High-risk consumer goods (PSC items) × Our own Japanese subsidiary imports

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)

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

The cleanest route: your subsidiary is the importer of record AND the notifying/licensed business for the product regimes (where a license is required — PMD — it must obtain or partner for it). It recovers import JCT through its own tax filings.

Your checklist

Subsidiary files the product-regime notifications in its own name (PSE/PSC/food as applicable)
Confirm the subsidiary holds any required licenses (PMD categories)
Standard customs setup: HS classification, duty, JCT, customs FX
[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
[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