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Major update to METI registration in Japan, mandatory "Japanese agency" for cross-border e-commerce, to be implemented from December 25, 2025!
Time：
2025-11-05
Starting from December 25, 2025, Japan's newly revised Electrical Appliance Safety Law and four other product safety laws will be officially implemented. For the first time, overseas e-commerce sellers will be directly included in Japan's domestic product safety supervision system, and a "domestic manager" (Japanese representative) must be designated in Japan. The METI filing process and role requirements have undergone significant changes.
Starting from December 25, 2025, four newly revised product safety laws in Japan, including the Electrical Appliance Safety Law and the Consumer Life Product Safety Law, will be officially implemented. For the first time, overseas e-commerce sellers will be directly included in Japan's domestic product safety supervision system, and there will be significant changes in the METI filing process and role requirements.
The core requirement of the new regulations is that overseas operators who sell specific products directly to Japanese consumers through e-commerce platforms must designate a "domestic manager" (commonly known as "Ri Dai") in Japan and fulfill a series of obligations. Non compliant sellers will face product bans, fines, and even criminal liability.
Part 1: Applicable Objects of the New Regulations
For overseas operators who sell PSE/PS logo products directly to Japanese consumers through e-commerce platforms (such as Amazon Japan, Temu, AliExpress, International Station, etc.) or self built websites, they are listed as specific product importers (like existing manufacturers/importers) and are required to register and comply with technical standards and other regulations.
Part 2 Control Products
01. Electrical Appliance Safety Law (Electrical Safety Law)
Regulatory scope: covering 457 types of electrical products.
Diamond shaped PSE (Specific Electrical Equipment): 116 high-risk products, such as power adapters, lithium batteries, air conditioners, refrigerators, microwave ovens (over 700W), hair dryers, etc. It must be tested and approved by a METI accredited laboratory before it can be affixed.
Circular PSE (non-specific electrical equipment): 341 conventional products, such as LED bulbs, USB chargers, electric fans, electric blankets, etc. Self declaration of compliance with standards, no mandatory testing required.
Regulatory requirements:
Products that belong to the mandatory category must first pass the Japanese PSE certification and affix the PSE logo according to regulations before entering the Japanese market;
A Japanese version of the product manual is required, which must clearly indicate key technical parameters such as rated voltage and rated current to ensure accurate information for consumers;
For products powered by batteries, in addition to meeting basic regulatory requirements, they also need to comply with the special standards for battery safety in the Electrical Appliance Safety Law.
02. Consumer Product Safety Law (Consumer Safety Law)
Covering some daily necessities, infant and toddler products, lighters, heating equipment, etc. (13 categories require PS markings). Must comply with national technical standards, affix PS (or PSC) logo and file for record. The seller is required to purchase personal injury compensation insurance (with a maximum coverage of 10 million yen per victim and 30 million yen per year), and must fulfill the obligation of accident reporting (within 10 days) and recall cooperation.
03. Gas Industry Law (Gas Law)
Covering gas water heaters, gas stoves, etc. (8 categories). Must comply with PSG technical standards and be labeled.
04. Liquefied Petroleum Gas Security and Trading Standardization Law (Liquefied Petroleum Gas Law)
Covering card type gas stoves, portable LPG burners, etc. (17 categories). Must comply with PSLPG standards and be labeled.
Part 3 Domestic Manager in Japan ("Nihon")
Ri Dai "(domestic manager in Japan) is similar to" Ou Dai "and" Ying Dai "in the European market, and is a Japanese compliance agent for overseas sellers.
1. The main responsibilities of the Japanese representative are:
As the official liaison window between the Japanese government, consumers, and overseas companies.
Save and submit product safety information and materials as necessary.
Receive and handle product safety accident reports.
Assist in investigation and recall measures.
Ensure that the product complies with Japanese safety standards and labeling requirements.
Submit annual periodic reports to the Japanese Ministry of Economy, Trade and Industry.
2. The conditions that Japanese representatives need to meet:
Have a domicile in Japan (legal person or individual).
● Possess Japanese communication skills.
● Able to save inspection records, receive government notifications, and cooperate in accident response.
Sign a written commission contract with the seller and submit a copy of the contract and proof of residence to METI.
Part 4: Changes in METI Registration in Japan
1. Must be registered as a 'specific import operator'
Complete the registration with the Ministry of Economy, Trade and Industry (METI) before importing or listing the product.
If the seller is not in Japan, a domestic manager (Japanese representative) must be designated.
2. Change of filing subject
The filing subject has changed from the original Japanese importer to an overseas seller. This means that Chinese e-commerce sellers now need to act as filing entities and designate a responsible person in Japan to complete the filing.
It is worth noting that prior to this, METI filing was mainly completed by Japanese importers and manufacturers, and the new regulations clearly pointed the responsibility to overseas sellers.
3. Filing process and cost changes
The original filing process has been relatively simplified, and the new regulations have been restructured into a clear three-step process, resulting in increased operational complexity and time costs. The cost composition is divided into two categories based on the processing method (self processing/agency service), as follows (the cost is subject to the official or service provider quotation at the time of actual processing):
Self application (requires a domestic administrator):
Step 1: Register GBiz id - The same company and person in charge only need to register once a year, which is the basic admission process.
Step 2: Register as a domestic administrator in Japan - Register according to product dimensions and re register once a year.
Step 3: Apply for METI registration - Register according to product dimensions and reapply once a year.
Proxy service application (using the domestic administrator provided by the service provider):
Step 1: Register GBiz id - The fee includes domestic administrator proxy services, and other requirements are the same as self application.
The requirements and fees for the second and third steps are exactly the same as those for self application.
Cost Summary: The new regulations have added two prerequisite steps, "GBiz id registration" and "domestic administrator qualification registration," on the basis of the original process. The compliance cost and operational complexity have significantly increased, and budget and process planning need to be done in advance.
Part 5 Seller Response Guide
Step 1: Quickly self check and identify 'high-risk products'
Confirm whether the product belongs to the mandatory PS certification category, especially household appliances, lithium batteries, gas appliances, children's products, etc., and promote the testing process and compliance labeling work as soon as possible.
Step 2: Determine the domestic manager (Japanese representative) and partner
Find reliable Japanese agency partners and sign compliance commission contracts. Japanese representatives should have a legal residence in Japan, possess professional knowledge of product safety, and be able to handle government documents and accident investigations.
Step 3: Complete the registration with the Ministry of Economy, Trade and Industry
Prepare the declaration form, registration certificate of the domestic administrator, authorization letter, commission contract and other materials, complete the registration with the Ministry of Economy, Trade and Industry (METI) before importing or listing the product, and become a "specific import operator".
Step 4: Establish product safety records
Including test reports, qualification certificates, accident response plans, etc. Ensure that the product complies with Japanese safety standards and labeling requirements.
Part 6 Frequently Asked Questions and Answers
Q: What requirements can one meet to become a Japanese representative?
1. Having a fixed residence in Japan (individuals need to provide a copy of their residence permit, while legal entities need to provide a certificate of registration).
2. Authorized by overseas sellers to receive government legal documents and notifications.
3. Familiar with Japanese product safety related laws and regulations.
4. Possess sufficient Japanese communication skills and be able to communicate fluently with government departments.
5. Sign a formal commission contract with overseas sellers to clarify the rights and responsibilities of both parties.
Q: Will Japan take responsibility for product quality?
No. Domestic managers are mainly responsible for administrative liaison and document preservation, and the first person responsible for product safety is still the overseas seller themselves. If there are quality issues with the product, the ultimate responsibility shall be borne by the seller.
Q: What other obligations does the seller have besides designating a day agent?
The core obligation of the seller is to ensure that the product complies with Japanese technical standards and bears the correct PSE/PS logo. When a major product accident occurs, it must be reported to the Japan Consumer Agency within 10 days and a product recall may need to be implemented.
Q: What penalties will non-compliance face?
This revision is not only a formal filing, but also has mandatory legal effect:
Legal penalty: up to 1 year of imprisonment or a fine of 1 million yen (individual/legal representative); The maximum compensation limit for a single personal injury accident is 100 million yen.
Market ban: All e-commerce platforms simultaneously remove all products; Listed on the blacklist of the Ministry of Economy, Trade and Industry for 10 years; The synchronization of affiliated enterprises is restricted (if the legal representative is the same or holds more than 30% of the shares).
Platform/Customs measures: Customs detention or destruction, mandatory product recall and announcement; Prohibit the import of subsequent products; Cancel business qualification (up to 3 years).
Q: I'm just a small seller, do I still need to handle it?
As long as you sell specific products to Japanese consumers through e-commerce platforms, regardless of their size, they are within the regulatory scope. Non compliance may result in the product being taken down from the platform, detained or destroyed by customs, and even legal liability may be borne.
Q: What is the key time point?
December 25, 2025: The new regulations will officially come into effect, and products listed thereafter must strictly comply with the requirements of the new regulations.
Products that have been filed before the implementation of the new regulations: It is recommended to complete the listing as soon as possible. After listing, they are not subject to the new regulations and can be sold according to the original mode.
Products listed after December 25, 2025 must strictly reapply for registration in accordance with the new regulations. Products that have not been registered are prohibited from being listed for sale.
December 25, 2025 is approaching, and the Japanese market is ushering in a new era of regulation. Overseas sellers who have not been registered or have no Japanese agents will completely lose their "legal identity" in the Japanese market, and their products may be taken down at any time, even facing the risk of platform account suspension. It is recommended that cross-border sellers take immediate action to complete compliance processes such as product testing, certification application, and Japanese agency selection as soon as possible, and complete product compliance layout to avoid affecting normal sales.
As a professional third-party testing and certification service organization, Jiayu Testing has qualifications such as CMA, CNAS, CBTL, and has obtained laboratory accreditation from multiple authoritative certification agencies at home and abroad. It is equipped with advanced instruments and equipment, has a skilled professional technical team, rich industry service experience, and strong testing technology capabilities. It is proficient in various regulatory standards and provides one-stop compliance services such as Japanese PSE certification and Japanese METI filing to ensure that products meet relevant regulatory requirements and help your products enter the Japanese market smoothly. Welcome to contact us at 400-9269-886!
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