Imported Products and the Consumer Product Safety Act — PSC Labeling, Accidents and Recalls

Imported Products and the Consumer Product Safety Act

The Consumer Product Safety Act as applied to imported products refers to the regulatory requirements under this Act that must be confirmed when importing and selling consumer products manufactured overseas within Japan in order to ensure product safety and prevent product-related accidents.

The Consumer Product Safety Act is a law designed to prevent harm to life or body caused by products used by general consumers in daily life, and to prevent the occurrence and spread of damage when product accidents occur.

Among the products used by general consumers, some may cause injury, fire, burns, suffocation, accidental ingestion, falls, breakage, or health hazards depending on their structure, materials, methods of use, intended age group, or usage environment.

In import operations, products that are commonly sold overseas are not necessarily permitted for direct sale within Japan.

In particular, products subject to the PSC Mark—including specified products, specially specified products, child-specific specified products, products requiring reporting of serious product accidents, and products intended for long-term use—must be managed not only through pre-import confirmation but also through post-customs clearance display, inspection, sales, and accident response.

Scope Covered in This Article

This article organizes the Consumer Product Safety Act as a general overview and introductory article on the safety of imported products, domestic sales, and post-sale measures.

The focus of this article is for import sellers to comprehensively understand the process from confirming the target items prior to sales, notification, compliance with technical standards, inspection, labeling, sales records, reporting serious product accidents, through to recalls.

Purpose of the Consumer Product Safety Act

The purpose of the Consumer Product Safety Act is to prevent harm to life or body caused by products used by general consumers and to prevent the expansion of damage in the event of a product-related accident.

The products covered include household goods, children's products, outdoor equipment, items involving fire, pressure, lasers, magnets, small parts, and other products that pose safety risks, primarily those intended for the daily use of general consumers.

As pre-sale regulations, this Act requires business notification for specified products, compliance with technical standards, voluntary inspections, conformity testing, and display of the PSC mark.

Post-sale regulations include reporting of serious product accidents, collection and provision of accident information, recalls, hazard prevention orders, and other related measures.

Overall Structure of the System

The Consumer Product Safety Act is not merely a law requiring the display of the PSC mark. Multiple systems are applied continuously from before product sale through post-sale.

Importers must not only confirm whether the product requires a PSC mark before sale but also manage post-sale accident reporting and recalls.

Differences Between Specified Products, Special Specified Products, and Specified Children's Products

Whether a product qualifies as a Specified Product is not determined solely by the product name. The product’s structure, purpose, performance, dimensions, target age, and method of use must be compared against the statutory definitions to make a determination.

Major Examples of Covered Products

The list of covered items may be added to or modified due to amendments in laws and regulations.

New regulations for infant beds and infant toys came into effect on December 25, 2025, while infant bed guards and baby strollers became regulated as of July 8, 2026.

For enforcement dates by product, previous markings, transitional measures, and sales deadlines, please refer to the article on “PSC Marks for Imported Products.”

Main Obligations Defined by This Law

For import sellers, it is important that their obligations extend beyond simply affixing the PSC mark.

They must manage business notification, technical standards compliance, voluntary inspections, inspection records, labeling, accident reporting, and recall measures as a continuous set of obligations.

Verification Flow for Sales of Imported Products

1. Confirm the intended use, structure, target age group, and sales method of the imported product.
2. Confirm whether the product is intended for general consumer use in daily life.
3. Check whether the product may be subject to the Consumer Product Safety Act.
4. Confirm if the product qualifies as a specified product, specially designated product, or children’s specified product.
5. Verify the need for PSC marks, children’s PSC marks, target age labeling, and warning labels.
6. Identify the domestic importer or Specified Import Business Operator.
7. Confirm the necessity of business notification and the applicable notification category.
8. Obtain specifications, drawings, material information, and test data from the overseas manufacturer.
9. Confirm compliance with Japan’s technical standards.
10. Determine the method of voluntary inspection, inspection units, and record retention procedures.
11. For specially designated products, undergo conformity inspection by a registered inspection body.
12. Check labeling on the product, packaging, instruction manuals, and sales pages.
13. Manage import dates, model numbers, lot numbers, sales quantities, and sales destinations.
14. Establish a system to respond to major product accidents, complaints, and recalls.
15. Begin domestic sales only after completing all verifications.

It is insufficient for an overseas manufacturer to merely explain safety.

Compliance with overseas standards and meeting obligations under the Japanese Consumer Product Safety Act are distinct matters.

Relationship with Overseas Operators and Cross-Border E-Commerce

When overseas operators sell PS mark-designated products directly to consumers in Japan via online marketplaces, their own e-commerce sites, or other methods without involving an importer in Japan, they may be subject to regulation as a Specified Import Business Operator.

Specified Import Business Operators must appoint a Domestic Responsible Person in Japan and fulfill obligations such as business notification, compliance with technical standards, voluntary inspections, labeling, record-keeping, and accident response.

The fact that products are shipped directly from overseas, payments are received outside Japan, or no Japanese legal entity exists does not exempt the products from Japanese product safety regulations.

Points Freight Forwarders Should Confirm

Freight forwarders are generally not in a position to make the final judgment on compliance with the Consumer Product Safety Act.

However, if there is a possibility that imported cargo falls under product safety regulations based on pre-import cargo information, it is practically effective to prompt the shipper or importer for confirmation.

• Whether the cargo is intended for sale in Japan as a consumer product
• Whether the items include helmets, lighters, laser products, pressure cookers, petroleum equipment, or products for children
• Whether the importer has confirmed the necessity of PSC marks or Child PSC marks
• If the products will be sold immediately after customs clearance, whether notifications, inspections, labeling, and preparation of inspection records are complete
• Whether inspection, labeling, repackaging, or replacement of instruction manuals is planned at the domestic warehouse
• Whether the importer anticipates serious product accidents or recall responses after sales
• Whether laws related to PSE, PSTG, PSLPG, the Food Sanitation Act, the Pharmaceuticals and Medical Devices Act (PMD Act), the Radio Act, or other regulations apply

Freight forwarders are not required to determine the applicability of these regulations definitively.

Prompting for confirmation does not transfer any legal obligations of the importer or seller to the freight forwarder.

Matters Customs Brokers Should Confirm

• Whether the invoice item names and specifications indicate the possibility of products subject to the Consumer Product Safety Act
• Whether the use, structure, target age, and sales method have been checked in addition to the HS code
• Whether the importer repeatedly imports the cargo for sales purposes
• Whether the products could fall under PSC mark items or specified products for children
• Whether the importer has confirmed notification, inspection, labeling, record keeping, and post-sale measures
• Whether there is any relevance to PSE, gas appliances, Household Goods Quality Labeling Act, Food Sanitation Act, Pharmaceuticals and Medical Devices Act (PMD Act), or Radio Law
• Whether inspection, label application, repacking, or manual replacement is planned after customs clearance
• Whether there is any confusion between Import Permit and the legality of domestic sales

The Import Permit indicates completion of import declaration procedures under the Customs Act.

It does not comprehensively certify compliance with domestic sales regulations, including the Consumer Product Safety Act.

Items Import Sellers Should Confirm

• Whether the product qualifies as a consumer product.
• Whether it falls under specified products, specially specified products, or specified products for children.
• Whether PSC marks, child PSC marks, target age, and cautionary labels are required.
• Whether business notification or registration as a Specified Import Business Operator is necessary.
• Whether documentation explaining compliance with technical standards is available.
• Whether voluntary inspection and the preparation and retention of inspection records can be conducted.
• Whether conformity inspection by a registered testing organization is required.
• Whether labeling of the product, packaging, instruction manuals, and sales pages is appropriate.
• Whether sales records, lot numbers, import dates, manufacturers, and factories can be properly managed.
• Whether there is a system in place for reporting serious product accidents, handling complaints, suspension of sales, and recalls.
• Whether arrangements for product liability (PL) insurance and recall cost insurance are being considered.

Particularly risky for import sellers is relying solely on overseas manufacturers’ product descriptions, foreign standards, or product pages on overseas e-commerce sites to determine if the products can be sold in Japan.

Relation to Other Product Safety Regulations

Multiple laws may apply simultaneously to a single product.

The presence of one mark cannot be used as a reason to omit confirmation of compliance with other laws.

Relation to Serious Product Accidents and Recalls

In the event of a serious accident caused by consumer products, manufacturers or importers may be required to report to the government.

Moreover, to prevent recurrence of similar accidents and further damage, recall actions such as product retrieval, inspection, repair, replacement, refund, public warnings, or suspension of sales may be necessary.

For imports, since overseas manufacturers often do not have a domestic base in Japan, importers or sellers typically take the lead in handling domestic responses.

Rather than reacting hastily after an accident occurs, it is important to organize labeling, instruction manuals, sales records, lot control, accident reporting systems, and recall procedures beforehand, before starting sales.

Main Cases Where Clearance Is Possible but Sales Are Prohibited

Management System to be Established Before Sales

• Internal process to verify whether the product is subject to regulations
• Legal compliance checklists for PSC, PSE, PSTG, and PSLPG, etc.
• Management of suppliers, manufacturers, production plants, model numbers, and lot numbers
• Retention of specifications, test data, inspection records, certificates, and instruction manuals
• Records of sales destinations, quantities sold, and sales channels
• Contact point to receive consumer complaints and accident information
• Initial response procedures to determine if an incident constitutes a serious product accident
• Procedures for recall-related collection, repair, replacement, refund, and consumer alerts
• Communication with overseas manufacturers regarding incidents, cost responsibilities, parts supply, and recovery claims
• Organization of product liability insurance, recall cost insurance, and marine cargo insurance

Product safety measures should not be prepared only after an accident occurs.

A management system must be established before sales that anticipates labeling, record-keeping, inquiries, incident reporting, and recalls.

Example 1: Importing Electric Toys for Children Under 3 Years Old

Assume an importer sells rechargeable electric toys intended for children under 3 years old within Japan.

First, confirm whether the product qualifies as a specified children's product for infants and toddlers, then check the technical standards, target age group, usage precautions, voluntary inspections, and requirements for the Child PSC Mark.

Next, individually verify the toy itself, the AC adapter, the charger, and the lithium-ion rechargeable battery. The electrical appliance safety law and PSE mark regulations may apply to the AC adapter or battery.

If the toy has Bluetooth or Wi-Fi functionality, also separately confirm compliance with technical standards certification under the Radio Law.

Therefore, checking only the Child PSC Mark is not sufficient. You need to separately verify the product, power supply components, battery, wireless functions, and labeling according to each applicable regulation.

Specific Example 2: Suspension of Sales After Importing Foreign-Made Lighters

Suppose an importer-retailer imports foreign-made lighters and attempts to list them on an e-commerce platform after obtaining the Import Permit, only to be requested to submit PSC-related documents.

If the lighter falls under the category of Specially Specified Products under the Consumer Product Safety Act, business notification, compliance with technical standards, voluntary inspection, and conformity testing by a registered inspection agency are required.

Even if the product displays a diamond-shaped PSC mark, sales cannot be based solely on that marking without verifying the registered domestic business operator, conformity inspection certificate, and inspection records.

The importer-retailer must suspend listing and sales, isolate the stock, and confirm the status with the overseas manufacturer, the registered inspection agency, and the relevant administrative office.

Having an Import Permit does not guarantee that lighters can be sold within Japan.

Common Misunderstandings

Summary

The Consumer Product Safety Act is a law designed to ensure the safety of products used by general consumers in daily life and to prevent the occurrence and spread of product-related accidents and harm.

This law does not only prescribe the PSC mark.

It is a comprehensive product safety system that includes designated products, specially designated products, children’s designated products, business notifications, conformity to technical standards, voluntary inspections, conformity inspections by registered testing organizations, labeling, reporting of serious product accidents, recalls, and the long-term use product safety inspection system.

In import operations, it is important not only to confirm whether customs clearance is possible but also whether the product can be sold legally in Japan and whether there is a system to respond to accidents after sales.

Importers and sellers are required to manage the target items, notifications, conformity to technical standards, inspection records, labeling, sales records, accident reports, and recall responses as an integrated whole.

The fact that a product is generally sold overseas, complies with overseas standards, has obtained an Import Permit, or bears a PSC mark-like label does not prove lawful sale within Japan.

Some products, such as electrical toys for children, are subject to multiple regulations simultaneously, including the Consumer Product Safety Act, the Electrical Appliance and Material Safety Act, the Radio Act, and others.

Freight forwarders and customs brokers are not in the position to make the final compliance determination for product safety regulations, but in practice, confirming potential applicability with the importer and coordinating inspections, labeling, storage, and the timing of sales commencement is effective.

When overseas businesses sell applicable products directly to consumers in Japan, the Specified Import Business Operator and Domestic Responsible Person requirements should also be checked.

Product safety compliance should not begin only after an accident occurs. The fundamental approach is to verify applicable laws, technical data, inspections, labeling, sales records, accident reporting, and recalls from the planning and ordering stages onward.

This article is intended as a general overview of the Consumer Product Safety Act and import sales practices and does not determine legal compliance for individual products, eligibility for PSC mark labeling, sales approvals, or legal liability in case of accidents. For actual products, it is necessary to confirm the latest laws, official documents, product specifications, target age, test data, and relevant administrative agencies.