High-risk consumer goods (PSC items) × Foreign seller — no entity in Japan (own-name import via ACP)

Rules verified as of 2026-08-08 · reviewed quarterly (next review: November 2026)

Typical products: Pressure cookers, motorcycle/bicycle helmets, climbing ropes, disposable lighters, laser pointers

The Dec 2025 amendment also expands child-product coverage. If your item is on the 特別特定 list, third-party conformity assessment is mandatory.

Which regimes apply

PSC — Consumer Product Safety Act (消費生活用製品安全法)

Products with specific hazards are 特定製品 (e.g. pressure cookers, motorcycle helmets, climbing ropes, disposable lighters, laser pointers, and from Dec 2025 more children's products). The importer must notify its business, verify conformity and affix the PSC mark; 特別特定製品 additionally require third-party conformity assessment.

Business notification to METI
Conformity with technical standards (third-party assessment for 特別特定製品)
PSC mark before sale

Sources: METI — product safety (PSC)

Dec 2025 cross-border e-commerce rules (特定輸入事業者・国内管理人)

Since 25 December 2025, foreign businesses selling regulated products (PSE/PSC/gas/LPG categories) DIRECTLY to Japanese consumers — e.g. via online marketplaces — are explicitly covered by the four product-safety acts as 特定輸入事業者, and appoint and notify a domestic administrator (国内管理人) in Japan who bears safety-compliance responsibilities. Notification procedures run through METI's electronic systems (GBiz-ID).

Determine whether your direct-to-consumer sales include regulated (PSE/PSC) products
Appoint a qualified 国内管理人 (domestic administrator) and file the notification
Keep the administrator informed for recalls / accident reporting duties

Sources: METI — foreign businesses now covered (特定輸入事業者)

Customs: duty, consumption tax and the importer of record

Every commercial import needs an importer of record with post-release disposal authority, correct HS classification, duty and 10% consumption tax. A non-resident importer files through an Attorney for Customs Procedures (ACP, 税関事務管理人) and needs a tax agent for JCT recovery.

Classify the product (HS code) and check the duty rate
Convert values with the official customs FX rate
Non-residents: appoint ACP (form C-7500) before the first declaration

Sources: Customs Answer 9601 — ACP

→ Tools: tariff finder & landed-cost calculator · customs FX rates · Guides: IOR, ACP

Who can be the importer — verdict

You CAN be the importer of record as a non-resident by appointing an Attorney for Customs Procedures (ACP) before the first declaration, and a tax agent to recover import JCT. BUT product regimes that require a domestic notifier or license holder (PSE, PSC, food sanitation, PMD) are NOT satisfied by the ACP — you need a Japan-side responsible business for those: a partner importer, or (for direct B2C sales of PSE/PSC goods since Dec 2025) a notified 国内管理人.

Your checklist

Appoint an ACP (税関事務管理人) — Customs form C-7500 — before the first import declaration
Appoint a tax agent (納税管理人) with the tax office if you will recover import JCT
Confirm who fulfils each product regime on the Japanese side (see the regimes above)
Register the invoice/classification pack: HS code, duty rate, customs FX rate
[PSC] Business notification to METI
[PSC] Conformity with technical standards (third-party assessment for 特別特定製品)
[PSC] PSC mark before sale
[Dec 2025 cross-border e-commerce rules (特定輸入事業者・国内管理人)] Determine whether your direct-to-consumer sales include regulated (PSE/PSC) products
[Dec 2025 cross-border e-commerce rules (特定輸入事業者・国内管理人)] Appoint a qualified 国内管理人 (domestic administrator) and file the notification
[Dec 2025 cross-border e-commerce rules (特定輸入事業者・国内管理人)] Keep the administrator informed for recalls / accident reporting duties
[Customs: duty, consumption tax and the importer of record] Classify the product (HS code) and check the duty rate
[Customs: duty, consumption tax and the importer of record] Convert values with the official customs FX rate
[Customs: duty, consumption tax and the importer of record] Non-residents: appoint ACP (form C-7500) before the first declaration