What units are required for the designated import business application and inspection records?
A thorough explanation of how to handle SKU, color variations, and renewals

When overseas businesses are going through the process of filing for designated import business registration, one of the biggest headaches is “In what unit should applications and inspection records be prepared?”.

We will provide a thorough explanation based on the latest guidelines on questions that you will inevitably face in practice, such as “Is it necessary to prepare them for each SKU (stock keeping unit)?” and “How should different colors and sizes be handled?”

The four revised product safety laws will come into effect on December 25, 2025. When starting activities as a designated importer, the most important thing is to correctly understand the management units for “notification” and “self-inspection records.” If you make a mistake here, you risk incurring excessive effort or, conversely, violating the law (failure to notify).

1. Unit of business notification: The basic unit is “type classification”

First, let’s talk about the units for “business notifications” submitted to the Ministry of Economy, Trade and Industry. This is not done by SKU, but by “model classification” as defined by law.

• What is a model classification? : A model classification is a group of products that share common safety-related elements such as structure, materials, and performance.
• Difference from SKU: For example, even if there are two types of AC adapters with the same specifications, one in white and one in black (2 SKUs), if the safety-related structure is the same, they can be reported together as “one model classification.”

2. In what units are inspection records (6 legal items) required?

Next, we will discuss the units of “self-inspection records” that domestic administrators must keep. This is a major point in practice.

① Color Variations:

Generally, if the color difference alone does not affect safety performance, it can be recorded together in the same inspection record.
However, among the six legally required items, the “quantity of products inspected” must accurately record the total number and breakdown of each color.

② Different SKUs:

For SKUs with different specifications (voltage, current, major components, structure, etc.), separate inspection records must be created for each.

• OK: Combine the 100V-only model (white) and the 100V-only model (black) on one record.
• NG: Combine the 100V model and the 240V model on one record, even though they have different safety ratings.

③ Renewals and Specification Changes (Minor Changes)

Caution is required when changing or renewing parts of a product.

• Changes that affect safety (such as changes to the circuit board or the material of the outer casing): This will be treated as a new “type,” and new notifications and individual inspection records will likely be required.
• Changes that do not affect safety (such as changing the logo design): This will be within the scope of the existing type, so inspection records can continue to be kept.

3. In-country custodian-company collaboration: when should records be submitted?

A major practical question is, “How can domestic managers manage records when they don’t know when goods are imported?”

If goods are shipped directly from overseas to customers, domestic managers don’t need to track the arrival of each and every package. The process is as follows:

• It’s OK to wait for periodic submissions from the company: In-country administrators do not collect records every time a product is imported. Instead, they receive and store inspection records submitted by the company on a “manufacturing lot” or “monthly” basis.
• “Linking” is important: When Japanese authorities request “Please provide records for this product sold on a certain date,” the in-country administrator’s role is to be ready to immediately present the records held by the company that correspond to that product (lot). For this reason, it’s ideal for companies to also share a comparison table of serial numbers and lot information that allows them to determine which products correspond to which inspection records.

4. Inspection timing when shipping directly to customers from overseas

For companies that use a direct shipping model, the timing of when inspections should be carried out is extremely important. The bottom line is that the legal timing is “before shipping to customers in Japan (i.e. before shipping from the factory or warehouse).”

• Complete inspections “before shipping” rather than “after ordering”: Instead of conducting inspections after a customer places an order, you must complete voluntary inspections of product groups (lots) that are in stock “for Japan” before shipping to Japan, and create records that meet the six legal requirements.
• Inspection record creation unit: There is no need to create a record for each individual shipping box. Create one inspection record for each group of products (production lot) made to the same specifications at the same factory at the same time.
• Flow that direct shipping companies should follow:
  1. Manufacturing and packaging for Japan are completed at the factory.
  2. At this time, a voluntary inspection (appearance, electrical conductivity, etc.) is conducted and records are created.
  3. Only lots that pass inspection are stocked for shipping.
  4. The created records are sent to the domestic administrator (or shared via cloud, etc.).

5. Lot Management and Renewal Considerations

When a product undergoes a minor change, even if the model classification remains the same, the “first lot with the new specifications” must be subject to strict new inspections and records.

まとめ：ビジネスモデル別の注意点