Dual-Use & Controlled Goods IOR Japan (外為法)

Name: Aplash
Price range: $$

Dual-Use & Export-Controlled Goods Importer of Record Japan (外為法)

Dual-use and export-controlled goods entering Japan fall under 外為法 (Foreign Exchange and Foreign Trade Act). Aplash reviews 該非判定 (applicability determination) materials provided by the manufacturer, coordinates METI (経済産業省) licence applications, and acts as Importer of Record after the regulatory path is cleared. All engagements in this category undergo pre-engagement assessment before quoting.

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Engagement scope

該非判定 (Hi-Higaisan-Tei, applicability determination) review against 外為法 List Items and Catch-All criteria. Aplash reviews the manufacturer's parameter sheets against the latest control list; final classification responsibility rests with the manufacturer and with METI.

外為法 export licence and import licence coordination with METI.

ECCN / EAR (US Export Administration Regulations) analysis as advisory overlay. Authoritative US classification rests with BIS (Bureau of Industry and Security); Aplash provides advisory only.

End-user verification: entity-list screening, sanctioned-party screening, end-use questionnaire, Case D (civilian buyer with military-end-use chain) EUC (End-Use Certificate) coordination.

Importer of Record for goods cleared as Catch-All-cleared or list-controlled with valid licence in hand.

Outside scope

ITAR-controlled goods (US Munitions List) — decline.

Weapons, ammunition, defense articles — decline. Aplash holds no defense security clearance.

Nuclear, radiological, explosive items — decline.

Sanctioned-country or sanctioned-entity destinations — decline.

Issue authoritative BIS ECCN rulings — US authority only.

Rush IOR (under 3 business days) on Case D without prior standing EUC and KYC.

該非判定 (Applicability Determination) process

該非判定 (Hi-Higaisan-Tei) is the manufacturer-led process to determine whether a good falls under 外為法 List Items or Catch-All control. Aplash reviews the manufacturer's parameter sheet against the latest control list; the manufacturer remains the data owner and final classifier. Aplash sequences customs filing only after the determination is documented.

ECCN / EAR advisory overlay

The US Export Administration Regulations apply when goods have US-origin content, US-origin technology, or transit US jurisdiction. Aplash provides advisory only; authoritative classification rests with BIS. We flag potential US-side gating early so the manufacturer can engage US export counsel as needed.

End-user verification

Every engagement includes entity-list screening, sanctioned-party screening, and an end-use questionnaire. Where the civilian-buyer chain has potential military-end-use exposure (Case D), an EUC (End-Use Certificate) is required. Aplash provides templates aligned to METI expectations and confirms the EUC against the end-user before filing.

Pricing band

Controlled tier (single shipment, single-list 外為法 List Item, EUC in hand): from $13,000 per shipment. ECCN-contested re-verification or Case D scenarios: add $2,000 to $3,000 re-verification + percentage CIF surcharge. All engagements undergo pre-engagement assessment before quoting.

Customs duties and Japanese consumption tax (JCT) pass through at cost. Aplash earns no margin on the goods, only on the service.

Frequently asked questions

What is 該非判定 (Hi-Higaisan-Tei, applicability determination)?

The manufacturer-led process to determine whether a good falls under 外為法 (Foreign Exchange and Foreign Trade Act) List Items or Catch-All control. Aplash reviews the manufacturer's parameter sheet against the latest control list; the manufacturer remains the data owner and final classifier.

Does Aplash handle ITAR-controlled goods?

No. ITAR-controlled items (US Munitions List) fall outside Aplash's IOR scope. We can refer the inquiry to a specialist with the relevant US export licensing and Japan-side defense clearance.

Can Aplash IOR for defense contractor goods?

Limited. Civilian buyer with military-end-use chain (Case D) may be acceptable with valid EUC (End-Use Certificate) and KYC. Weapons, ammunition, and direct defense-end-user transactions fall outside scope. All defense-adjacent inquiries undergo pre-engagement assessment before quoting.

How long does a 外為法 (Foreign Exchange and Foreign Trade Act) import licence take?

Case-by-case, multi-week to multi-month, depending on the specific List Item, end-use, and Catch-All review depth. Aplash sequences customs filing only after the licence is granted; we do not pre-clear goods.

Do I need an EUC (End-Use Certificate)?

Required for any shipment with military-end-use chain potential (Case D) and for many Catch-All scenarios. Aplash coordinates EUC preparation with the end-user and provides templates aligned to METI expectations.