On 28 August 2025 Japan's Ministry of Economy, Trade and Industry (METI) formally published the revised Product Safety Act, requiring all overseas operators that sell PSE/PS-marked products directly to Japanese consumers through e-commerce platforms to register and appoint a domestic manager in Japan. The rules become enforceable on 25 December 2025.

The core of the change

Products shipped directly from e-commerce platforms to individual consumers in Japan have long bypassed traditional importers and often sat in a blind spot of the existing market surveillance system. The revision achieves the regulatory objective that products circulating in the Japanese market must meet the same safety standards regardless of the sales channel.

The key shift is that the responsible party moves upstream from the Japanese importer to the overseas seller. Chinese cross-border sellers, brand owners and manufacturers selling applicable products directly to Japanese consumers must therefore register with METI in their own name and assume full responsibility for product safety compliance.

Mandatory domestic manager

One of the most challenging requirements is the mandatory appointment of a domestic manager, commonly known as a Japanese representative. This person must be a natural person or legal entity located in Japan and acts as a critical legal and administrative bridge:

1. Official contact point, communicating formally with METI and other government departments on behalf of the overseas seller.

2. First point of responsibility for safety incidents, receiving and handling reports of product safety accidents from Japanese consumers and, where necessary, assisting government investigations and product recalls.

3. Reporting obligations, submitting periodic annual reports to METI.

Products in scope

1. Electrical appliances. All 457 product categories under the Electrical Appliances and Materials Safety Act are covered, including the 116 specified electrical appliances requiring the diamond PSE mark, such as power adapters and chargers, and the 341 non-specified electrical appliances requiring the round PSE mark.

2. Consumer daily goods. Certain products under the Consumer Product Safety Act are also covered, including infant and child products, lighters, heating appliances and gas appliances, which must meet the relevant technical standards and carry the PS and other safety labels.

Guidance for sellers

1. Screen products and lock down risk. Review every product line sold to Japan immediately and identify precisely the high-risk products within the scope of the PSE/PS mark.

2. Select and contract a domestic manager. Find a reputable Japanese service provider or individual with the necessary expertise, sign a formal agreement and define the responsibilities of both parties.

3. Complete the METI registration. Prepare the required company and product information and file through the Japanese government online platform, including GBiz-ID registration. The new process has three steps and is more complex, so allow sufficient time.

4. Build a complete product safety file. Systematically organise conformity documents such as test reports and certificates, technical files and internal quality control records so they can be produced at any time during a regulatory inspection.