Japanese Market Requires Designation of Japanese Representative

Attention all cross-border sellers on the Japanese site! In just 2 months, a compliance reform regarding "whether you can continue to sell goods" will officially land --- On December 25, 2025, 4 product safety-related regulations in Japan, including the Consumer Product Safety Act and the Electrical Appliance and Material Safety Act, will be officially implemented. For the first time, overseas e-commerce sellers will be directly incorporated into Japan's domestic regulatory system, with a mandatory requirement to designate a "Domestic Administrator (Japanese Representative)". The new regulations aim to bring overseas operators into the scope of supervision, ensure product safety, and protect consumer rights.

Applicable Objects

Targeted at overseas operators who directly sell PSE/PS mark products to Japanese consumers through e-commerce platforms (such as Amazon Japan, Temu, AliExpress, Alibaba International, etc.) or self-built websites. They will be classified as specified product importers (the same as existing manufacturers/importers), required to undergo record-filing registration, and strictly mandated to comply with technical standards and other regulations.

Domestic Administrator (Japanese Representative)

Refers to the statutory agent of the overseas seller within Japan, serving as the sole official liaison bridge with the Japanese Ministry of Economy, Trade and Industry (METI).

Qualification Requirements for the Domestic Administrator (Japanese Representative)

1. Have a fixed residence in Japan (individuals must provide a copy of their residence certificate/Juminhyo, and corporations must provide a certificate of registered matters).

2. Be officially authorized by the overseas seller, and be able to receive government legal documents and notices.

3. Be familiar with Japanese laws and regulations related to product safety.

4. Possess sufficient Japanese communication skills to communicate fluently with government departments.

5. Sign a formal entrustment contract with the overseas seller to clarify the rights and responsibilities of both parties.

Q&A

1. If there is no importer information, can we still rent it from JJR LAB?

After the new regulations take effect on December 25, renting will no longer be permitted.

2. If the client can provide importer information, can JJR LAB operate the registration on their behalf?

Yes, account information needs to be provided: ID and password.

3. If the registration is currently completed using JJR LAB's importer information, is there a validity period?

Yes, after the implementation of the new regulations, the original registration will become invalid.

4. The record-filing has already been completed previously, and the products have already been labeled with the original filing merchant's label. What should be done?

After December 25, if the previously rented importer information is delisted/taken down, it can no longer be used. If it has not been taken down, it can be used temporarily. Currently, the regulations are not completely clear, so we will have to wait and see after the implementation.

5. For sales made through e-commerce platforms, how should it be handled if there is no actual importer information?

For platform sales, find the logistics company responsible for shipping to Japan to act as the filing merchant representative.

6. If a company has multiple store entities, how should the record-filing be handled?

Every main entity of an e-commerce store needs to correspond to one filing merchant's information (If one company has many store entities, they cannot share the same filing merchant information. For example, 10 entities require 10 corresponding filing merchants). The e-commerce company entity will be recorded and reflected on the filing certificate.

7. Must the filing merchant be a company?

The filing merchant can also be an individual, but the corresponding residence certificate (Juminhyo) needs to be provided.