Do I need to become a “Specified Importer” even if I’m not a manufacturer?
New obligations and measures that overseas retailers must take

To all overseas retailers (sellers) who think, “We’re not the manufacturer, so this doesn’t concern us.” If you continue to think that way, you may not be able to continue selling in Japan after December 25, 2025.

In this article, we will explain why non-manufacturer stockists and sellers need to become “designated importers” and the important responsibilities they must bear.

We often receive questions from many retailers who purchase products from overseas factories and manufacturers and sell them on Japanese sites such as Amazon and Rakuten: “We’re not a manufacturer, but do we need to register our import business with the Japanese government and become a designated importer?”

The answer is, “If you are an entity that sells directly to the Japanese market, you need to register as a ‘designated importer’ even if you’re not a manufacturer.”

1. Why are “retailers” designated importers?

The revised law, which will come into effect on December 25, 2025 (Reiwa 7), will consider the responsible party to be the “window that directly provides products to Japanese consumers,” which sends products directly from overseas to Japan.

Even if you are a retailer that does not have its own manufacturing facilities, as long as you are selling under your own shop name, you are considered the “person responsible for imports” in Japan, i.e., a “designated importer.”

All legal safety responsibilities (compliance with standards, inspections, and recall responses) will be borne by you, not the manufacturer.

2. Six legally required items of “self-inspection records” that domestic managers must keep

Designated importers are obligated to verify the safety of the products they ship and to prepare and keep records of the verification. These records must be available for immediate presentation by an administrator in Japan upon request by the authorities.

Inspection records must include all of the following “six statutory items” as stipulated by Japanese law:

1. Product type (what type of product?)
2. Inspection date (when was the inspection performed?)
3. Inspection location (where was the inspection performed?)
4. Name of inspector (who was responsible?)
5. Quantity inspected (how many units were inspected?)
6. Inspection results (did it pass? What were the numerical results?)

In-person advice: The general “test reports” sent by overseas manufacturers often contain incomplete information about these projects. The special name is the person’s name and the exact date. It is very important to have a contract that stipulates that a report that includes these six items must be issued every time.

3. Flow for efficiently utilizing “manufacturer’s inspection data”

Even if you do not have your own testing equipment, you can achieve both legal obligations and efficiency by following the steps below.

• Step 1: Instruct the manufacturer. Instruct the manufacturer to conduct inspections (appearance, insulation, etc.) in accordance with Japanese laws and regulations and to prepare records that cover all six statutory items.
• Step 2: Sending data to the in-country manager. Send the inspection records received from the manufacturer to the in-country manager either as is or with a Japanese translation.
• Step 3: Storage by the in-country manager. The in-country manager verifies that the received records meet the six statutory items and stores them appropriately in Japan (records are usually required to be stored for three to seven years).

4. Application Procedures and Future Outlook

Notification of specified import business operators is currently accepted in the following ways:

• Currently (before implementation): Applications can be made directly to the Ministry of Economy, Trade and Industry by email, or via a domestic administrator via the Security Network.
• In the future (after December 25, 2025): Overseas businesses will be able to apply directly online through Japan’s e-government portal, “e-Gov.”

Summarize: Proper Record-Keeping Protects Your Business