China sanctions 50 Japanese companies
On the first working day after the Spring Festival, China’s Ministry of Commerce (MOFCOM) issued two consecutive announcements, placing 50 Japanese companies on its sanctions lists.
Among them, 30 entities were added to the Export Control List (all defense-related companies; Chinese companies are prohibited from conducting transactions with them), while 20 entities were added to the “Watch List” (midstream and supporting enterprises in the defense supply chain. It is similar to the U.S. Unverified List (UVL): Chinese companies may transact with them, but the relevant security review and risk assessment requirements are extremely stringent).
The two announcements:
MOFCOM Announcement No. 11 of 2026
Decision to Add 20 Japanese Entities to the Export Control List
Issuing Authority: Bureau of Security and Control
Document No.: MOFCOM Announcement No. 11 of 2026
Date of Issuance: February 24, 2026
Pursuant to the Export Control Law of the People’s Republic of China and the Regulations of the People’s Republic of China on Export Control of Dual-Use Items, and in order to safeguard national security and interests and fulfill international non-proliferation obligations, it has been decided to add 20 Japanese entities, including Mitsubishi Heavy Industries Shipbuilding Co., Ltd., that are involved in enhancing Japan’s military capabilities, to the Export Control List (see Annex). The following measures are hereby imposed:
Export operators are prohibited from exporting dual-use items to the above-mentioned 20 entities. Overseas organizations and individuals are prohibited from transferring or providing dual-use items originating from the People’s Republic of China to the above-mentioned 20 entities. Ongoing related activities shall be immediately suspended.
Where export is genuinely necessary under special circumstances, export operators shall apply to the Ministry of Commerce for approval.
This Announcement shall take effect as of the date of its publication.
Annex: Export Control List (February 24, 2026)
Ministry of Commerce
February 24, 2026
Annex
Export Control List
(February 24, 2026)
Mitsubishi Heavy Industries Shipbuilding Co., Ltd.
Mitsubishi Heavy Industries Aero Engines, Ltd.
Mitsubishi Heavy Industries Marine Machinery & Equipment Co., Ltd.
Mitsubishi Heavy Industries Engine & Turbocharger, Ltd.
Mitsubishi Heavy Industries Maritime Systems, Ltd.
Kawasaki Heavy Industries Aerospace Systems Company
KAWAJU Gifu Engineering Co., Ltd.
Fujitsu Defense & National Security, Ltd.
IHI Power Systems Co., Ltd.
IHI Master Metal Co., Ltd.
IHI Jet Service Co., Ltd.
IHI Aerospace Co., Ltd.
IHI Aero Manufacturing Co., Ltd.
IHI Aerospace Engineering Co., Ltd.
NEC Network and Sensor Systems, Ltd.
NEC Aerospace Systems, Ltd.
Japan Marine United Corporation
JMU Defense Systems Co., Ltd.
National Defense Academy of Japan
Japan Aerospace Exploration Agency
MOFCOM Announcement No. 12 of 2026
Decision to Add 20 Japanese Entities to the Watch List
Issuing Authority: Bureau of Security and Control
Document No.: MOFCOM Announcement No. 12 of 2026
Date of Issuance: February 24, 2026
Pursuant to the Export Control Law of the People’s Republic of China and the Regulations of the People’s Republic of China on Export Control of Dual-Use Items, it has been decided to add 20 Japanese entities, including SUBARU Corporation, for which the ultimate end users and end uses of dual-use items cannot be verified, to the Watch List (see Annex).
Where export operators export dual-use items to the above-mentioned entities, they shall not apply for a general license nor obtain export documentation through information filing and registration procedures. When applying for an individual license, they shall submit:
A risk assessment report concerning the entity listed on the Watch List; and
A written undertaking that the dual-use items will not be used for any purposes that contribute to enhancing Japan’s military capabilities.
The time limit for license review shall not be subject to the time limits specified in Article 17, Paragraph 1 of the Regulations of the People’s Republic of China on Export Control of Dual-Use Items.
The Ministry of Commerce shall implement stricter end-user and end-use reviews for exports of dual-use items to entities on the Watch List. Exports involving Japanese military end users, military end uses, or any other end users or end uses that contribute to enhancing Japan’s military capabilities shall not be approved.
Entities included on the Watch List may, pursuant to Article 26 of the Regulations of the People’s Republic of China on Export Control of Dual-Use Items, apply for removal from the Watch List after fulfilling their obligation to cooperate with verification. Upon verification, the Ministry of Commerce may remove them from the Watch List.
This Announcement shall take effect as of the date of its publication.
Annex: Watch List (February 24, 2026)
Ministry of Commerce
February 24, 2026
Annex
Watch List
(February 24, 2026)
SUBARU Corporation
FUJI Aerospace Technology Co., Ltd.
ENEOS Corporation
Yusoki Co., Ltd.
ITOCHU Aviation Co., Ltd.
Leda Group Holdings Co., Ltd.
Institute of Science Tokyo
Mitsubishi Materials Corporation
ASPP Co., Ltd.
Yashima Denki Co., Ltd.
Sumitomo Heavy Industries, Ltd.
TDK Corporation
Mitsui Bussan Aerospace Co., Ltd.
Hino Motors, Ltd.
Tokin Corporation
Nissin Electric Co., Ltd.
Sun Tectro Co., Ltd.
Nitto Denko Corporation
NOF Corporation
Nacalai Tesque, Inc.