Effective from 25 December 2025, Japan will implement sweeping reforms to its product safety regime, altering the way overseas businesses can access its consumer market.  

Amendments to four key product safety laws – the Consumer Product Safety Act, the Electrical Appliances and Materials Safety Act, the Gas Business Act, and the Act on the Securing of Safety and the Optimisation of Transaction of Liquefied Petroleum Gas – will, for the first time, place foreign e-commerce sellers under the same compliance obligations as domestic Japanese companies.  The amendments mark a dramatic shift from the previous compliance model of importer liability. 

The Japanese Ministry of Economy, Trade and Industry (METI) (経済産業省) has stated that the amendments are designed to close long-standing regulatory gaps created by e-commerce activity, with a view to upholding and reinforcing consumer safety standards more consistently.  

Shifting responsibility from importer liability to overseas seller liability

Japan has traditionally relied on local importers and distributors as the first line of responsibility for product safety. 

Under the existing compliance model, importers were legally obliged to ensure that products met any relevant technical standards, had the appropriate safety markings or certifications, and complied with incident reporting requirements.

However, the large influx of e-commerce activity has disrupted this model. 

Many overseas businesses now sell directly to Japanese consumers through online marketplaces such as Amazon Japan and Rakuten, bypassing traditional import channels.  

Despite numerous safety incidents such as fires caused by lithium-ion batteries and malfunctioning electrical appliances, authorities struggled to identify a legally responsible party within Japan under the existing compliance model.  

The emerging product safety issues are particularly pertinent when, in an earlier report from June 2024, the Japanese government reported that the business-to-consumer market had reached nearly 14 trillion yen in 2022, more than double its size 10 years earlier.  

New Domestic Administrator requirements 

Amendments made to the four product safety legislations mean that from 25 December 2025, any overseas business selling regulated goods directly to Japanese consumers must:

1. Appoint a Domestic Administrator (国内管理人).  This person or entity must have a registered address in Japan and will act as the seller’s official legal contact. The representative is responsible for compliance with safety laws, incident reporting, product recalls, and communication with regulators such as METI and the Consumer Affairs Agency (消費者庁).
2. Register with METI as an importer.  All overseas sellers must submit product information, safety documentation, and the details of their appointed Domestic Administrator through METI’s system.
3. Accept equivalent liability to Japanese companies. Once appointed, the Domestic Administrator bears joint liability with the overseas seller for any compliance failures, including fines, civil damages, and in some cases criminal penalties.

Affected product categories

The four product safety legislations apply to hundreds of items designated as products liable to cause harm, spanning 493 categories as of June 2024. This includes:

• Electrical appliances (e.g. extension cords, LED lighting, microwaves, refrigerators).
• Gas appliances (e.g. water heaters, space heaters, cooktops).
• Liquefied Petroleum Gas equipment (17 categories of LPG-related devices).
• Children’s products: a new high-priority category covering toys, prams, child seats, and tableware for children. Products in this category will require a Children’s Safety (CS) mark, based on international standards such as EN 71 and ISO 8124, though in some cases Japan’s domestic standards impose stricter requirements.

Depending on the specific products being sold, additional requirements such as product labelling in Japanese, safety documentation, and insurance coverage may also be mandatory. 

Enforcement and penalties

The consequences of non-compliance are severe:

• Financial penalties: fines up to 100 million yen for failing to register or label products correctly.
• Criminal liability: up to one year’s imprisonment or personal fines of 1 million yen for company representatives.
• Administrative sanctions: product recalls, import bans, and cancellation of business qualifications for up to three years.
• Market exclusion: e-commerce platforms will be required to delist products or suspend accounts.
• Public disclosure: METI will publish details of registered sellers, their Domestic Administrator, and any compliance violations on a public database accessible to consumers and other competitors.

This ‘name and shame’ mechanism is designed to effectively create a compliance credit score, where one breach may damage a brand’s reputation in Japan, and deter other consumers from purchasing from a seller. 

The amendments also impose a requirement on digital marketplaces to act as enforcers. 

If a seller fails to meet compliance obligations, such as responding to a recall order or is found distributing non-compliant goods, platforms are legally obliged to remove product listings, and may potentially freeze funds and suspend seller accounts.  

Future compliance 

Japan’s new Domestic Administrator requirement clarifies the legal grey area that existed under the previous compliance model of importer liability.  

Whilst these new measures will undoubtedly entail higher costs and administrative complexity, the reforms aim to create a safer, more transparent, and ultimately more trustworthy e-commerce ecosystem in Japan. 

For more information, contact our team at TBA Global.