All exporters in Japan require CP implementation???

I happen to get trade bulletin which explain Japan's recent export control regulatory development, but provide apparently wrong information. This bulletin was provided by one of big prestigious consulting firms. The topic and content is as follows.

Japan
Implementation of internal export control compliance programme (CP) requirement for all exporters.
Under existing practices, only exporters who wish to obtain bulk export licenses are required to submit a CP to the Ministry of Economy, Trade and Industry (METI) for approval.
However, in the revision of the Japanese Foreign Exchange and Foreign Trade Law (FEFTL), effective from 1 April 2010, all exporters will be required to implement CP..... (continue)

Above statement provide wrong information. For those who follow the recent FEFTL revision in Japan, it is easy to guess the author of this article apparently confuse the CP and "Exporter Compliance Standard" which was newly set forth in the FEFTL article 55-10.
Article 55-10 do NOT require all exporters to implement CP, but follow the compliance "Standard" which METI sets separately in Ministerial Ordinance. Otherwise, Guidance, Advice, Recommendation, Order and otherwise Penalty will be forced by METI. Exporter Compliance Standard just describe very very basic matters to be followed by exporters to be compliance to export control regulation. Normal CP (e.g. sample recommended by CISTEC) generally covers such basic export compliance matters, therefore CP holders do not need any additional new requirement after April 2010.

Just think with some common sense, you can find above information is rather strange.
FEFTL Article 1 states the purpose of FEFL as "on the basis of the freedom of foreign exchange, foreign trade and other foreign transactions, ....... through the minimum necessary control or coordination of foreign transactions", it may be against this purpose.
Also from practical operational point of view, if government force "millions of" all exporters in Japan to implement and submit CP to METI, that will jeopardize their operational capacity.

The trade bulletin provided by big consulting firm is really really excellent one, only except this Japanese export control topic. I won't disclose the name of this firm, but keep in my mind as a lesson, that I also should be careful to provide correct information.