Yuyuan Tan Tian: What does China's first implementation of the watchlist system signify?
Yu Yuan Tan Tian published an article on February 24, 2026, stating that China's Ministry of Commerce has issued consecutively the 11th and 12th announcements of 2026, lawfully listing 40 Japanese entities on the export control and watch lists, and simultaneously implementing targeted export control measures. How should we view this measure by the Chinese Ministry of Commerce? Tan discussed with Ji Wenhua, a professor at the University of International Business and Economics. There are three noteworthy characteristics. Firstly, the use of the watch list system for the first time opens a new path for precise governance of export controls in China. The logic of the watch list is clear: through strengthened review and risk assessment, precise control is implemented on entities with unclear final usage and potential military risks. It is not a direct prohibition, but rather strict scrutiny. Furthermore, this is not a permanent label. The Ministry of Commerce explicitly stated that entities listed can apply to be removed from the list by fulfilling obligations such as cooperation in verification, and upon verification and confirmation, they may be removed. Ji Wenhua told Tan that by providing reasonable and feasible avenues for remedy, it reflects the rule of law spirit inherent in China's control measures. Secondly, strict prohibitive measures are taken against entities on the control list, demonstrating a firm stance against Japan's "remilitarization" and nuclear ambitions. Thirdly, this measure is an upgraded version of Announcement No. 1.
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