Japan’s Product Safety 4 Laws Reformed: Extra-Territorial Compliance Duties for Foreign E-commerce Operators
Key Words: Japan Product Safety, Product Safety 4 Laws, PSE Regulation, PSC Regulation, METI Compliance, PS Mark, Specified Importer Japan, Cross-Border E-Commerce Japan, Overseas Seller Regulation, Direct-to-Consumer Imports Japan, Domestic Manager Requirement, Authorized Representative Japan, METI Business Notification, Japan Product Compliance, Technical Documentation Japan, Product Recall Japan, Accident Reporting Japan, Lithium-Ion Battery Regulation Japan, Electrical Appliance Certification Japan, Japan Market Entry Compliance, Consumer Goods Regulation Japan.
I. Introduction[1]
Driven by the rapid expansion of cross-border e-commerce and recurring safety incidents involving overseas-manufactured electrical appliances, lithium-ion batteries, and household devices, the Japanese government has substantially revised its product-safety framework. These amendments extend the statutory obligations traditionally imposed on domestic importers to a new category of foreign operators that sell regulated products directly to consumers in Japan.
Under this revised regime, overseas manufacturers, marketplace sellers, and D2C brands may be legally treated as “Specified Importers” even without any physical presence, employee, or entity in Japan. This designation triggers a comprehensive set of regulatory duties, including technical-standards compliance, documentation retention, accident reporting, and the requirement to appoint a Japan-based Domestic Manager who will act as the regulatory representative before METI and other authorities.
These changes represent a deliberate shift by the Japanese government to eliminate enforcement blind spots that emerged as digital platforms increasingly enabled direct-to-consumer sales from abroad. As a result, a wide range of overseas operators (particularly those handling electrical appliances, lithium-ion-battery products, gas devices, and other regulated consumer goods) must reassess their Japan-facing business models and prepare for a structured compliance cycle.
The sections below outline the key elements of this new framework, focusing on:
• the statutory structure under the Product Safety 4 Laws;
• the definition and scope of a Specified Importer;
• mandatory obligations imposed on overseas operators; and
• a practical roadmap for achieving compliance.
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[1] This communication is provided as a service to our clients and friends and is for informational purposes only. It is not intended to create an attorney-client relationship or constitute an advertisement, a solicitation, or professional advice as to any particular situation. Further, the legal framework related to e-commerce and consumer protection laws in Japan is subject to frequent amendments and evolving regulatory interpretations. Readers are strongly encouraged to verify the most up-to-date information and seek advice from counsel before taking any action.