Japan's farm ministry has opened a public comment window on rule changes that would tighten how it manages fertilizer, one of the goods designated as economically critical under the 2022 Economic Security Promotion Act. The proposal follows a June 2026 amendment to that law and to the Japan Bank for International Cooperation Act, and the comment period runs from July 27 to August 25, 2026, with the revised rules expected to take effect in late September 2026.
The headline change is procedural but consequential: companies already certified as "supply assurance operators" for fertilizer would get a formal way to ask the agriculture minister to intervene with raw-material suppliers when they see their approved supply plan at risk of failing. Under a new Article 8-2 and accompanying Form 12-2, an operator would file a written request naming its certification number, the critical material at issue, and why execution has become difficult; the minister could then press suppliers and other relevant parties for cooperation. To avoid double paperwork, operators who file this new request would be exempted from the ministry's existing separate "significant obstacle" report under Article 10.
The draft also writes a new cybersecurity duty into the certification framework, though it is not a blanket rule for every operator already certified. Going forward, operators seeking certification, or renewing or amending an existing one after the revision takes effect, would have to promptly report any cyberattack, or suspected attack, through the farm ministry to the Cabinet Secretariat's National Cyber Director's Office, regardless of which part of their certified plan is affected. That duty is added as a fifth eligibility criterion in the fertilizer supply action guidelines. Plans already certified before the revision takes effect continue under the previous rules unless later amended, so the reporting duty phases in with new and changed certifications rather than applying overnight to every current holder.
| Provision | What it does |
|---|---|
| New escalation request (Article 8-2, Form 12-2) | Lets a certified operator formally ask the minister to seek cooperation from raw-material suppliers when its supply plan looks likely to fail. |
| Reporting overlap removed (Article 10) | An operator that files the new escalation request no longer also has to file the ministry's separate significant-obstacle report. |
| Cyber-incident reporting for new or renewed certifications (Form 1, guideline Section 5) | Operators certified, renewed, or amended after the revision takes effect must promptly report cyberattacks or suspected attacks, via MAFF, to the Cabinet's National Cyber Director's Office; existing certified plans keep the prior rules unless later changed. |
| Security certification recommendation (guideline Chapter 6) | Operators are encouraged to obtain the top-tier, four-star Supply Chain Security Assessment mark for themselves (system starts March 2027) and to use JC-STAR-labeled IoT devices; suppliers are encouraged toward three-star or four-star marks depending on circumstances. |
| Business-exit impact review (guideline Chapter 2) | If a fertilizer business closes and supply risk rises, the minister will investigate the impact and can prompt other operators to submit supply assurance plans. |
The draft guideline also recommends specific technical steps. Certified operators are encouraged to obtain the top tier, marked with four stars, under the forthcoming Supply Chain Security Assessment system, which is due to start operating in March 2027, and to use IoT equipment labeled under the JC-STAR security-labeling scheme, with routers, other communication devices and network cameras specifically flagged for the three-star level. Operators are separately asked to encourage their own material suppliers to obtain either the three-star or four-star mark under the same assessment system and to use JC-STAR-labeled IoT equipment, with the exact tier left to the operator's judgment based on each supplier's circumstances.
On the business-continuity side, the revised action guidelines add a new measure: if a fertilizer-related business shuts down or exits and that raises supply risk, the agriculture minister will investigate the impact and can prompt other operators to file supply assurance plans of their own.
None of the underlying documents name which companies currently hold fertilizer supply certification, and the Supply Chain Security Assessment system itself will not begin operating until March 2027, so that part of the guidance functions as advance notice rather than an immediate requirement. Comments on both the ordinance and the guideline revision are due by August 25, 2026, addressed to the ministry's Agricultural Production Bureau in Tokyo.