Issuance of a Compliance Determination Letter
This page provides the "Non-Restricted Goods Certification" required for exporting Miki Pulley products. Please review the "Issuance of Non-Restricted Goods Certification" section below
, and once you agree to the terms, obtain the "Non-Restricted Goods Certification" from the "Certification Results" section that appears.
Purpose of the Legality Determination
A determination of export control status involves assessing whether an export license is required when “exporting goods” or “providing technology” to a foreign country.
This assessment determines whether the product in question falls under “list-based controls” or “catch-all controls” as defined by law.
When exporting products or machinery, customers are responsible for determining whether an export license application is required.
Handling of Compliance Determinations
The results of the export eligibility determination and the determination certificate are provided as information to support your export operations and do not constitute a guarantee or certification.
Please note that our company assumes no responsibility whatsoever regarding the feasibility of your license application or the outcome of such applications. Furthermore
, please use the results of the export eligibility determination and the determination certificate based on the effective date of the latest legal amendments. Preparation
of the Export Eligibility Determination
Please obtain a compliance determination certificate for each product and attach or transcribe that information onto the compliance determination certificate you will submit. Please note that we do not accept requests to add information to your own forms
, as this could cause significant inconvenience in the event of any errors.
| Listed Controls | If the goods you intend to export fall under the categories of sensitive goods with a particularly high potential for military diversion specified in Items 1 through 15 of "Appendix 1 of the Export Trade Control Order," or if the technology you intend to provide falls under Items 1 through 15 of the "Appendix to the Foreign Exchange Order," you must obtain prior permission from the Minister of Economy, Trade and Industry regardless of the destination country for the goods or the recipient of the technology. This system is referred to as "List Controls." |
| Catch-All Controls | Even when dealing with items other than those subject to list-based controls, if the exporter becomes aware that the goods to be exported or the technology to be provided could be used for the development, manufacture, use, or stockpiling of weapons of mass destruction, or for the development, manufacture, or use of conventional weapons, or if the exporter receives a notification (inform notice) from the Minister of Economy, Trade and Industry requiring an application for permission, permission from the Minister of Economy, Trade and Industry must be obtained prior to export or provision. This system is commonly referred to as “catch-all controls.”The scope of catch-all controls is defined in Item 16 of “Appendix 1 to the Export Trade Control Order” or “Appendix to the Foreign Exchange Order,” covering all goods and technologies other than listed controlled items, excluding foodstuffs and timber. In other words, items falling under the classifications listed in the Appendix to the Customs Tariff Act, as specified in Item 16, are subject to these controls. |
| U.S. Re-export Controls | Under the U.S. Export Administration Regulations (EAR), which govern the export of civilian goods, software, and technology that can be diverted for military purposes, re-exports from Japan of U.S.-origin goods or non-U.S.-origin goods incorporating U.S.-origin goods are subject to the "re-export controls" of the EAR. In Miki Pulley’s compliance determination results , this assessment under the re-export controls is listed as "U.S. Re-export Controls (EAR Determination)." |
Important Notes
Specification Indicators in Product Names
Since product names include a "specification code" (consisting of numbers, letters, symbols, hyphens, spaces, etc.) following the series/model/type designation, we have indicated this specification code with an "*" on the Conformity Certificate.
Note that the "specification" includes "specification instructions such as product shape, hole diameter, length, tolerances, mounting direction, capacity, reduction ratio, surface treatment, and options," as well as "special numbers for custom products requested by customers." However, since the product itself can be identified by the series/model/type, even if the values in the subsequent specification differ or if there is no specification, the "product itself is the same," so this has no impact on the conformity determination result.
- Examples of model numbers on compliance certificates - The
model number "SFC-060DA2-*" includes the following models:
・SFC-060DA2-12B-16B (Clamp Hub)
・SFC-060DA2-12B-16B-L60 (Specified Overall Length)
・SFC-060DA2-12BH-16BJ (With Keyway)
・SFC-060DA2-T017 (Special Number)
FAQs on Legality Determinations
What about products not listed in the website's compliance list?
Please contact us via the "Contact Form" and include the product name and model number. Since these are not standard items
, verification may take some time; even if we accept the order, delivery may take two weeks or more. Furthermore, for "external products," we must request them from the manufacturer, which takes approximately one month. If you are in a hurry, please contact the manufacturer directly via their website or other means to inquire about availability. Our response regarding our own products will be the same as the compliance determination on our website, and we will submit the manufacturer’s response as is.
How are parts and optional products evaluated for compliance?
Parts such as "elements," "rubber components," and "transmission belts," as well as optional products such as "roosters/clamps, brackets, and idlers," are available on our website; please check there
. Please note that the compliance certificates on our website do not cover all parts and optional products.
How do I determine compatibility for "discontinued products"?
We may discontinue products due to performance improvements or replacement with new models; however, please note that some products list the "old model number" in the compatibility certificate, so please check it.
What is the effective date of the relevant laws listed on the compliance determination document?
It refers to the date on which the legal amendment regarding the compliance determination came into effect. At Miki Pulley, we verify the compliance determination every time a notice regarding the latest legal amendment is issued. However, please note that depending on the content of the legal amendment, we may not list the effective date at that time. Please be advised that we do not accept requests to change or delete the effective date.
Can you provide a determination based on Appendix 2 of the Export Trade Control Order?
The goods listed in Appendix 2 include “diamonds,” “blood products,” “nuclear source materials and nuclear fuel materials,” “pesticides,” and “pharmaceuticals.” Since these are unrelated to the products handled by Miki Pulley, we do not perform determinations for them.
What about the “Parameter Sheet” and the “Item-by-Item Comparison Table”?
We do not issue them.
Can I create them in a specified format?
The Eligibility Determination Form is a document that you, the customer, are required to prepare. Since preparing or adding information to the form using a specified format would involve us acting on your behalf, we do not accept such requests due to the risk of liability issues arising from errors or causing inconvenience to you.
Can I add drawing numbers or other information to the Conformity Assessment Report?
Customer information such as drawing numbers and part numbers is not handled by our company. Furthermore, there is no need to add such information to the Conformity Assessment Report. Since errors could occur, we do not accept requests to do so.
Why is there an asterisk (*) next to the model number on the Conformity Assessment Report?
We use an asterisk (*) to simply indicate specifications that do not affect the identification of the product itself. These include combinations of hole diameters, differences in mounting methods to shafts, and special numbers assigned at the customer’s request. Therefore
, even if the model number includes an asterisk (*), it has no impact on the compliance determination result. Consequently, we do not accept requests to display the full model number on the compliance determination certificate. However, if necessary, customers are welcome to fill in the full model number on the certificate themselves.
Related websites of public agencies
The Export Trade Control Order and other relevant regulations are subject to periodic amendments.
For details, please refer to the following website.
*This link leads to an external site.
■Ministry of Economy
, Trade and Industry (METI) / Security Trade Control - Listed Controls -
Catch-All Controls - Information on Amendments to Related Laws and Regulations ■e-Gov (
Comprehensive Government Portal)
■Center for International Security Trade Information (CISTEC)
■Japan External Trade Organization (JETRO)
■Japan Machinery Exporters' Association (JMC)