2010年3月16日火曜日

Japan implement both Wassenaar 2008 and 2009 lists at once

On April 01, 2010, Japan will update its export control list to reflect recent change of international regimes, such as NSG, AG, MTCR and Wassenaar Arrangement ("WA").
The relevant Ministerial Ordinance and Notifications for stipulating updated export control list was announced on March 05, 2010.

As for WA dual-use items, last list change was October 2009. It was to reflect WA 2007 list.
Now Japan will implement both 2008 and 2009 list at once on April 01, 2010.

This is significant change of list update, as change including 2 years equivalent lists at once is not so usual.

For example, as for 4A003.b, the technical bar level is APP 0.75WT, which reflect WA 2008 list.

"US EAR 4A003.b: “Digital computers” having an “Adjusted Peak Performance” (“APP”) exceeding 0.75 weighted TeraFLOPS (WT);"

In Japan's new list, the equivalent category is APP1.5WT by reflecting WA 2009 list.

Another example is Category 5 - part 2. In WA 2009 list update is to reduce the scope of category 5 part 2 note 4 “ancillary cryptography”. The direct result of this new definition is that lots of cryptography items are no longer controlled by the dual use list of Wassenaar if the primary functions of goods, software or technology is not information security. Typical examples are items for gaming, car accessories, and home electrical goods etc which contain encryption but not sending/receiving encryption via network with outside. Accordingly, Japan will implement this exemption rule of encryption items from April this year by stipulating it into Notification called "Unyo Tsutatsu (for goods)" and "Ekimu Tsutatsu (for software and service)".

In Japanese classification practice, to fill in item's technical specification into Parameter sheet is popular procedure. Many companies will be busy for re-newing new parameter sheet and review its classification in these months.

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