If you want to sell your products in Japan without setting up a local entity, one question shapes everything else: Do you need an Importer of Record (IoR) in Japan? The short answer: It depends on your product category — and, for some categories, on whether you are prepared to register with Japanese authorities yourself. Here is how to work out which route applies to your products, before you commit to a logistics or marketplace setup that turns out to be non-compliant.
Japan regulates imports by product type, not by seller size or order volume. If your products fall under any of the six regimes below, someone with a legal presence in Japan has to take responsibility for them.
(1) Electrical Appliance and Material Safety Act (電気用品安全法, “Denan”)
The Act requires electrical products sold in Japan to bear a valid PSE mark together with the name of the notified business operator (届出事業者) — the manufacturer or importer that has filed a business notification with METI. 457 product items are designated, in two groups:
METI publishes the full statutory procedure in its PSE guideline (電気用品安全法 法令業務実施手引書).
(2) Consumer Products Safety Act (消費生活用製品安全法, CPSA)
This Act was established to prevent accidents arising from everyday consumer products that may cause injuries, burns or deaths, and to protect consumer safety and interests. Products designated as “specified products” must meet technical standards and bear the PSC mark — the category covers beds for babies and infants, portable laser applicators, bike helmets, lighters, pressure cookers and bath water heaters, among others.
An overview in English is available here.
A sub-category of children’s specified products (子供用特定製品) now also exists, with its own technical standards, age and warning labelling requirements, and a dedicated children’s PSC mark. Four products are currently designated:
Bed guards and strollers were added by a cabinet order announced on 3 April 2026 (METI press release). Transition periods apply: unmarked bed guards may be sold until 7 July 2027 and unmarked strollers until 7 July 2028. After those dates, products without the children’s PSC mark cannot be sold in Japan — which makes this a live deadline for any nursery or juvenile products brand planning a Japan launch.
(3) Gas Business Act and the LP Gas Act
Gas appliances carry the PSTG mark under the Gas Business Act, and LP gas equipment the PSLPG mark under the Act on the Securing of Safety and the Optimization of Transaction of Liquefied Petroleum Gas. English overviews are available here for PSTG and here for PSLPG.
(4) Pharmaceuticals and Medical Devices (PMDA)
Drugs, quasi-drugs, cosmetics and medical devices are regulated under the Pharmaceuticals and Medical Devices Act (薬機法). Placing these products on the Japanese market requires a marketing authorisation holder licensed in Japan — a foreign company cannot hold that licence directly and must appoint a designated holder. Cosmetics and supplements with functional claims are caught more often than overseas brands expect. Start with the PMDA English guidance.
(5) Food Sanitation Act (食品衛生法)
Food products, food additives, utensils, containers and packaging, and products intended for infants and small children (feeding bottles, eating utensils, plates, toys) must comply with the Food Sanitation Act, which ensures food safety for the public. Every commercial shipment requires an import notification to the quarantine station at the port of entry, filed by the importer in Japan — this is a filing no overseas entity can make on its own behalf.
The original Act No. 233 of 1947 is here; an overview including the 2018 amendment is here.
(6) Household Goods Quality Labeling Act (家庭用品品質表示法)
Covered products must carry a quality label in Japanese showing the name and a Japanese address of the manufacturer or importer. The regulated categories are listed in the official handbook and in more detail in Japanese under 対象品目. Typical categories include kitchenware, furniture, textiles and cleaning supplies.
If your products fall into any of the categories above, you need a party in Japan that imports your goods, takes the financial and legal risk for the Japanese market, and — where your packaging does not already comply — handles the labelling obligations. That is the classic Importer of Record role.
This is the part most guides written before 2026 get wrong. Until recently, PS mark products effectively had to be notified by a business located in Japan. Since 25 December 2025, the amended Product Safety Four Acts (Denan, CPSA, Gas Business Act, LP Gas Act) extend the notification regime to overseas businesses that sell directly to Japanese consumers, typically through an online marketplace.
Under the amended framework:
Note that a Domestic Administrator is not an Importer of Record. It represents you before the regulator, but it does not take title to your goods, does not clear customs, and does not assume the commercial risk. Which one you need — or whether you need both — depends on how your goods physically enter Japan.
Sources:
If your products do not fall into any of the regulated categories above, or if you have PS products for which you have appointed a Domestic Administrator (国内管理人), you may be eligible for direct cross-border import into Japan, shipping to a fulfilment centre or to the end customer without a Japanese importing entity.
For that, however, you need an ACP (Attorney for Customs Procedures). An ACP is a representative in Japan appointed to handle customs declarations and act as the contact point for Japan Customs on your behalf. It is a customs function only: an ACP does not act as importer, does not take ownership of the goods, and cannot satisfy a labelling requirement that calls for a Japanese importer name and address.
One product line can need more than one of these, so it is settling the question with a scheme that works for all your products.
Gloden Rule: In any case, never initiate your first shipment before enuring the adequate structure / duly registered partners are in place, to avoid storage fees at port of entry and product returned for failure to clear Customs.
Next Level Japan supports international brands across Japan market entry, ACP setup, product and page localization, and marketplace operation on Amazon Japan, Rakuten, and other Japanese marketplaces. From working out which regime your products fall under to getting them listed and selling, our team makes sure your products reach Japanese consumers smoothly and legally.
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