Self-Assessment Concerning the Deemed Export Controls

This page concerns Deemed Export Controls, which ask you to confirm whether you fall into one of the following categories:

- Category ①: You have a contract with a foreign governmental body or foreign corporation

- Category ②: You earn a large amount of money or other significant profit from a foreign governmental body

Please read the following instructions, access the link below, and answer the questions.

*When you see "foreign” in the instructions below, please interpret it as “non-Japanese.”  

_________________ 

Self-assessment concerning the Deemed Export Controls following the revision of the Foreign Exchange and Foreign Trade Act

１. Reason for self-assessment

The related laws and regulations of the Foreign Exchange and Foreign Trade Act (FEFTA) were revised in 2022 such that the scope of “deemed export controls” covers not only the export of goods and transfer of technology across borders, but also the transfer of technology domestically from a resident (*) to a non-resident. This also includes technology transfer from a resident to a resident who is under significant influence of a non-resident. The categories of “significant influence” are defined.

FEFTA requires the University of Tokyo to confirm whether faculty and staff at the university fall under either of the specified categories, which means that all faculty and staff are required to declare their status to the university.

See the attached “For those who start to work as a faculty or staff in Japanese universities and research institutes” by the Ministry of Economy, Trade and Industry

 ​Request for Your Cooperation for Compliance with Regulations of Deemed Export Controls .pdf (sharepoint.com)​

(*) resident: a Japanese national living in Japan or a foreign national who has been living in Japan for more than 6 months

２. Who is required to declare?

All faculty and staff members at the university except those working abroad.

３. Declaring which of the specific categories applies

FEFTA defines two categories of those who qualify as being under the influence of a non-resident.

Category ①: You have a contract with a foreign governmental body or foreign corporation

Category ②: You earn a large amount of money or other significant profit from a foreign governmental body

Please declare if you fall into Category ①, Category ②, or neither. If you fall into Category ① or ②, then please declare the name of the foreign entity. The link to the declaration form is shown in 4. below.

４. How to declare using the form (Important)

The information below explains each item of the form. Please refer to the following, especially if you have any contract with a foreign government or corporation, as not all contracts necessarily qualify as Category ①.

• If you have multiple positions at the University of Tokyo, please make a declaration through each department using the links provided by your various departments. (Note: You do not have to make a declaration through Integrated Research Systems.)
• Regarding Category ①, please read the information below and the attached document concerning contracts with foreign bodies that fall into Category ①“.

• You fall under Category ① if you have any of the following types of contact:

1. a) Engagement agreement as a board member, auditor, or equivalent positions
2. b) Employment agreement including cross appointments
3. c) Commission contract, service contract, or other contract which constrains you by time and place

Even if one of these applies to your situation, you may not come under Category ①. Please see the additional details in the attached document above.

• “Foreign government” includes foreign governments, governmental agencies, local governments, central banks, political parties or any other political organizations.
• “Foreign corporation” refers to corporations and organizations that have been established under foreign laws and regulations. This does not include a Japanese arm of a foreign corporation.
• Even if you have a contract that meets the above conditions, if you have agreed in writing with the foreign entity that the chain of command between you and the University of Tokyo has priority, then you will not be classified as Category ①. For more information, please see the details in the following document: “Exception from Category ① through written agreement prioritizing the directions or the duty of care of the University of Tokyo“.

(3)Category ② means that you earn a large amount of money from a foreign government.

• “Foreign government” means foreign governments, governmental agencies, local governments, central banks, political parties or any other political organizations. In other words, this does not include money from private corporations.
• “A large amount of money” means money or other significant profits which account for 25% or more of your annual income. “Annual income” is either income in a calendar year or fiscal year.

(4) The clauses contained within ① or ② in 1(3)サ of the “Notification for Transactions or Acts of Transferring Technology Requiring Permission pursuant to Article 25 (1) of the Foreign Exchange and Foreign Trade Act and Article 17 (2) of the Foreign Exchange Order" (Document No. 492 of the Trade Bureau published on December 21, 1992) mean that if you transfer technology to those applicable classified as either Category ① or ② inside or outside the university, technology transfers are regulated by FEFTA. In such cases, you are required to obtain a license from the Minister of Economy, Trade, and Industry.

(5) The declaration form is written in both English and Japanese, but please be aware that the Japanese version is official, while the English one is for reference only (and not necessarily grammatically correct). For the last two questions, the following are more grammatically accurate than the ones in the form.

> Do you pledge the following?

1.  I have filled in the above questions correctly so that the University of Tokyo may comply with the Foreign Exchange and Foreign Trade Act.
2.  I understand that when the University of Tokyo transfers technology to a resident categorized as Catyegory ① or ② in 1(3)サof the “Notification for Transactions or Acts of Transferring Technology Requiring Permission pursuant to Article 25 (1) of the Foreign Exchange and Foreign Trade Act and Article 17 (2) of the Foreign Exchange Order" (Document No. 492 of the Trade Bureau published on December 21, 1992), it may be necessary for the university to obtain permission from the Minister of Economy, Trade and Industry based on the Act Article 25 (1) and (2) of the FEFTA.

> Do you consent to the following?

1. You will resubmit this declaration form as soon as possible when you begin a new contract with a foreign government or corporation or when you begin to earn profit from another foreign government.
2. You will resubmit this declaration form soon after you move to another department.
3. The answers you have provided above will be shared among the staff in charge of compliance with the Foreign Exchange and Foreign Trade Act in order for the University of Tokyo to comply with the Act.
4. The answers you provided above may be used in order to crosscheck with other applications based on the regulations on concurrent employment (‘Kengyo kitei’), declaration based on the conflict of interests policy and the ethical code, declaration based on the guideline on execution of competitive research funding, and so on.

５. Important notes

(1)   What you declare will be shared with relevant staff in your department, including staff in charge of Deemed Export Control in the Export Control Office and your project manager (the head of laboratory) (where applicable) for the purposes of conducting export control and information management.

Also, it will be shared with any person who transfers technology to you in order for that person to know whether they need to conduct an evaluation according to FEFTA. Staff in charge of export control will contact you to ask whether you will be receiving any technology from that person before the staff is able to share your information with the person in question.

Furthermore, what you declare may be used to crosscheck with other applications based on the regulations on concurrent employment (‘Kengyo kitei’), declaration based on the conflict-of-interest policy and the ethical code, declaration based on the guideline on execution of competitive research funding, and so on.

(2)   You may be penalized if the University of Tokyo determines that you have not made a declaration or you have made false declarations.

Also, if you do not make a declaration, you will be categorized as a person who is under significant influence of foreign entities with the highest risk.

(3)   You are required to submit a declaration again if any changes to what you have declared occur.

1.  If you have a new situation that comes under Category ① or ②, or if you change your name, please re-declare using the same URL or QR code.
2. When you move to another department, please re-declare using the URL or the QR code provided by the new department.

(4)   What you declared will be automatically sent to the email address you provided. The opening of the email will read as follows. If you are Category ① or ②, please comply with the request below.

“If you fall into Category ① or ②, please notify the head of your laboratory (or if you are the head, your immediate supervisor) that you have been classified as being deemed export category ① (or ②) as defined in FEFTA. If other faculty or staff members in the university are transferring technology to you, that member, together with the Export Control Office must conduct screening along with FEFTA. Please tell the head of your laboratory and also contact the Export Control Office (anzen@ducr.u-tokyo.ac.jp). The office will provide you with necessary information concerning the screening.”

６. In case of inquiries

(1) The Guidebook (Benri-cho) on the UTokyo Portal posts information and Q&A on Deemed Export Control and this self-assessment. Please refer to the guidebook first (which is in Japanese) in the event your question has already been answered.

便利帳 Guide Book - Office_of_Export_Control (sharepoint.com)

(2) The Office of Export Control: anzen@ducr.u-tokyo.ac.jp

Last updated : October 09, 2025