On September 8, 2024, amendments to Japan’s Export Control Order and Foreign Exchange Order took effect, adding quantum computing-related technologies and advanced semiconductor items to the list of controlled goods. The amendments had been promulgated on July 8, 2024, following a public comment period.
According to Baker McKenzie’s analysis, the newly controlled items included cryogenic CMOS circuits (cryo-CMOS), scanning-type electron microscopes for semiconductor imaging, GAAFET transistor design and manufacturing technology, and related software. An export license was required for controlled items regardless of destination.
Specification thresholds for semiconductor manufacturing equipment were also updated to align with export control trends in other countries. The amendments represented Japan’s implementation of quantum-related export restrictions prior to formal inclusion in the Wassenaar Arrangement’s multilateral framework.