Two Chinese business groups have provided the Japanese government with their comments on its proposed revision of export control measures for semiconductor equipment, calling on Japan to consider its proposal carefully.
The comments, jointly made by the China Council for the Promotion of International Trade (CCPIT) and the China Chamber of International Commerce, urge the Japanese government to seriously listen to the voices of reason and make decisions in the interests of the semiconductor industry in both countries.
The proposed revision of the export control measures under Japan’s Foreign Exchange and Foreign Trade Law is too broad in scope and unclear and opaque in provisions, with many items to be regulated going far beyond the scope of conventional control, said a spokesperson with the CCPIT.
A lot of civilian items are included, and some should not be controlled as explicitly provided in the Wassenaar Arrangement. Such control measures have gone far beyond the scope made by international norms and other countries, the spokesperson said.
It is worth noting that Japan’s proposed measures are aimed at semiconductor manufacturing equipment that cannot be diverted to military use. The final use of semiconductor products produced by Japan is generally for consumer electronics, which has nothing to do with military use.
Although Japan says that the proposed measure is not aimed at specific countries, it will adopt case-by-case licensing procedures and methods for China and many other countries outside the 42 countries or regions it describes as friendly.
This practice, in essence, sets up obstacles for and takes discriminatory measures against China and many other countries, which is a suspected violation of WTO obligations, such as the principle of most-favored-nation treatment and the principle of quantitative restriction, the spokesperson said.
The two business groups also challenged the legislative process of the proposed revision and the wording of some provisions, as the Japanese government has obviously ignored the opinions of relevant enterprises and made it difficult for companies to comply with the regulations.
Once put into effect, the proposed control measures will have a major adverse impact on Sino-Japanese economic and trade cooperation, as well as scientific and technological exchanges in the semiconductor field, hurting not only market players of both countries but also global supply chains, and strangling the sector’s overall competitiveness and development potential, the spokesperson said.
