throughout the year.

Open questions

• Gate-count/process-node thresholds for FPGA Item 7(10-2): METI has not published English-

language parameter tables; the Japanese-language Appended Table 1 amendment text should be retrieved from the Official Gazette (官報) for exact numerical thresholds.

• Peptide-synthesizer throughput limits: The Australia Group specifies capacity thresholds

(e.g., per-run synthesis scale) that Japan's implementing language may adopt verbatim or modify; the full Japanese implementing order text is needed to confirm.

• Licensing guidance: METI has not yet published a catch-all licensing guidance note analogous

to BIS's supplements for the Australia Group items; an advisory opinion from METI Trade Control Division is expected in Q1 2026.