Introduction: Safety Legislation Adapting to Digitalization and Globalization Japan's "Four Product Safety Laws" (Seihin Anzen Shihou) refer to the Electrical Appliances and Materials Safety Act (PSE Act), the Consumer Products Safety Act (PSC Act), the Gas Utility Industry Act, and the Liquefied Petroleum Gas Act. These laws form the foundation for ensuring the safety of products consumers use daily.

However, the market has changed dramatically in recent years. In particular, the spread of e-commerce has led to an explosive increase in cases where overseas manufacturers sell products directly to Japanese consumers (Cross-Border E-Commerce). This has brought to light problems such as the inflow of irresponsible products that do not comply with Japanese regulations, and the lack of clarity regarding accountability when accidents occur.

To address this challenge, the laws are being revised, with the introduction of the "Domestic Manager (Kokunai Kanrinin)" system being a key focus. This article delves into the background of the legal revision and the role of the Domestic Manager.

Background to the Legal Revision: Cross-Border E-Commerce and the "Blind Spot" in Product Safety Traditional laws designated the entity that imports a product into Japan as the "Specified Importer" (Tokutei Yunyuu Jigyo-sha), placing safety responsibility on them and securing a point of contact for accident response. However, this mechanism of responsibility has become non-functional with cross-border e-commerce.

1. Absence of the Specified Importer
When an overseas manufacturer sells directly to a Japanese consumer, there is no entity in Japan that "imports as a business" (the Specified Importer). This creates the following "blind spot":

• Absence of Conformity Check:
  No one verifies if the product meets Japanese technical standards (PSE, PSC, etc.).
• Absence of Accident Response Contact:
  If a product causes a serious accident, the Consumer Affairs Agency or the Ministry of Economy, Trade and Industry (METI) has no domestic responsible party to contact.
• Impossibility of Recall and Retrieval:
  Effective product recalls and consumer alerts regarding problematic products cannot be carried out.

2. New Risks from the Increase in IoT Products
With the rise of IoT (Internet of Things) products, such as smart home appliances and wireless devices, cybersecurity is now also considered part of product safety. A legal framework capable of addressing not only physical safety but also digital risks, such as information leakage, is required.

Introduction and Role of the "Domestic Manager" System The mechanism introduced by the legal revision to fill this "blind spot" and resolve the safety issues caused by cross-border e-commerce is the "Domestic Manager" system.

1. Definition of the Domestic Manager

• Obligation to Appoint:
  Required when an overseas manufacturer sells regulated products (Specified Products, etc.) directly to Japanese consumers.
• Role:
  Acts as the domestic point of contact between the overseas manufacturer and Japanese consumers to fulfill legal obligations.

2. Specific Duties of the Domestic Manager

1. Technical Standards Conformity Confirmation:
   Confirms that the imported product meets Japanese technical standards and maintains the necessary certification documents (design drawings, test data, etc.).
2. Securing Inspection Systems:
   Ensures a system is in place for post-import batch inspections or spot checks to confirm that product quality is consistently maintained.
3. Contact Point for Complaints and Accidents:
   Serves as the centralized domestic contact point for consumer complaints and accident information, coordinating with the overseas manufacturer for a swift response. They are obligated to promptly report serious accidents to METI.

3. Significance of the System's Introduction
By mandating the appointment of a Domestic Manager, overseas manufacturers must establish a responsible entity within Japan that complies with Japanese law when selling in the Japanese market. This significantly enhances the effectiveness of Japan's product safety system, enabling consumer safety assurance and the tracing/response to accidents.

Differences and Cooperation Between the Specified Importer and the Domestic Manager Both the Specified Importer and the Domestic Manager system share the goal of being responsible for product safety, but their legal positions differ.

It is easiest to understand this as: the Specified Importer is responsible for their own import liability, while the Domestic Manager acts on behalf of the overseas manufacturer's sales liability.

Summary and Next Steps: Reinforcing Safety Regulations is Essential The revision of the Four Product Safety Laws and the introduction of the Domestic Manager are measures to strengthen consumer protection in the era of globalization. It is essential for Japanese importers and companies considering direct sales from overseas to understand this new system and build a business model that clearly defines "who bears responsibility, where, and how."

Furthermore, since the Domestic Manager is subject to strict checks from Japan's METI, it is recommended to entrust this role to a trustworthy company. AirtTrade's PS Domestic Manager System coordinates with METI and has a particularly strong relationship with Rakuten Ichiba in Japan. If your company has not yet found a Domestic Manager, please feel free to inquire!