Effective December 25, 2025, amendments to Japan’s Four Product Safety Acts, including PSE and PSC, came into force, introducing new regulatory obligations for foreign businesses selling products directly to consumers in Japan. Foreign entities selling PS Mark-regulated products directly to Japanese consumers are now required to comply with technical standards, submit notifications to METI, and appoint a Domestic Administrator (sometimes referred to as “Domestic Representative”) in Japan.  

1. Overview of the New Regulations

1-1. Regulations on Overseas Sellers

With the growth of cross-border e-commerce, an increasing number of foreign sellers have been offering Four Product Safety Acts regulated products (e.g., PSE, PSC products) directly to Japanese consumers. Under the previous legal framework, however, the entity responsible for product safety was often unclear.

Under the amended law, foreign sellers who supply regulated products directly to consumers in Japan via online marketplaces or similar platforms are defined as “Specified Importers” if they conduct business involving the import of designated products. Specified Importers must comply with obligations equivalent to those imposed on domestic manufacturers and importers, including:

• Filing notifications with authorities

• Ensuring products comply with technical safety standards

To ensure enforceability, Specified Importers are also required to appoint a Domestic Administrator (sometimes referred to as “Domestic Representative”) in Japan.

Requirements for a Domestic Representative include:

• Having a registered address in Japan

• Ability to communicate in Japanese

• Entering into a written delegation agreement covering prescribed responsibilities

 

Regulated Product Categories

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1-2. New Safety Requirements for Children’s Products

Unlike the U.S. and EU, Japan historically lacked comprehensive mandatory safety standards for children’s products, allowing certain items to be sold without adequate safety verification.

The amendment introduces a new regulatory category: “Specified Products for Children.”
Two product categories have been designated:

• Baby beds

• Toys intended for children under three years old

From December 25, 2025 onward:

• Products must comply with technical safety standards, and

• Display required labeling (age indication, safety warnings, usage instructions)

Products meeting applicable requirements may display the Child PSC Mark and be legally sold.

 

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2. Appointment of a Domestic Administrator

Foreign entities classified as Specified Importers must appoint a Domestic Representative and file notification with METI.

ACP JAPAN provides a combined solution, offering:

• ACP (Attorney for Customs Procedures) Service

• Domestic Administrator (Representative) Service under the Four Product Safety Acts

This enables foreign sellers to comply with regulatory requirements while importing and selling legally in Japan.

 

PSE and PSC Domestic Administrator Service

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Reference

Ministry of Economy, Trade and Industry (METI) –
“From December 25, 2025, foreign businesses will also be required to submit notifications.”

 

 

Track Record – Attorney for Customs Procedures (ACP) Services

We have supported import and export operations in Japan for over 200 clients across more than 40 countries.  

What is ACP? – Attorney for Customs Procedure

In principle, Japan Customs does not permit a foreign entity to act as the Importer of Record (*IOR). But the foreign entity can act as a non-resident importer (IOR – Importer of Record) if you appoint an ACP (Attorney for Customs Procedure) who can handle the customs procedure on your behalf.

We, ACP Japan provide this service as being ACP. On behalf of non-resident clients, we support by ensuring the import customs procedure. We support many import projects including E-commerce such as Amazon’s FBA (Fulfillment By Amazon) program and Rakuten for the international sellers.

Please feel free to contact us!

Our ACP Service: The Best Solution for the Japan Importer of Record (IOR) and Exporter of Record (EOR)

ACP is an effective solution for addressing Importer of Record (IOR) and Exporter of Record (EOR) requirements in Japan. Through our ACP service, non-resident entities located outside Japan are able to import and export goods as Non-Resident IOR and EOR.

Below is an overview of our basic scope of work, together with a diagram illustrating the operational structure of the ACP service. Once ACP registration is completed, the non-resident entity can act as the Importer of Record (IOR) and Exporter of Record (EOR) in Japan.

Scope of Work – How We Can Assist

• Consultation with Japan Customs to support successful ACP registration.
• Liaison with relevant stakeholders, including freight forwarders and Japan Customs, to ensure the smooth and compliant import and export of goods.
• Assistance in preparing and reviewing import and export clearance documentation.
• Support in the calculation of customs value, in accordance with the Japan Customs Tariff Act.
• Assistance with advance rulings on HS classification, customs valuation, and rules of origin.
• Import compliance support for regulated products, including Domestic Administrator (sometimes referred to as “Domestic Representative”) Services under the Product Safety Acts (PSE/PSC) and food-related products regulated under the Food Sanitation Act.
• Support for security export control, including list-based classification, catch-all control assessment, and assistance with export license applications to the Ministry of Economy, Trade and Industry (METI).
• Record-keeping support in accordance with Article 95 of the Japan Customs Law.
• Provision of professional trade and customs advisory services to address and resolve issues that may arise during import or export operations.

**Both import and export activities can benefit from the use of an ACP (Attorney for Customs Procedures). This support is applicable in scenarios where a non-resident acts as the Importer of Record (IOR) for imports and as the Exporter of Record (EOR) for exports.

Three Steps to Initiate Shipments Under the ACP Program:

1. Quotation Review to Contract Conclusion: Upon receiving your contact details, we will promptly provide a quotation for your review.
2. Commencing the Registration of ACP (Attorney for Customs Procedures) to Japan Customs: This process is generally completed in about two weeks.
3. Initiation of First Shipment, Import/Export