In recent years, cross-border online sales have surged, leading to an influx of products with unverified safety reaching Japanese consumers. Accidents involving children’s products, in particular, have occurred, highlighting the following issues:

  • Unclear responsibility of overseas business operators.
  • Limited safety regulations for children’s products in Japan.

→ Legal reform became necessary to strengthen consumer protection.

  1. Consumer Product Safety Act
  2. Gas Business Act
  3. Electrical Appliance and Material Safety Act
  4. Act on the Securing of Safety and the Optimization of Transaction of Liquefied Petroleum Gas

For overseas e-commerce businesses, the relevant laws are primarily the “Consumer Product Safety Act” and the “Electrical Appliance and Material Safety Act” .


1. Clarification of Overseas Businesses (Specified Importers) as Regulated Entities

Companies (e.g., from China, South Korea, etc.) that sell directly to Japan via online malls are now defined as “Specified Importers.”
Overseas businesses selling directly to Japanese consumers are newly subject to regulation.
→Requirement to appoint and notify a “Domestic Andinistrator” (Representative in Japan).

Figure 1: Targets of the new regulations (specific importers) (Ministry of Economy, Trade and Industry)
https://www.meti.go.jp/policy/consumer/seian/shouan/contents/tokuteiyunyu_kaisei_English.pdf

2. Establishment of the Domestic Administrator System

This position serves as the “proxy within Japan” for overseas business operators.

Requirements for Domestic Administrators
  • Must have a domicile (address) within Japan.
  • Must be able to communicate in Japanese.
  • Must have a contract with the overseas business operator stipulating necessary matters.
Duties of Domestic Administrators
  • Periodic confirmation of the communication structure with the Specified Import Business Operator.
  • Prior reporting in the event of contract termination to prevent a “vacancy” (unappointed state).
  • Understanding and reporting on the status of legal compliance.

➡ The Domestic Administrator effectively bears the responsibility for ensuring safety.

【Obligations】

  1. Obligation to preserve copies of inspection records.
  2. Obligation to accept orders for the collection of reports, on-site inspections, and product submission.

【Reports Required from Domestic Administrators】

  1. Every year following the date the Specified Import Business Operator submits a notification, the Domestic Administrator is required to report the following:
    * Phone number and email address of the notified business operator.
    * Status of the communication structure.
  2. If the Domestic Administrator intends to terminate the contract with the Specified Import Business Operator, they must report this at least 30 days prior to the scheduled date of termination.

3. Strengthening Obligations for Transaction Digital Platforms (DPF)

“Transaction DPF Providers” such as Amazon and Rakuten will also bear a certain level of responsibility.

  • They will be required to take measures such as suspending the listing of problematic products.
  • If there is a risk of harm, the government can request the deletion of listings.

4. Regulations for Specified Products for Children (Newly Established)

A new classification for “Specified Products for Children” has been added. Initially, the following two products are subject to this regulation (Figure 2):

図2:子供用特定製品への製品の追加(経済産業省)
https://www.meti.go.jp/policy/consumer/seian/shouan/contents/toys_kaisei_Japanese.pdf
Attention to Business Operators: Procedures Required by the Four Product Safety Acts (Ministry of Economy, Trade and Industry)
https://www.meti.go.jp/english/policy/economy/consumer/product_safety/index.html

Infant Toys
After December 25, 2025, all manufactured and imported products will be required to bear the round “Children’s PSC Mark” .

Infant Beds

図3:改正製品安全4法による、新たな規制の対象者、対象製品等の具体的な内容について(経済産業省)
https://www.meti.go.jp/product_safety/consumer/pdf/2025Jan_block_setumei.pdf
Attention to Business Operators: Procedures Required by the Four Product Safety Acts (Ministry of Economy, Trade and Industry)
https://www.meti.go.jp/english/policy/economy/consumer/product_safety/index.html

■ Overseas Business Operators (Specified Import Business Operators)

■ Domestic Administrators

  • Maintain a communication structure with the overseas business operator.
  • Support compliance with laws/regulations and submit reports.
  • Provide prior reporting when terminating the contract.

Domestic Sellers / E-commerce Malls

  • Strengthened safety labeling for children’s products.
  • Ensuring the safety of products from overseas business operators.
  • Early removal of dangerous products from transaction platforms.
  • Effective Date: December 25, 2025
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Outline of the Act to Partially Amend the Consumer Product Safety Act and Other Acts (Ministry of Economy, Trade and Industry)
https://www.meti.go.jp/policy/consumer/seian/shouan/contents/tokuteiyunyu_kaisei_English.pdf
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