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New PSE and METI Filing Requirements for Cross-Border E-commerce in Japan in 2025
New regulations for cross-border e-commerce in Japan will take effect in 2025! Importer Representative Application Guide + Avoidance Tips
From December 25, 2025, Japan's revised four product safety laws will officially come into effect, bringing significant compliance requirements to the cross-border e-commerce industry: all overseas operators selling specific products to Japanese consumers through e-commerce platforms or self-built websites must designate a Japanese "domestic manager" (commonly known as a "Japanese proxy"), otherwise they will face severe penalties such as product sales bans and store closures. This "compliance bomb" has forced many cross-border sellers to respond urgently. This article will break down the core points of the new regulations, the application process, and avoidance tips to help sellers successfully expand into the Japanese market.
I. Background and Core Objectives of the New Regulations
In recent years, the model of overseas merchants selling products directly to Japanese consumers through e-commerce platforms such as Amazon Japan and Temu has developed rapidly, but the resulting product safety issues have become increasingly prominent. Some overseas products have not undergone compliance inspections, posing safety hazards. Furthermore, the lack of domestic responsible parties after accidents makes it difficult to assign blame, particularly concerning the safety of children's toys and electrical appliances.
To address this pain point, Japan's Ministry of Economy, Trade and Industry has introduced new regulations. The core objective is to bring overseas operators under regulatory oversight by requiring the designation of domestic managers, clarifying the product safety responsibility chain, ensuring imported products meet Japanese technical standards, and ultimately protecting the lives and property of Japanese consumers. The legal basis for these new regulations includes four acts: the Consumer Products Safety Act, the Electrical Appliance and Material Safety Act, the Gas Business Act, and the Act for Ensuring the Safety of Liquefied Petroleum Gas and Optimizing Transactions, covering a wide range of high-risk products.
II. Scope and Core Requirements of the New Regulations
(I) Applicable Entities All overseas operators selling "PSE/PS Marked Products" directly to Japanese consumers through e-commerce platforms (including third-party platforms and self-built websites), regardless of company size, must comply with the new regulations. It is worth noting that even small sellers must complete the relevant procedures if they are involved in the sale of designated products; there are no exemptions.
(II) Mandatory Requirements
* **Designation of a Domestic Manager:** Overseas operators must designate a qualified domestic manager within Japan to serve as the sole official liaison with Japanese government departments.
* **Product Compliance Certification:** Products sold must pass testing according to relevant Japanese technical standards and bear the prescribed PS/PSE marks (circular marks indicate self-inspection compliance, diamond marks indicate third-party certification compliance).
* **Obligations:** These include maintaining product inspection records (for at least 3 years), reporting incidents to the Consumer Affairs Agency within 10 days, and cooperating with product recalls.
(III) **Consequences of Violation:**
* **Legal Sanctions:** A maximum fine of 1 million yen or imprisonment for up to one year may be imposed. Companies and responsible persons may face criminal charges.
* **Market Ban:** Violating products will be removed from the platform. Repeat offenders will have their shops permanently banned and funds frozen.
* **Civil Compensation:** If product defects cause harm or loss to consumers, sellers will be liable for substantial civil damages. Small and medium-sized sellers may face bankruptcy.
* **Reputation Damage:** Information about violating companies and their domestic managers will be publicly exposed and blacklisted, impacting brand credibility. III. List of Product Categories Requiring Compliance The new regulations cover four main categories of products eligible for the PS/PSE mark:
* **Consumer Product Safety Law (Class 13):** Lighters, laser pointers, oil stoves, magnetic sets, water-absorbing and expanding balls, cribs, infant toys, etc.
* **Electrical Appliance Safety Law (Class 457):** Divided into round PSE (mandatory certification, such as sockets, extension cords, LED lights, DC power supplies, etc.) and diamond PSE (voluntary certification, such as air conditioners, refrigerators, microwave ovens, etc.);
* **Gas Industry Law (Class 8):** Gas water heaters, gas stoves, etc.
* **Liquefied Petroleum Gas Safety and Optimization of Transactions Law (Class 17):** Cartridge stoves, portable liquefied petroleum gas burners, etc.
Sellers must check their product categories to confirm whether they fall within the regulatory scope to avoid overlooking compliance requirements.
IV. Qualifications and Core Responsibilities of Domestic Managers
(I) Qualification Requirements
To become a domestic manager, the following mandatory conditions must be met:
**Having a fixed address in Japan (individuals need to provide a copy of their resident registration certificate, legal entities need to provide a certificate of registration);**
**Obtaining formal authorization from the overseas seller and being able to receive legal documents and disciplinary notices from Japanese government departments;**
**Being familiar with Japanese product safety laws and regulations and possessing the professional ability to perform duties;**
**Possessing fluent Japanese communication skills and being able to efficiently liaise with government departments;**
**Signing a formal agency contract with the overseas seller, clearly defining the rights and responsibilities of both parties.** (II) Core Responsibilities As the legal representative of the overseas seller, the domestic administrator primarily undertakes the following obligations:
Document Management: Maintain copies of product inspection records; for particularly specific products, copies of conformity inspection certificates are also required.
Supervisory Cooperation: Accept requests for reports, on-site inspections, and product submissions from Japanese government departments.
Report Submission: Submit a report annually from the date of the seller's declaration; if the agency agreement is to be terminated, an application must be submitted 30 days in advance.
Communication Support: Establish an effective communication mechanism with the Japanese Ministry of Economy, Trade and Industry to ensure timely and accurate information transmission.
Risk Control: Assist in handling emergency matters such as product recalls and hazard prevention.
It should be clarified that the domestic administrator only assumes administrative liaison and document management responsibilities; the primary responsibility for product quality and safety remains with the overseas seller.
V. Complete Process for Importer Representatives
Step 1: Selecting a Compliant Domestic Administrator
It is recommended to prioritize professional agency service organizations (such as administrative scrivener corporations or compliance service providers). Key aspects to verify include: whether they have a fixed address in Japan, familiarity with relevant laws and regulations, a track record of successful service cases, and adequate Japanese communication skills. Avoid choosing unqualified individuals or small agencies to prevent subsequent liability shirking or service interruptions.
Step Two: Sign a Formal Agency Agreement
The agreement must be written in Japanese or English and clearly include the following core contents:
The communication mechanism with the Japanese Ministry of Economy, Trade and Industry (addresses, telephone numbers, and emergency contact persons for both parties);
The cooperation method for product recall and hazard prevention measures;
The authorization statement for the domestic manager to receive government penalty notices;
The method of providing and retaining inspection records, certification documents, etc.;
The obligation to cooperate in report submission and on-site inspections. The agreement is a crucial basis for the subsequent division of rights and responsibilities and is recommended to be reviewed by a legal professional before signing.
Step Three: Prepare Application Materials
When applying to the Japanese Ministry of Economy, Trade and Industry, the following complete materials must be submitted:
Application form (using format No. 3);
Proof of the domestic manager's qualifications (legal entities provide a certificate of registration, individuals provide a copy of their resident registration certificate);
Letter of authorization (format 3-2), proving the legal authorization of the domestic manager;
Copy of the agency agreement;
Letter of guarantee (format 3-3), in which the domestic manager promises to meet the qualification requirements.
Step Four: Submitting the Business Application
After December 25, 2025, applications can be submitted through one of the following three methods:
e-Gov Electronic Application: Overseas sellers register a Japanese e-government account, fill in the application information online, upload relevant documents, and complete the application after review and approval;
Email Application: After filling in the application form, send it to the designated email address of the Bureau of Economy, Trade and Industry or the Product Safety Division of Japan, and wait for review feedback;
Security Network Agency Application: The application is submitted on behalf of the seller by a domestic manager or administrative scrivener through the Japanese "Security Network" system. This is suitable for sellers unfamiliar with Japanese language or Japanese administrative procedures.
If the application materials are incomplete, they will be returned for correction. It is recommended to check the completeness of the materials in advance to ensure a smooth application process.
VI. Common Pitfalls to Avoid
Beware of "Unlicensed Agents": Some agencies claim to offer "fast processing" but cannot provide legal qualification certificates, which may lead to application failure or subsequent legal repercussions. When choosing an agent, verify their registration certificate, resident certificate, and other core documents.
Contract Terms Must Be Clear: The agency contract must clearly define the authority, responsibilities, and termination procedures of the domestic manager to avoid disputes caused by ambiguity. Pay particular attention to clearly defining responsibilities for receiving government notices and handling incidents.
Product Labels Must Be Correctly Affixed: Different products require different PS/PSE label types (circular/diamond). Labels must be affixed correctly according to the certification method. Incorrect or missing labels will result in product bans.
Ignoring Subsequent Obligations: Successful application is not a one-time event. Inspection records must be kept as required, annual reports submitted on time, and reporting obligations fulfilled promptly after an incident. Failure to do so will result in penalties.
Misjudging Product Scope: Some sellers mistakenly believe that niche products are not within the scope of regulation. Verify each product on the four categories of regulations. Consult a professional compliance agency if necessary.
As a crucial market for cross-border e-commerce, Japan's new regulations, while raising entry barriers, also create a safer market environment for compliant sellers. Overseas operators must complete the designation and declaration procedures for their domestic administrators by December 25, 2025, to ensure compliant product sales. Sellers are advised to plan their application process in advance and choose reliable service providers to avoid missing out on Japanese market opportunities due to compliance issues. If encountering problems with qualification verification or document preparation during the application process, consult professional compliance service providers or Japanese administrative scriveners to ensure full legality and compliance.
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