(FAQs) about Japan’s PSE Four Product Safety Laws

Effective from December 25, 2025, new regULations will be implemented for operators selling products coveRED by the Four Product Safety Laws directly to consumers in Japan from overseas.

For details, click the title below to jump to the relevant page:

Countdown to December 25 Enforcement! Sellers of These Categories on Amazon Japan, Take Immediate Action!

For reference, visit the help page:

https://sellercentral.amazon.co.jp/help/hub/reference/external/GJXRBNGX52EMJZZB?locale=zh-CN

This document addresses the most concerned questions of sellers, categorized into 7 sections for targeted reading:

1. Certification Bodies, Certification Reports & Certificates of Conformity

2. Importers & Qualifications of Specified Importers

3. Domestic Responsible Persons

4. METI Notification Procedures & Requirements

5. Product Labeling & Nameplates

6. Existing Products & Inventory

7. PSC (Consumer Products Safety Act) & Toys for Infants and Young Children

Certification Bodies, Certification Reports & Certificates of Conformity

Q1: Do all PSE-regulated products require a Certificate of Conformity (CoC)?

A: No, not all products require a CoC. A CoC is only mandatory when the electrical appliance manufactured or imported by the operator completing the business registration falls under the category of specified electrical appliances.

Q2: Do products with the Circular pse mark require a CoC in addition to a test report?

A: Products marked with the Circular PSE Mark (non-specified electrical appliances) do not require a CoC. Only products marked with the Diamond PSE Mark (specified electrical appliances) need a CoC.

Importers & Qualifications of Specified Importers

Q1: Which overseas operators qualify as specified importers? Does selling on Amazon from overseas fall under this scope?

A: Overseas operators selling directly to consumers in Japan via e-commerce platforms such as Amazon are classified as specified importers and are required to complete business registration.

Q2: I am a seller/overseas operator. The manufacturer or factory has already completed business registration with an importer in Japan. Do I still need to submit a new registration? Do overseas operators not need to appoint a Domestic Responsible Person? If I entrust a Japanese importer to complete the business registration, is it sufficient to sign a contract and submit the registration?

A:

①　If an overseas operator sells directly to consumers in Japan without going through a Japanese importer, it must register as a specified importer, appoint a Domestic Responsible Person, and ensure product compliance with technical standards.

②　If the overseas operator’s products are sold to Japanese consumers through a domestic operator with a contractual relationship (e.g., sales contract), the domestic operator will be recognized as the regulated importer in Japan, and the overseas operator is not required to complete separate registration.

③　Regulated importers (Japanese domestic importers) prior to the law amendment will remain regulated entities after the amendment takes effect.

Domestic Responsible Persons

Q1: If sales are conducted by a Japanese legal entity, is a Domestic Responsible Person still required?

A: If an overseas operator has an importer (Japanese legal entity) in Japan, the importer will remain a regulated entity under the amended law. In this case, the overseas operator does not need to appoint a Domestic Responsible Person (a Domestic Responsible Person is only required when the overseas operator registers as a specified importer).

Q2: Can we appoint the operator who previously completed our business registration as the Domestic Responsible Person?

A: Yes, provided that the operator meets the following criteria for a Domestic Responsible Person:

Criteria for Domestic Responsible Persons

1. Has a doMICile in Japan (a certificate of registered matters or a resident certificate must be submitted during registration).

2. Is authorized by the registered operator (specified importing operator) to receive official notices of disciplinary actions and opportunities to provide opinions from the Minister of Economy, Trade and Industry (METI) (a power of attorney in the format specified by METI must be submitted during registration).

3. Has no record of violating relevant laws and is not likely to violate laws in the future (i.e., must be a law-abiding entity/individual).

4. Possesses Japanese language proficiency for communication purposes.

5. Has a written entrustment contract with the registered operator covering the following items (the contract must be submitted during registration; it may be in Japanese or English—if in English, a Japanese translation is required):

①　Communication mechanism with METI

②　Product recall procedures and measures to prevent the escalation of risks and hazards

③　Matters related to the authorization specified in Item 2 above

④　Provision and retention of inspection records and copies of Certificates of Conformity

⑤　Matters related to the submission of reports, on-site inspections, and product presentations

⑥　Other matters approved by the Minister of Economy, Trade and Industry

6. Has appropriate operational capabilities and management systems to perform the duties of a Domestic Responsible Person.

Q3: Must the Domestic Responsible Person be the same entity as the registered operator?

A: No. When an overseas operator completes business registration, it must appoint a Domestic Responsible Person in Japan who can take responsibility for product safety, and this person must be a different entity/individual from the registered operator. The appointee must meet the above criteria for Domestic Responsible Persons.

Q4: Is a Domestic Responsible Person required to be added during the validity period of the business registration, or can we wait until the registration expires?

A: Business registrations submitted to the Japanese government do not have an expiration date.

Q5: What happens if we fail to sign a contract with a Domestic Responsible Person by December 25? Is there a grace period?

A: Failure to appoint a Domestic Responsible Person will result in the business registration being deemed invalid, even if the registration documents are submitted. Sales will not be permitted in this case.

Q6: If we stop selling PSE-regulated products and only sell products not covered by the Four Product Safety Laws, is a Domestic Responsible Person still required?

A: For products not regulated by the Four Product Safety Laws, PSE marking is not required, and thus no Domestic Responsible Person needs to be appointed. However, please note that even non-regulated products may fall under the scope of other laws and regulations, which must be complied with.

Q7: Is a Domestic Responsible Person required for products with the Circular PSE Mark?

A: Yes. Products with the Circular PSE Mark are regulated by the Four Product Safety Laws. Therefore, business registration with the government and appointment of a Domestic Responsible Person are mandatory.

Q8: Can one overseas operator appoint multiple Domestic Responsible Persons? Additionally, can the same Domestic Responsible Person be appointed for multiple business registrations?

A:

①　Business registration is filed by product category (electrical appliance classification), not by operator. Therefore, different Domestic Responsible Persons can be appointed for different product categories covered by separate registrations.

②　The same Domestic Responsible Person can be appointed for multiple registrations covering different product categories.

METI Notification Procedures & Requirements

Q1: How soon after product sales begin must business registration be completed?

A: The timeline varies by law:

①　Electrical Appliance and Material Safety Act: Pursuant to Article 3 of the Act, registration documents in the specified format must be submitted to the Minister of Economy, Trade and Industry within 30 days of commencing business operations. Note that the "business commencement date" refers to the actual date of manufacturing or importing (customs clearance) electrical appliances, as well as the date of internal decisions or preparatory actions for the business.

②　Consumer Products Safety Act: Business registration is required to display the PSC Mark. Under this Act, only specified products bearing the PSC Mark may be sold or displayed for sale. Therefore, registration must be completed before the product is sold or displayed for sale. Please allow sufficient time for the authorities to review and accept the registration documents.

Q2: Is business registration filed in the name of the overseas operator or the Domestic Responsible Person?

A: Business registration documents are submitted in the name of the overseas operator, and the information of the Domestic Responsible Person must be included in the registration form.

Q3: When filing a notification via the Hoan Network (Safety Network System), should the importer information be filled with the Japanese Responsible Person or the Chinese enterprise?

A: When filing via the Hoan Network, the "manufacturer/importer" field must be filled with the name and address of the importer. Additionally, the information of the Domestic Responsible Person appointed by the overseas operator must be entered in the relevant section.

Q4: Does the name of the overseas operator need to be indicated as the notifying entity on the product nameplate? Does the name of the Domestic Responsible Person need to be included?

A: Pursuant to Article 17 of the Enforcement Regulations of the Electrical Appliance and Material Safety Act, the notifying entity name displayed on the product nameplate must be that of the overseas operator (the registered entity). The name of the Domestic Responsible Person does not need to be displayed on the nameplate.

Q5: If the same product is sold in multiple stores, does each store need to complete separate business registration?

A: No. If multiple stores on Amazon are operated by the same enterprise, business registration is filed in the name of the enterprise, not by individual store.

Q6: When selling products from the same manufacturer to multiple e-commerce platforms, how many business registrations are required?

A: Business registration with the government is based on the classification of electrical appliances manufactured or imported, not the number of e-commerce platforms the products are sold on.

Q7: Can PSE-regulated products with different specifications be included in a single business registration? Is there a limit to the number of products per registration?

A: Registration is filed by "electrical appliance classification". You must select the appropriate "model classification" corresponding to the electrical appliance category. There is no limit to the number of products that can be included in a single registration.

Q8: How can I confirm whether my business registration has been accepted?

A:

①　If registration documents are submitted directly to the government via email, a confirmation of acceptance will be sent to the registered operator’s email address.

②　If applying electronically via the Hoan Network, an acceptance confirmation email will also be sent to the applicant’s email address.

Q9: Can I check past business registrations?

A:

①　For registrations filed before the law amendment, you can request access to the records from the government in accordance with relevant legal provisions.

②　For registrations filed after the amendment takes effect, the relevant information will be published and available for inquiry on the official registration information disclosure platform by late December.

Q10: If the applicant for the Diamond pse certificate of Conformity is the factory, does the seller need to apply for a new Certificate of Conformity?

A: If the "seller" is classified as an "importer", the seller must obtain and retain a copy of the Certificate of Conformity issued by the factory (manufacturer). Additionally, starting from December 25, 2025, if the holder of the Diamond pse certification sells products directly to consumers via online marketplaces, the holder will be classified as a "specified importer" and does not need to apply for a new Certificate of Conformity.

Q11: Must the Certificate of Conformity be retained as a physical original? Can it be stored electronically?

A: Pursuant to Article 9, Paragraph 1 of the Electrical Appliance and Material Safety Act, the Certificate of Conformity must be retained as a physical original. Electronic storage is not permitted.

Product Labeling & Nameplates

Q1: Is it compliant to display the PS Mark on the product packaging box?

A: The requirements vary by product type:

①　Toys for infants and young children (under the Consumer Products Safety Act): The mark is generally required to be displayed on the product itself. However, if the mark is clearly shown on the packaging, display on the product can be omitted. In all cases, the mark must be placed in a conspicuous location using a method that prevents easy removal.

②　Other products regulated by the Four Product Safety Laws: The mark must be displayed on the surface of the electrical appliance or main unit in a conspicuous and non-removable manner.

Q2: Must the PS Mark be printed directly on the product itself, or can it be applied as a sticker?

A: The law requires the mark to be displayed using a method that prevents easy removal. Therefore, a sticker is acceptable as long as it is printed with non-erasable content and is not easily peeled off.

Q3: I am an overseas operator selling directly to Japanese consumers. Do I need to change the notifying entity name on the product nameplate from the Japanese agent to my company’s name?

A:

①　If selling directly to Japanese consumers, the overseas operator must register as a specified importer, and the notifying entity name on the nameplate must be the registered name of the overseas operator (specified importer).

②　If the overseas operator’s products are sold to Japanese consumers through a domestic agent (with a contractual relationship), the pre-amendment regulated importer (Japanese domestic importer) will remain the regulated entity. In this case, no change to the nameplate is required.

Existing Products & Inventory

Q1: Which documents need to be newly prepared or obtained under the new regulations?

A: Key points for business registration as a specified importer under the amended law are as follows:

Registration Methods

Registration can be submitted via:

1. The Hoan Network (filed by a domestic agent or representative; a power of attorney is required if the agent is not a licensed administrative scrivener).

2. Email (direct application by the overseas operator).

Submission via the Hoan Network through a Domestic Responsible Person is recommended for a smoother process.

Submission Office

①　If the Domestic Responsible Person’s office, business premises, store, or warehouse is located within the jurisdiction of a single Regional Bureau of Economy, Trade and Industry, submit the application to that regional bureau.

②　If the locations span multiple jurisdictions, submit the application directly to METI headquarters.

For contact email addresses, please refer to:

https://www.meti.go.jp/product_safety/tokuteiyunyu/tokuteiyunyu.html

Required Documents

The following documents must be submitted for business registration as a specified importer:

1. Business registration application form (must include Domestic Responsible Person information)

2. Certificate of registered matters (if the Domestic Responsible Person is a legal entity) or copy of resident certificate (if an individual)

3. Power of attorney

4. Copy of the entrustment contract

5. Affidavit

For detailed requirements, visit the official website:

https://www.meti.go.jp/product_safety/tokuteiyunyu/tokuteiyunyu.html

Q2: For products stored in Amazon Fulfillment Centers (FS) before the law amendment, do they need to be discontinued or returned after the amendment takes effect? Can products stored in FS before December 25 continue to be sold, while only new inventory after December 25 needs to comply with the new regulations?

A: Products stored in FS warehouses after completing customs clearance before the law amendment can continue to be sold after the amendment takes effect.

Q3: For inventory stored overseas, do we need to update the product nameplates to comply with the new regulations?

A: Yes. For overseas inventory, if products regulated by the Four Product Safety Laws are sold directly to Japanese consumers via online marketplaces after December 25, 2025:

1. Business registration with the Japanese government must be completed.

2. The PS Mark must be displayed on the product.

3. The nameplate must indicate the registered operator’s name (the overseas operator).

Q4: When must sellers take action for products already on sale? What happens if business registration is not completed?

A: Starting from December 25, 2025, products regulated by the Four Product Safety Laws sold directly to Japanese consumers via online marketplaces must bear the PS Mark. Sellers must complete business registration in advance to legally display the mark. Failure to register will result in the inability to display the PS Mark on specified products, and sales will be prohibited.

PSC (Consumer Products Safety Act) & Toys for Infants and Young Children

Q: I am an overseas operator. For toys for children under 3 years old that are already on sale and in stock (overseas or in FS warehouses), do I need to complete business registration to continue selling after December 25?

A: Toys stored in FS warehouses after completing customs clearance before the law amendment can continue to be sold after the amendment takes effect without additional registration.