On 1 April 2012, the Ministry of Economy, Trade and Industry of Japan (“METI”) issued a notification introducing changes in application procedures for individual and general bulk export license for dual-use goods. The notification includes changes to:
i) Single-use License
The notification introduces a new format for End-User Certificate (“EUC”). The EUC is a document signed by the foreign importer or ultimate end-user which is required for application of single-use export license. The notification requires applicants to submit the revised EUC as supporting documents when applying for single-use license. The new EUC format takes effect on 1 April 2012 and the previous EUC format will be valid until 1 July 2012 .An English version of the new EUC format is available on the METI web site.
ii) General Bulk License
The notification splits the existing general bulk license (locally called “Ippan Houkatsu” export license) into two categories:
a. White Country Bulk License
Traders looking to export certain non-sensitive dual-use items to white countries can apply for white country bulk licenses. Requirements for this license are less stringent – only registration of responsible executives and staff involved in classification are required; an Internal Compliance Program (“ICP”) is not required. Application for the license can only be done through the NACCS online system.
b. Special General Bulk License (locally called “Tokuichi Houkatsu”):
This license allows export of certain non-sensitive dual-use items to various countries except high risk countries such as Iran, North Korea, Iraq, and United Nations (“UN”) embargoed countries. The details of eligible items and destination is included in a matrix chart included in the notification. Existing holders of general bulk license will have their licenses automatically converted to special general bulk license automatically. New applicants for the special general bulk license are required to undergo an on-site pre-audit by METI in addition to the existing requirement to implement ICP and registration with METI. Existing general bulk license holders will not be required to undergo on-site audits by METI for license renewal.
The above mentioned new bulk license scheme takes effect on 1 July 2012.