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Policy Watch

MLIT Proposes Adding 'Essential Services' Test to Japan's Supply-Security Certification

A one-month comment window closing August 21 will decide whether Japan's economic-security certification track also covers the services that keep critical materials flowing, not just the materials themselves.

Jul 23, 20262 min read
Cranes loading steel plate and engine components onto a cargo ship at a dock, with a checkpoint barrier in the foreground suggesting regulatory review.

Japan's Ministry of Land, Infrastructure, Transport and Tourism (MLIT) has opened a month-long public comment period on a draft revision to the ministerial ordinance that governs certification of supply assurance plans under the Economic Security Promotion Act. Comments are open from July 23 to August 21, 2026, and must arrive by the close of that window.

What the draft actually changes

Under the 2022 law, the government designates certain materials as "specified critical materials." Companies working to secure stable supply of those materials, or the raw inputs behind them, submit a supply assurance plan to the relevant minister for certification, a step that opens access to the law's support measures. A Diet-passed amendment enacted this year, Act No. 38 of 2026, which also revised the JBIC Act, extends that framework to "essential services": services indispensable to supplying important materials. When an essential service shows external dependency and a probability of supply disruption, the material it supports can be designated a specified critical material, and the essential service itself can receive support aimed at securing it. MLIT's draft ordinance would fold this essential-services criterion into what applicants for supply assurance plan certification must address, on top of the existing material-focused requirements.

What is still missing from the public record

The overview document supplied to commenters explains the legal background and the reason for the change, but it stops short of listing which services or sectors MLIT expects to qualify, or the scale of support certified plans could receive. The excerpt reviewed here also does not state when a final ordinance would take effect once the comment period closes.

How to comment, and by when

MLIT is taking submissions through the e-Gov portal's comment form, by email to the Maritime Bureau's shipping industry division, or by fax; phone submissions are not accepted, and comments must be filed in Japanese. The ministry says it will consider the feedback before finalizing the ordinance but will not respond to individual submissions. For companies in the maritime supply chain watching the economic-security certification track, the practical question is narrower than the legal language suggests: will an essential service they rely on, or provide, end up on the list this ordinance is built to cover. That answer will not be public until after August 21.