Amended Public Notice on Export and Import of Strategic Items Strengthens Semiconductor Controls and Exporter Obligations

On July 13, 2026, the Ministry of Trade, Industry and Resources issued an administrative notice of a partial amendment to the Public Notice on the Export and Import of Strategic Items. The amendment (“Amended Notice”) took effect on September 1, 2026.

The Amended Notice introduces two principal changes. First, it revises the dual-use item and munitions control lists to reflect updates adopted under international multilateral export control regimes (e.g., the Wassenaar Arrangement, the Nuclear Suppliers Group, the Missile Technology Control Regime and the Australia Group). Notably, export controls on high-performance integrated circuits and advanced semiconductor manufacturing equipment have been significantly strengthened.

Second, the Amended Notice abolishes the “Exporter’s Written Pledge” that exporters previously had to submit when applying for a strategic-items export license, and in its place, newly establishes substantive exporter obligations.

Key details of the changes are as follows.

Revisions to Dual-Use Item and Munitions Control Lists

Annexes 1 through 4 of the Amended Notice, covering dual-use items and munitions control lists, have been revised.

The control framework for high-performance integrated circuits (“ICs”) and advanced semiconductor manufacturing equipment has been restructured, and certain items subject to control have been expanded. The key changes are as follows:

Expansion of controls on high-performance ICs
Reorganization of export control classification numbers for related computers and electronic assemblies
Reorganization of the control framework for semiconductor manufacturing equipment
Additional controls on specific silicon or silicon-germanium (“Si·SiGe”) epitaxial growth equipment, lithography equipment, extreme ultraviolet (“EUV”) pellicles and advanced deposition equipment

The following table summarizes the principal changes to the dual-use item control list:

Item	Control Number		Key Changes
Item	Before Amendment	After Amendment	Key Changes
High-Performance ICs	3A903	3A501.a.16	Deletes the requirement for an I/O bidirectional transfer rate of 600 GByte/s and expands control based on a Total Processing Performance (“TPP”) threshold of 6,000 or more
Computers/Electronic Assemblies Incorporating High-Performance ICs	4A902	4A507	Reorganizes export control classification numbers for computers, electronic assemblies and components that contain ICs falling under 3A501.a.16
Items Related to Field Programmable Logic Devices (“FPLDs”)	-	3A502.i (new)	Adds controls over specific electronic assemblies, modules and equipment that contain FPLDs
Semiconductor Manufacturing Equipment Framework	3B901–3B904	3B501–3B504	Reorganizes the control framework for advanced semiconductor manufacturing equipment
Si·SiGe Epitaxial Growth Equipment	-	3B501.a.1 (new)	Adds controls over specific high-performance lithography equipment
Lithography Equipment	-	3B501.f (new)	Adds controls over specific high-performance lithography equipment
EUV Pellicles	-	3B501.m (new)	Adds controls over specific pellicles for EUV lithography
Deposition/Process Integration Equipment	-	3B501.n (new)	Adds controls over specific ALD, CVD, plating and advanced process integration equipment

Abolition of Exporter’s Written Pledge and Codification of Exporter Obligations

The Amended Notice abolishes the “Exporter’s Written Pledge,” which previously had to be submitted as part of a strategic-items export license application. In its place, substantive exporter obligations have been expressly set out in the main body of the Amended Notice through the introduction of Article 18-3.

Before applying for an export license, an exporter must verify the identity of the parties to the transaction (i.e., the buyer, ultimate consignee and end-user). Where there is doubt as to the identity of such parties or the intended use of the export item, the exporter must immediately suspend the export—even after an export license has been granted—and consult with the head of the licensing authority.

Even after export, where doubts arise as to the identity of the parties to the transaction or the intended use of the item, or where the exporter is requested by such parties to give prior consent to resale, re-export or re-transfer abroad, the exporter must consult with the head of the licensing authority.

3.	Practical Implications

First, companies should reassess whether handled items are now controlled under the Amended Notice. Because the control framework for high-performance ICs and advanced semiconductor manufacturing equipment has been reorganized and the scope of controlled items expanded, it will be necessary to review whether items previously determined not to constitute strategic items have now become subject to control.
Second, companies should check for new classification or licensing requirements. Where handled items fall under controlled items whose classification framework has changed, companies should verify whether they are required to newly obtain a classification determination or an export license.
Third, companies should inspect compliance with the newly codified exporter obligations. Instead of the abolished “Exporter’s Written Pledge,” the obligations to verify the parties to the transaction, and to suspend export and consult with the licensing authority upon the occurrence of irregularities have now been directly set out in the main body of the Amended Notice.
Finally, companies should note that violations may carry criminal penalties. These exporter obligations may be imposed as conditions of an export license, in which case a violation of such license conditions may be subject to criminal penalties. Accordingly, companies should take particular care to ensure full compliance with the newly codified obligations.

[Korean Version]

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