2011年9月7日水曜日

METI add more FAQ in post-license manegement

Japanese METI updated the export control license management FAQ on Sept 5, 2011.
Unfortunately for most of global traders, this FAQ is written only in Japanese and no English translation.
What is written in this FAQ is about the procedure of supporting documents and post-license management in exporting Japanese control item Category 4 (18) - Batch mixers and Continuous mixers - or equivalent to US ECCN 1B117 and 1B118.

In exporting such goods, the export license is required with various supporting documents.  The supporting documents include (in case by case) the statement of end-user, factory layout plan where the equipments are installed, the oath of NOT relocating the equipment to another location even in another floor in the same property, etc. etc. 
What is written here is guideline of such supporting documents and METI's policy of post-license management.  As long as the license applicant follow up to clear the diversion risk and non proliferation concern and report to METI in advance if required so, METI don't prohibit relocation of the equipments.

When I talk with non-Japanese export control specialist, some of them complaint about Japanese METI's extra-territorial control.  In principle, Japanese export control law is NOT extra-territorial, but some believe the METI's post-license management is substantially extra-territorial effect.  That may be partly true from operator's point of view.  Why foreign end-users need to have approval of METI when they relocate the controlled equipments which were exported legally under METI license?  In order to mitigate such Japan extra-territorial license management practice, METI try to refine the FAQ by providing much guidance with details.  Hope this FAQ is provided in English.

(Resource from below URL - in Japanese.)

Q&A「6.連続式の混合機関連 別表第1の4の項(8)」 ttp://www.meti.go.jp/policy/anpo/qanda065.html

Q&A「7.連続式の混合機関連 別表第1の4の項(8)<添付資料関係>」http://www.meti.go.jp/policy/anpo/qanda0655.html

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