oriiJapan Compliance

Guide · 2026-09-15

Japan's Domestic Administrator rule for overseas sellers (since 25 Dec 2025), explained

Who must appoint a Domestic Administrator (国内管理人) in Japan, what the five contractual duties are, what METI publishes, and the three ways to satisfy the rule.

Since 25 December 2025, Japan's four product-safety laws (電気用品安全法 PSE, 消費生活用製品安全法 PSC, ガス事業法, 液化石油ガス法) apply to overseas businesses that sell regulated products directly to consumers in Japan. METI calls such a business a specified importer (特定輸入事業者).

Who is affected

You are likely affected if all of the following are true:

  • your product carries, or should carry, a PSE or PSC mark (AC adapters, lithium-ion cells above a certain energy density, LED luminaires, many appliances; lighters, pressure cookers, infant beds and a few others for PSC);
  • you sell to consumers in Japan through Amazon.co.jp, your own store, or crowdfunding rewards; and
  • there is no Japanese importer of record between you and the consumer.

If a Japanese importer or distributor buys from you and resells, the importer carries the obligations instead.

What you must do

  1. Notify METI of the start of your import business (電気用品輸入事業届出 or the equivalent under the other laws). Forms are in Japanese; METI publishes an English overview of the amendment, not English forms.
  2. Appoint a Domestic Administrator (国内管理人) — an individual or company with an address in Japan and Japanese-language ability — and file the administrator's registry certificate or resident record, a certificate of authority (権限証明書), a copy of the delegation contract, and a pledge (誓約書). A power of attorney is needed only if an agent files for you. The administrator must keep copies of your inspection records, submit to METI inspections, report to METI every year, and give 30 days' notice before terminating.
  3. Keep test records and conformity certificates, and make them available through the administrator.

METI publishes the administrator's name together with the notifying business.

The five duties the contract must cover

METI requires the delegation contract to cover at least: (1) a contact channel with the Minister of Economy, Trade and Industry; (2) measures to prevent and contain hazards, including recalls; (3) authority to receive ministerial dispositions and notices on your behalf; (4) providing and preserving inspection records and copies of conformity certificates; (5) responding to reports, on-site inspections and product submissions.

Three ways to satisfy the rule

Option Typical cost Fits when
A Domestic Administrator service provider (English-speaking providers exist; one lists from JPY 5,000/month) JPY 60,000–300,000 per year, provider-dependent You keep direct sales
A Japanese importer of record Their margin You are fine giving up direct sales
Your own Japanese entity JPY 60,000 registration + accounting Only at volume

What to check before signing with a provider

Liability cap; what happens if you become unreachable (immediate termination and a METI update); who holds the test reports; whether product-liability insurance is required; and whether the provider also covers the customs ACP role for FBA shipments.

Informational summary from public sources, not legal advice. Confirm with METI or a registered body. Source: METI, 海外事業者が製品安全4法の規制対象となりました.

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© Torii Japan Compliance. Informational summary, not legal advice. Japanese source documents prevail.