Fully Compliant with the Amended “Four Product Safety Acts”
Fully Compliant with the Amended “Four Product Safety Acts”
Domestic Administrator Service for PSE / PSC Products
Starting from JPY 5,000 per month
Domestic Administrator Service for PSE / PSC Products
Starting from JPY 5,000 per month
Overview of the Domestic Administrator Service
Overview of the Domestic Administrator Service
By entering into an agreement with Commerce Robotics, Overseas E-commerce Companies can appoint a Domestic Administrator in Japan and receive comprehensive services in accordance with the amended Product Safety Four Acts.
Domestic Administrator Cloud System for PSE / PSC Products
Domestic Administrator Cloud System for PSE / PSC Products
After entering into an agreement with Commerce Robotics, overseas e-commerce businesses will be issued an account for the Domestic Administrator Cloud System. Prior to the commencement of sales, inspection records for the applicable products shall be uploaded to the cloud system. Commerce Robotics will review and approve the submitted inspection records. Subsequently, the reporting of inspection records to the competent authorities will be carried out in an integrated manner through the Domestic Administrator Cloud System.
Application Procedure for the Domestic Administrator Service
Application Procedure for the Domestic Administrator Service
Application Process
| No. | Procedure | COMMERCE ROBOTICS | Client Responsibility |
|---|---|---|---|
| 1 | Response and Submission to Hearing Sheet | Provide a hearing sheet. | Respond to two types of information in the sheet: 1) Company information 2) Application mark / application category / number of SKUs 3) Items to be confirmed |
| 2 | Insurance Confirmation (Mandatory Contract Requirement) | Insurance confirmation. | 1) Submit insurance certificate covering product liability 2) Submit documents that allow confirmation of registrant information |
| 3 | Quotation ① Submission of Quotation ② Submission of Draft Contracts ・Basic Agreement ・Power of Attorney ・Agreement ・Certificate of Authority |
The following information will be provided by email: 1) Official Quotation 2) Drafts of contracts required for conclusion (final version): ・Basic Agreement ・Power of Attorney ・Agreement ・Certificate of Authority |
① Internal Approval for the Quotation ※Payment shall be made on an annual prepayment basis. ② Review of Draft Contract Documents ※Except for the Basic Agreement, the documents are provided in prescribed formats. Please review the notation of your company information and check for any typographical errors or omissions. |
| 4 | Contract Execution ① Execution of Electronic Contract via CloudSign ② Issuance of Invoice ③ Confirmation of Payment |
① Contract Documents Sent via CloudSign ② Invoice Sent by Email ③ Confirmation of Payment |
① Contract Documents Sent via CloudSign ② Invoice Review and Payment ※Account issuance will take place after confirmation of payment. ※Commencement of all services will take place after confirmation of payment. |
| 5 | System Account Issuance | Issue Login Account | Management of the Login Account ※Account management shall be the responsibility of your company. |
| 6 | Proxy Application to "Hoan-Net" (Free Support) ※Available upon request only |
If proxy application via Hoan-Net is required, free support will be provided. | If a proxy application to Hoan-Net is required, please indicate this in your response to the hearing sheet. |
Domestic Administrator AI Chatbot
(Provided Free of Charge)
Domestic Administrator AI Chatbot (Provided Free of Charge)
Companies under contract for the Domestic Administrator Cloud System may use the Domestic Administrator AI Chatbot eeBot. developed in-house by Commerce Robotics, free of charge.
This chatbot automatically responds to inquiries regarding classification determinations required for the preparation of notification documents for electrical appliances and related products, as well as questions concerning applicable laws and regulations.
System Usage Fee for the Domestic Administrator Service
System Usage Fee for the Domestic Administrator Service
From
JPY 5,000 per month
※Special discounted rates are available for overseas companies that have entered into an AirTrade service agreement with us.
Overview of the Amendments to the Four Product Safety Acts and the Designation of Specified Import Business Operators and Domestic Administrator
Overview of the Amendments to the Four Product Safety Acts and the Designation of Specified Import Business Operators and Domestic Administrator
The amendments to the Four Product Safety Acts will come into effect on December 25, 2025. As a result of these amendments, overseas companies from countries such as China, South Korea, and the United States that sell PS Mark–regulated products to Japan via online marketplaces will be defined as Specified Import Business Operators. Specified Import Business Operators are required to submit a notification prior to commencing business operations, ensure that products offered for sale conform to the applicable technical standards, and appoint and file a notification for a Domestic Administrator in Japan.
For further details, please refer to the Electrical Appliance and Material Safety Act, the Consumer Product Safety Act, and other relevant laws and regulations.
Background of the Legal Amendments
With the increase in online sales from overseas, the importation of products with unverified safety into Japan has been rising. In this context, issues have become evident, including the lack of clarity regarding the responsibility of overseas business operators and insufficient safety regulations for products intended for children.
Accordingly, institutional reforms were implemented to strengthen consumer protection. These amendments will come into effect on December 25, 2025.
Role of the Domestic Administrator
Under the Electrical Appliance and Material Safety Act, a Domestic Administrator is defined, for example, as “a person who causes the importer to take the necessary measures within Japan to prevent the expansion of danger and harm arising from the electrical appliances imported.”
While responsibility for ensuring the safety of electrical appliances and compliance with inspection obligations rests with the Specified Import Business Operator, the Domestic Administrator is responsible for retaining copies of inspection records submitted by the Specified Import Business Operator, responding to requests for reports and on-site inspections, and submitting periodic reports to the Ministry of Economy, Trade and Industry (METI).
(Details of the obligations of the Domestic Administrator are described below.)
Who May Be Appointed as a Domestic Administrator
A Domestic Administrator is required, among other conditions, to have an address in Japan, be capable of communicating in Japanese, and have the necessary matters stipulated by contract with the overseas business operator. (Article 15-2 of the Ministerial Ordinance on Technical Standards, etc. for Specified Products under the jurisdiction of the Ministry of Economy, Trade and Industry)
A Specified Import Business Operator must appoint a corporation or individual that satisfies these requirements as its Domestic Administrator.
How Does METI Confirm That a Domestic Administrator Meets the Required Criteria?
- Having an address in Japan
→ A certificate of registered matters (corporate registry extract) or a copy of the resident record of the Domestic Administrator - Being granted the authority to receive notifications of administrative actions taken by the competent minister under the relevant laws from the notifying business operator
→ A Certificate of Authority prepared by the Specified Import Business Operator - Compliance with laws and regulations applicable to specified products; possession of Japanese-language communication ability; and appropriateness of the methods for performing the duties of the Domestic Administrator
→ An agreement prepared by the Specified Import Business Operator - Existence of a contractual relationship stipulating the necessary matters
→ A copy of the service agreement
What Obligations Do Specified Import Business Operators Have?
The principal obligations of a Specified Import Business Operator are as follows:
- Notification of business operations to the Ministry of Economy, Trade and Industry (METI) or the relevant Bureau of Economy, Trade and Industry
- Appointment and notification of a Domestic Administrator
- Obligation to comply with technical standards
The Specified Import Business Operator must verify through inspections that imported products conform to the applicable technical standards in Japan. In addition, inspection records must be prepared and retained. Copies of the inspection records shall be submitted to the Domestic Administrator.
- Affixing of the PS Mark
- Obligation to respond to and report accidents upon becoming aware of them
- Taking necessary measures to enable the Domestic Administrator to appropriately respond to governmental requests for reports, on-site inspections, orders for product submission, and other regulatory actions
Method for Filing Notification of a Domestic Administrator by a Specified Import Business Operator
A Specified Import Business Operator is required to submit an Import Business Notification Form to the Ministry of Economy, Trade and Industry (METI) or the relevant Bureau of Economy, Trade and Industry, and in that notification form must state the name and address of the Domestic Administrator, and, in the case of a corporation, the name of its representative, and must also attach a copy of the Service Agreement, a Certificate of Authority, an Agreement, and a Power of Attorney.
Is it acceptable to attach an electronically executed copy of the Service Agreement to the “Import Business Notification Form”?
A copy of a contract that has been executed electronically is acceptable.
Inspections to Be Conducted by Specified Import Business Operators
Depending on the products to be imported, there are cases where certification by a METI-registered third-party conformity assessment body, conformity inspections, and self-inspections/external testing are required, and cases where only self-inspections/external testing are required. In all cases, the retention of inspection records is mandatory, and such records must be submitted to the Domestic Administrator.
PSE Classification, Inspections, and Retention of Inspection Records
| PSE Classification | Third-Party Certification | Conformity Inspection | Self-Inspection | Domestic Administrator | Retention of Inspection Records |
|---|---|---|---|---|---|
| Specified Electrical Appliances (Diamond-shaped PSE) |
Not Required | Required | Required | Required | Required |
| Electrical Appliances Other Than Specified Electrical Appliances (Round PSE) |
Not Required | Not Required | Required | Required | Required |
PSC Classification, Inspections, and Retention of Inspection Records
| PSC Classification | Certification | Conformity Inspection | Self-Inspection | Domestic Administrator | Retention of Inspection Records |
|---|---|---|---|---|---|
| Specially Specified Products (Diamond-shaped PSC) |
Required | Required | Required | Required | Required |
| Specified Products Other Than Specially Specified Products (Round PSC) |
Not Required | Not Required | Required | Required | Required |
| Infant Beds *1 (Diamond-shaped Children’s PSC) |
Required | Required | Required | Required | Required |
| Infant and Toddler Toys for Children Under 3 Years of Age *2 (Round Children’s PSC) |
Not Required | Not Required | Required | Required | Required |
※1 Infant Beds
Products bearing the old mark will be required to be re-labeled with the diamond-shaped Children’s PSC Mark.
Transitional measure: From March 25, 2027, products bearing the old mark may no longer be sold, and caution is required. As there is a strong possibility that the scope of products subject to the diamond-shaped Children’s PSC Mark will be expanded in the future, it is necessary to continue checking announcements from the Ministry of Economy, Trade and Industry even after December 25, 2025.
※2 Infant and Toddler Toys
For products manufactured or imported on or after December 25, 2025, the round “Children’s PSC Mark” will be mandatory. The designated target age must be based on reasonable grounds. For example, if a baby’s photograph is used on the packaging, it would be difficult to designate the target age of the product as 3 years and over. Indications consisting solely of numbers, symbols, or foreign languages are also prohibited.
Inspection of Electrical Products Already Sold in Japan
Inspections are required. The Electrical Appliance and Material Safety Act is not a certification system administered by the Ministry of Economy, Trade and Industry. Rather, it is a system under which business operators that manufacture or import electrical appliances are permitted to sell such products only after they themselves fulfill the obligations prescribed by the Act and determine, at their own responsibility, that the products conform to the applicable standards. Even if the same product is imported and sold by another company, it will be deemed a violation of the law unless each individual import business operator fulfills all legal requirements on its own.
Obligations of the Domestic Administrator (Under the Electrical Appliance and Material Safety Act)
< Obligations >
1) Obligation to retain copies of inspection records.
(in the case of Specified Special Products, copies of certificates related to conformity inspections as well)
2) Obligation to accept requests for reports, on-site inspections, and orders for submission of products.
[Articles 40, 41, and 42 of the Act]
* In the event of a violation of these obligations, penalties may be imposed on the Domestic Administrator, and prohibition of labeling may be applied to the relevant Specified Import Business Operator.
< Reports Required from the Domestic Administrator >
1) The Domestic Administrator is required to submit a report each time one year has elapsed from the date on which the Specified Import Business Operator filed the notification. (Report items)
2) If the Domestic Administrator intends to terminate the contract with the Specified Import Business Operator, it must submit a prior notice no later than 30 days before the day preceding the date of termination.
(Prior notification is required in order to prevent a situation in which no Domestic Administrator is appointed.)
Scope of Transaction DPF (Digital Platform) Providers
Transaction DPFs subject to the Product Safety Four Acts are assumed to include internet marketplaces and internet auction platforms. Whether a transaction DPF or its provider is located in Japan or overseas is not determinative; rather, the determination is based on whether it provides a venue for transactions targeting Japanese consumers. In determining whether a platform provides a venue for transactions targeting Japanese consumers, various factors are comprehensively taken into consideration, such as whether the website is written in Japanese, whether delivery methods to Japan are available, and whether prices are displayed in Japanese yen.
Explanation of the Key Points of the Recent Amendments to the Product Safety Four Acts
Explanation of the Key Points of the Recent Amendments to the Product Safety Four Acts
< Response to the Expansion of Internet Transactions >
Consumer Product Safety Act / Electrical Appliance and Material Safety Act / Gas Business Act / Liquefied Petroleum Gas Act
①Inclusion of Overseas Business Operators as Regulated Entities (Appointment of a Domestic Administrator)
Where an overseas business operator sells products directly to domestic consumers without using a domestic import business operator, such as by utilizing a transaction DPF, the amendments clarify that such overseas business operators are subject to notification under the Consumer Product Safety Act and related laws, and require the appointment of a Domestic Administrator.
➁Establishment of Measures to Request Removal of Listings from Transaction Digital Platform Providers (e.g., Rakuten, Amazon)
With respect to products offered through a transaction DPF, where it is recognized that there is a risk of harm to domestic consumers and it cannot be expected that the seller of the product will take necessary measures such as recalls, measures may be taken to request the transaction DPF provider to remove the listing of the relevant product.
③Establishment of a System for Public Disclosure of Notification Information
A system is established to publicly disclose information such as the names of notifying business operators, the classification of models of specified products, and the names of Domestic Administrators.
④Establishment of a System for Public Disclosure of Violators of Laws and Regulations
A system is established under which the names and other information of persons who have committed acts in violation of laws or orders issued pursuant to laws may be made public.
< Response to Ensuring the Safety of Children’s Products Such as Toys >
Consumer Product Safety Act
①Establishment of Regulations for Children’s Products
For specified children’s products, manufacturers and importers are required to ensure conformity with technical standards established by the government and to provide warning labels such as target age and precautions for use. In December 2024, infant toys (toys intended for children under three years of age) and infant beds were designated as specified children’s products.
Products without labeling indicating compliance with these obligations may not be sold.
For infant toys (for children under three years of age), products manufactured or imported on or after December 25, 2025 are required to bear the round “Children’s PSC Mark”.
For infant beds, products bearing the old mark are required to be re-labeled with the diamond-shaped “Children’s PSC Mark”. Although transitional measures apply, products bearing the old mark may no longer be sold on or after March 25, 2027.
②Special Exception for Used Children’s Specified Products
With respect to used children’s specified products, a special exception is established to permit sales, subject to conditions such as providing warnings to domestic consumers and establishing systems to ensure safety.