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On May 23, 2023, Japanese government announced an amendment of the export control regulations on the additional semiconductor related items, which will go into effect on July 23, 2023.

The overview of the amendment of the Products and Technologies Specifications Ministry Order (“Ministry Order”), to which specific products and technologies were added to the controlled items, is as follows:

From the international peace keeping and security point of view, items related with advanced semiconductor manufacturing devices were added so that they are subject to the export control regulations.

In addition, in order to have programs designed for a use of additional items to be subject to the export control, additional provisions were added to the Ministry Order.

The followings are the additional items to be subject to the export control:

ItemsProvision of the Ministry Order
Cleaning (3 items)Item 17 (ya)-(ke)
Deposition (Film formation) (11 items)Item 17 (re)-(o)
Annealing (Heat treatment) (1 item)Item 17 (ku)
Lithography (Exposure) (four items)Item 17 (ru)-(wa), Item 17-2
Etching (Chemical removal) (3 items)Item 17 (ka)-(ta)
Inspection (1 item)Item 17 (fu)

The following guidelines would be amended accordingly.

・Guideline for the Operation of the Export Control Order

・Guideline for the documentation and concerns regarding export license

・Guidelines for a bulk license






洗浄 (3 品目)第17号 ヤからケまで
デポジション(成膜) (11 品目)第17号レからオまで
アニーリング (熱処理) (1 品目)第17号ク
リソグラフィ(露光) (4品目)第17号ルからワまで, 第17号の2
エッチング (化学的除去) (3 品目)第 17号カからタまで
検査 (1 品目)第 17号フ






Junko Suetomi is a partner in Baker McKenzie Tokyo. Prior to joining the Firm, she worked in the WTO Dispute Settlement Division of the Ministry of Foreign Affairs' Economic Bureau. She has also worked for a global law firm in Washington, DC and New York, and served as a court-appointed defense attorney in many criminal cases. Junko is recognized as a leading lawyer by Marquis Who's Who, Asia Business Law Journal, Chambers Global and Chambers Asia Pacific, Best Lawyers, Who's Who Legal and other legal directories. She was the chair from 2019 to 2021 and now is vice chair of the Human Rights Committee of the Tokyo Bar Association and a part-time lecturer at Waseda University. She was a legal advisor to the Ministry of Finance Japan's Office of Trade Remedy Affairs, Tariff Policy and Legal Division, Customs and Tariff Bureau from 2016 to 2019. She has served as a bar examiner of the Ministry of Justice since November 2020. She has served as an expert member of the Ministry's Council on Customs, Tariff, Foreign Exchange and Other Transactions since 13 March 2019. She has served as an expert member of the Financial Services Agency's Financial System Council, Fund Settlement System Working Group since October 11, 2021. She also holds a Certificate in Business Analytics from the Harvard Business Analytics Program (March 2021).

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