Only some of Japan's bulk export licences require a Compliance Programme, CP (コンプライアンス・プログラム). The basic General Bulk Licence (一般包括輸出許可) runs a simpler no-CP route: registering a compliance officer and a general manager. The Special General, Specific, and Specific Subsidiary bulk licences require a CP plus an annual Compliance List filing instead. Which route applies depends on which licence type your export pattern actually needs.
What Is a Bulk Export Licence Under Japan's Export Control Law?#
A bulk export licence (包括輸出許可) lets an exporter cover multiple shipments within approved parameters, such as destination, item category, and volume, instead of filing an individual licence (個別輸出許可) for every transaction. Authority for all Japan export licensing sits in the Foreign Exchange and Foreign Trade Act, FEFTA (外為法), Article 48.
There are six bulk licence types, and they are not interchangeable. Three require a CP; three do not. Confusing them is one of the most common mistakes exporters make when they assume a single "bulk licence" category exists.
Which Japan Bulk Export Licences Require a CP?#
Three of the six require a Compliance Programme; three run on a different basis entirely. This article covers the export side only; it does not address whether a specific product or transaction requires a licence at all, which is a separate commodity classification determination (該非判定) question covered in our Japan Export Control and Commodity Classification Determination guide.
No-CP route:
(a) General Bulk Licence (一般包括輸出許可). Requires registering a compliance officer (該非判定責任者) and a general manager (統括責任者). Filed through NACCS. Issued by the regional bureau. No CP and no Compliance List required.
CP-gated route:
(b) Special General Bulk Licence (特別一般包括輸出許可). Requires a CP receipt and a Compliance List receipt, plus a completed compliance status survey (実施状況調査), which the Ministry of Economy, Trade and Industry, METI, conducts on-site, by document inspection, or by simultaneous voice call. Filed through NACCS. Issued by the regional bureau.
(c) Specific Bulk Licence (特定包括輸出許可). Same CP and Compliance List requirements as the Special General Bulk Licence, plus a continuing transaction relationship with the same counterparty. Filed by mail or post to METI's Security Export Control Division (安全保障貿易審査課).
(d) Specific Subsidiary Bulk Licence (特定子会社包括輸出許可). Same CP and Compliance List requirements, plus majority shareholding of over 50 percent in the subsidiary receiving the goods. Filed by mail or post to the Security Export Control Division.
Narrow-purpose, no CP:
(e) Special Return Bulk Licence (特別返品等包括輸出許可). Covers only the return, repair, or exchange of previously exported weapons-category items. Requires a responsible-person selection, not a full CP. Filed by mail or post to the Security Export Control Division.
(f) Exhibition Service Bulk Licence (展示会等包括役務取引許可). Covers technology discussed in early-stage defence-equipment business talks. Requires responsible-person registration. Filed by mail or post to the Security Export Control Division.
One waiver exists on the CP-gated route: the compliance status survey requirement is waived for an Authorized Exporter (特定輸出者) certified under Customs Act (関税法) Article 67-3, Paragraph 1, Item 1, applying for the Special General Bulk Licence's export or technology-transfer program-use type specifically.
How Do You File a CP With METI?#
Filing a CP is voluntary, but it becomes a prerequisite the moment you need one of the three CP-gated bulk licences above. The current CP notice was promulgated April 9, 2025, and took effect May 9, 2025.
A new CP filing comprises three forms, the CP document itself, a corporate registry extract, and supporting documents where they exist: internal rules, sub-rules, an organisation chart, and a company profile. METI issues a CP receipt once the content is judged adequate. Any change to the CP's content must be notified to METI within one month, and withdrawing the CP voids both the receipt and any Special General Bulk Licence that depends on it.
What Is the Annual Compliance List, and What Happens If You Miss the Filing Window?#
The Compliance List (CL) is a yearly filing every CP holder must make between July 1 and July 31. Missing that window matters because the resulting CL receipt is only valid for 13 months from issue, so a lapsed filing leaves a CP-gated bulk licence holder without the current receipt copy a new application or renewal requires.
A CL receipt is also invalidated early if METI demands its return on grounds that the holder is not following its own CP. The CL receipt copy attaches to every Special General Bulk Licence application and to each renewal, so a gap in CL filing history is a direct gap in a company's ability to keep that licence current.
How Long Does a Japan Bulk Export Licence Last?#
Every bulk licence type runs up to three years from the date it takes effect, regardless of which of the six categories issued it. Renewal is available up to three years from the day after expiry, and the renewal application must be filed starting three months before the current licence expires.
Separately from any bulk licence, exporters who conduct list-controlled exports as a business must meet the Exporter Compliance Standard (輸出者等遵守基準), based on FEFTA Article 55-10, whether or not they hold a CP. Holding a bulk licence of any type does not mean an exporter can ship freely; each shipment still requires the underlying commodity classification and, where applicable, catch-all analysis described in our Japan Export Control and Commodity Classification Determination guide.
Key points:
(a) The General Bulk Licence uses a no-CP route (compliance officer and general manager registration); the Special General, Specific, and Specific Subsidiary Bulk Licences require a CP and an annual Compliance List filed every July.
(b) A CP filing is voluntary in the abstract, but mandatory in practice for any exporter that needs one of the three CP-gated licence types.
(c) Every bulk licence type, CP-gated or not, is valid for up to three years and renewable up to three years from the day after expiry, with the renewal window opening three months before expiry.
Our Non-Resident Exporter Customs Agent guide covers a related but separate question: how a non-resident exporter appoints a Japan-based agent to handle the customs declaration itself, as opposed to the export licence analysed here. For goods entering Japan temporarily before re-export under a licence exception, see our Temporary Admission FEFTA Re-Export Licence guide.
Frequently Asked Questions#
Do I need a Compliance Programme for every Japan export licence?
No. The General Bulk Licence, the most commonly used entry point for exporters moving beyond individual per-shipment licences, runs on compliance officer and general manager registration rather than a CP. A CP becomes necessary only when the export pattern requires the Special General, Specific, or Specific Subsidiary Bulk Licence.
How long does a Compliance List receipt stay valid once issued?
Thirteen months from the date of issue. Because the annual filing window is fixed at July 1 to July 31, a CP holder that misses that window can end up without a current receipt to attach to a bulk licence application or renewal, even if the underlying CP itself remains valid.
Can a bulk export licence ever be permanent?
No. Every bulk licence type, whether it requires a CP or not, is capped at three years from the date it takes effect. Continued use requires a renewal application filed from three months before the current licence expires, valid for up to a further three years.
Conclusion#
Japan's six bulk export licence types split cleanly into a CP-gated group and a no-CP group, and treating them as a single undifferentiated category is the most common source of confusion for exporters planning their compliance infrastructure. Aplash advises exporters on matching the licence type to the actual transaction pattern and on structuring the underlying commodity classification work that every licence type still requires. For guidance specific to your export structure, see our regulatory strategy services.
This article is informational only and does not constitute legal, tax, or regulatory advice. Consult a qualified advisor before acting on the content. Last updated: September 2026.