Prepared for Example Labs (fictional) by Torii Japan Compliance · 2026-09-14 · Sample document
This sample uses a fictional product to show the depth and structure of a brief. Figures are indicative and sourced as noted; a real brief is built from your product's actual specifications and a live database lookup on the day it is written.
| Rule | Likelihood | Why |
|---|---|---|
| Radio Act — Giteki (技適) | High | Wi-Fi/Bluetooth via an ESP32-WROOM-32 module. 13 certifications for this module family exist in the MIC database; whether they cover your antenna and firmware decides the route. |
| PSE — Electrical Appliance and Material Safety Act | High | The bundled 12 V / 2 A AC adapter is a DC power supply unit — a specified (diamond-PSE) item. The LED lamp body itself likely falls under LED luminaire — a non-specified (round-PSE) item. |
| Domestic Administrator (国内管理人) | High | You plan to sell on Amazon.co.jp from overseas without a Japanese importer. Since 25 Dec 2025 this requires a METI notification and a Japan-resident administrator. |
| Customs ACP (税関事務管理人) | High | Inventory shipped to Amazon FBA Japan is imported in your name; a Japan-resident customs representative must be on file before the first shipment. |
| PSC / PMD Act | Low | No listed PSC product; no health or cosmetic claims. |
Indicative total (external costs): JPY 400,000 – 900,000 depending on whether the adapter is bought pre-certified (see §3) and whether the module certification carries over (see §2). Indicative timeline: 8 – 12 weeks from lab booking to a compliant Amazon.co.jp listing.
This week
Database lookup (MIC, 2026-09-11 data): 13 records match "ESP32-WROOM-32". Examples:
| Number | Date | Holder | Type name | Kind |
|---|---|---|---|---|
| 020-230093 | 2023-04-03 | LG Electronics Inc. | ESP32-WROOM-32UE | Construction design certification |
| 211-171114 | 2017 | Espressif Systems | ESP32-WROOM-32 | Construction design certification |
What this means. A module certification (工事設計認証) covers the module as certified: its PCB antenna or a specific external antenna, and the RF parameters set by the certified firmware. If Lumo uses the module with its onboard antenna and stock RF settings, the certification is likely to carry over and the product needs only the Giteki mark (the "技適" logo with the certification number) on the product or in an on-screen electronic display. If you changed the antenna, added an RF shield that alters the pattern, or tuned output power, product-level certification is likely required.
| Route | When | Indicative cost | Time | Source |
|---|---|---|---|---|
| Rely on module certification + mark display | Module used as certified | Labelling only | 1 week | MIC certification rules |
| Technical conformity certification (per unit type) | Small runs, prototypes | from JPY 180,000 | 3–5 weeks | TÜV Rheinland Japan wireless price list, 2026-09 |
| Construction design certification (production) | Series production | JPY 350,000 – 530,000 | 4–8 weeks | same |
Mark display: the Giteki mark must be visible on the product or shown electronically in the device UI; packaging alone is not enough.
| Item in the box | PSE category | Mark | Route |
|---|---|---|---|
| 12 V / 2 A AC adapter | DC power supply unit (直流電源装置), specified | Diamond PSE | Conformity assessment by a registered body (登録検査機関) + notifying business in Japan |
| Lamp body (LED, mains-powered via adapter) | LED luminaire (エル・イー・ディー・電灯器具), non-specified | Round PSE | Self-assessment against the technical standard + records kept by the notifying business |
The practical shortcut. Most brands do not certify their own adapter. Buy an adapter model that is already diamond-PSE certified under a Japanese notifying business (many OEM adapter makers offer these for the Japanese market) and the adapter obligation moves to them. Your remaining PSE work is the round-mark self-assessment for the lamp body.
| Work | Indicative cost | Time | Source |
|---|---|---|---|
| Round PSE self-assessment testing (lamp body) | USD 1,700 – 2,000 | 2–4 weeks | Test-lab quotations collected 2026-09 |
| Diamond PSE conformity assessment (if you certify your own adapter) | USD 5,000 – 6,500 | 4–6 weeks | same |
Who is the notifying business (届出事業者)? For direct sales from overseas, you are, as a "specified importer" — which is exactly what triggers §4.
Rule. Since 25 December 2025, an overseas business selling PSE/PSC products directly to Japanese consumers (Amazon.co.jp, own store, crowdfunding) must file a notification with METI and appoint a Domestic Administrator: an individual or company with an address in Japan and Japanese-language ability. The administrator's name is published by METI.
The delegation contract must cover five duties: (1) a contact channel with METI, (2) recall and hazard-prevention measures, (3) authority to receive ministerial notices on your behalf, (4) providing and keeping test records and conformity certificates, (5) responding to reports and on-site inspections.
| Option | Indicative cost | Fits when |
|---|---|---|
| Domestic Administrator service provider (English-speaking) | JPY 60,000 – 300,000 / year, provider-dependent; one provider lists from JPY 5,000 / month | You keep direct sales and your own margin |
| Japanese importer of record / distributor | Margin-based | You are fine giving up direct sales |
| Own Japanese entity (GK) | JPY 60,000 registration + accounting | Only at volume |
Check before signing: liability cap, what happens if you become unreachable (immediate termination + METI update), who holds the test reports, whether PL insurance is required, and whether the provider also covers the customs ACP role.
Shipping stock to Amazon FBA in Japan means you are the importer; Amazon does not act as importer of record. A Japan-resident Attorney for Customs Procedures must be notified to customs before the first shipment. Duties and consumption tax remain yours (the ACP is a representative, not the importer). One provider publishes USD 500 setup + USD 300 – 1,200 per shipment (Aplash, 2026-09); most others quote individually. Several Domestic Administrator providers bundle the ACP role — ask for both in one contract.
Expect Amazon.co.jp to ask for: the PSE certificate or test report, a photo of the PSE mark on the adapter and the lamp, the notifying business's name and address, and the Giteki certification number for the radio module. Keep these in one folder before you list; a suspended listing takes 1–3 weeks to restore once documents are complete.
| Step | Weeks | Cost range |
|---|---|---|
| Confirm module certification scope with vendor; source pre-certified adapter | 1 | — |
| Book lab; round-PSE testing of lamp body | 2–4 | USD 1,700 – 2,000 |
| (If needed) product-level Giteki certification | 4–8 (parallel) | JPY 180,000 – 530,000 |
| Domestic Administrator + ACP contracts; METI notification | 1–3 (parallel) | JPY 60,000 – 300,000 / year |
| Marking, Amazon document submission | 1 | — |
Total, typical case (pre-certified adapter, module certification carries over): about JPY 400,000 in year one, 8 weeks. Worst case (own adapter certification, product-level Giteki): about JPY 900,000+, 12 weeks.
Torii Japan Compliance can introduce English-speaking test labs and Domestic Administrator / ACP providers on request, and can pre-fill their intake with this brief so you do not explain the product twice. One round of follow-up questions is included with every brief.
This is an informational summary generated from public sources and is not legal advice. Final applicability must be confirmed with a registered certification body (登録認証機関) or the relevant ministry (METI / MIC / MHLW). Japanese source documents prevail over any English summary. Costs are indicative, quoted with source and date, and change with lab queues and exchange rates.