AEO exporter benefit in Japan bulk export license

As of February 9, 2013, a draft proposal to change Japan bulk export license regulation is posted on e-gov web site for public comment. 
http://search.e-gov.go.jp/servlet/Public?CLASSNAME=PCMMSTDETAIL&id=595113010&Mode=0

The draft proposal is, as always, in Japanese only, let me summarize the main points of change.

1. AEO approved exporter will have a benefit in applying bulk export license:Currently, in order to apply bulk export licenses in Japan (excluding White country bulk license), on-site audit by METI is mandatory requirement for a new applicant.  The proposed new provision will eliminate METI on-site audit specifically for AEO exporter.  It is allowed for AEO exporter to apply bulk license without METI on-site audit.  This exemption is certainly welcomed by AEO exporter who don't have METI bulk license.
2. METI official seminar not required for bulk license:  Currently, the attendance to METI official export control seminar by full time employee is mandatory requirement before bulk license application, and also in renewal of bulk license in extending its validity.  This seminar requirement will be eliminated, and instead, the new provision states as: "for exporter to get latest export control regulatory update and disseminate it to relevant employees internally".  In addition, the participation of the official seminar is not required also in renewal of bulk license.  In essence, exporter don't reply on government effort, but try themselves to keep update.

My finding and comments are:

1. Benefit in AEO exporter: 
   AEO system is governed by Customs under Ministry of Fiance, while export control is under METI.  Historically, there have been very little interaction between Customs and METI in regulatory development in export control, but this announcement is new trial to remove barrier between Ministries.  I appreciate this new trial by METI and Customs.  Because, in order to be AEO exporter, there have been duplicated effort as export control in ICP implementation or set up export operation procedures, it would be welcomed by traders.  However, I notice the AEO exporter is only 246 companies in Japan as of January 2013, and many of them are likely to already have bulk export license.  Therefore, the beneficial impact will be limited to small number of companies.
2. METI official seminar not required: 
   This will be welcomed by traders as relax of the requirements, because METI official seminars have been conducted in only a few chances a year in limited cities, and the number of seats have been limited each time, it has been inconvenient for traders.  The seminar material is always posted and available in METI web site, and its content is pretty basic level.  I find there is no strong reason to continue this government official seminar by spending resource of tax payer in Japan.

The public comment is by March 10, 2013.  The Bulk License Notification will be update accordingly perhaps April 2013 onward.