Electrical Appliance and Material Safety Act (PSE) — Notifications, Conformity and Labeling for Imported Products
Interlink編集部What Is the Electrical Appliance and Material Safety Act for Imported Goods
The Electrical Appliance and Material Safety Act for Imported Goods is a regulatory framework that applies when electrical appliances manufactured overseas are imported into Japan and sold or displayed for sale domestically. It covers safety regulations at the manufacturing, importation, and sales stages.
The Act regulates the manufacturing and sale of electrical appliances and promotes voluntary safety measures by private businesses. Its objective is to prevent hazards and damage such as fires, electric shocks, overheating, smoke generation, and electric leakage caused by electrical appliances.
When selling electrical appliances subject to the Act within Japan, importers must notify the authorities of the import business, confirm compliance with technical standards, conduct voluntary inspections, prepare and retain inspection records, obtain conformity assessments from registered testing bodies for specified electrical appliances, and display the PSE mark and related labeling.
Products sold overseas that bear CE marks, UL certification, or conform to IEC standards are not automatically considered compliant with Japan’s Electrical Appliance and Material Safety Act.
Additionally, even if the main product itself is outside the scope of the Act, accompanying items such as AC adapters, chargers, power cords, plugs, extension cords, or lithium-ion batteries may individually be subject to regulation.
The Electrical Appliance and Material Safety Act is not merely a system for affixing a PSE mark. It is a comprehensive management system integrating notification, technical standard compliance, voluntary and conformity inspections, record retention, labeling, sales restrictions, post-distribution accident response, and danger prevention measures.
Scope Covered in This Article
| Article / Regulation | Main Role | Relation to This Article |
|---|---|---|
| Electrical Appliance and Material Safety Act for Imported Goods | Determination of electrical appliance scope, import business notification, technical standards, voluntary inspection, conformity testing, labeling, sales restrictions | Core focus of this article |
| PSE Marking for Imported Goods | Diamond-shaped PSE, round-shaped PSE, labeling details, notifying business name, registered testing body name, etc. labeling practice | Details on PSE marking |
| Imported Goods and the Consumer Product Safety Act | Safety regulations for consumer products, PSC system, accident reporting, recalls | General overview of product safety including non-electrical products |
| Serious Product Accidents Involving Imported Goods | Judgment of applicability for deaths, serious injuries and illnesses, carbon monoxide poisoning, fires, etc. | Relevant when serious accidents occur post-sale |
| Product Accident Information Reporting System for Imported Goods | Reporting obligations for serious product accidents, deadlines, reporting authorities, public disclosure system | Statutory post-sale reporting |
| Recalls for Imported Goods | Collection, repair, replacement, refund, sales suspension, usage cessation notifications | Measures to prevent harm expansion |
| Imported Goods and the Radio Act / Technical Conformity Mark | Technical standards for wireless equipment such as Wi-Fi, Bluetooth, LTE, etc. | Checked together for electrical products with wireless functions |
| Imported Goods and the Telecommunications Business Act | Technical conformity certification for terminal equipment connecting to communication lines, etc. | Checked for products with telephone or communication terminal functions |
This article addresses the overall legal framework of the Electrical Appliance and Material Safety Act and import sales practices. Determinations about whether specific items fall within the scope and details of PSE marking should be confirmed based on product specifications and Ministry of Economy, Trade and Industry interpretations of scope inclusion or exclusion.
Purpose of the Electrical Appliance and Material Safety Act
Electrical appliances are widely used in homes, offices, stores, factories, and other locations. However, if there are issues with their design, insulation, wiring, heat generation, charge control, components, materials, or usage environment, they could potentially cause fire, electric shock, smoke emission, abnormal heating, leakage current, burns, and other hazards.
Therefore, the Electrical Appliance and Material Safety Act requires ensuring safety for designated electrical appliances from the manufacturing and import stages through post-sale.
- Identify the applicable electrical appliances
- Notify authorities of manufacturing and import operations
- Comply with technical standards established by the government
- Conduct voluntary inspections and keep inspection records
- Undergo conformity assessment for specified electrical appliances
- Display PSE marks or equivalent when statutory requirements are met
- Do not sell applicable products without proper markings
- If hazards become apparent after distribution, respond by halting sales and implementing recalls
Legal Positioning
| Law / Article | Main Content | Practical Meaning in Import Operations |
|---|---|---|
| Electrical Appliance and Material Safety Act Article 1 | Purpose of the Act | Confirms the overall system purpose to prevent hazards and defects caused by electrical appliances |
| Same Act Article 2 Paragraph 1 | Definition of Electrical Appliances | Check whether the product falls under electrical appliances designated by law |
| Same Act Article 2 Paragraph 2 | Definition of Specified Electrical Appliances | Confirm whether the electrical appliance is particularly prone to hazards or defects |
| Same Act Enforcement Order Article 1 and Appendix 1 | Designation of Specified Electrical Appliances | Verify the items and scope subject to the diamond-shaped PSE mark |
| Same Act Enforcement Order Article 1 and Appendix 2 | Designation of Electrical Appliances Other Than Specified Electrical Appliances | Verify the items and scope subject to the circular PSE mark |
| Same Act Article 3 | Notification of Manufacturing and Import Business | Notify start date, category of electrical appliance, model classification, etc. Specified importers also notify Domestic Administrator details |
| Same Act Article 8 Paragraph 1 | Obligation to Conform to Technical Standards | Notifying businesses must ensure electrical appliances they manufacture or import comply with technical standards |
| Same Act Article 8 Paragraph 2 | Inspection and Inspection Records | Conduct voluntary inspections and create and preserve inspection records |
| Same Act Article 8 Paragraph 3 | Provision of Copies of Inspection Records from Specified Importer to Domestic Administrator | Inspection records are shared between overseas business and Domestic Administrator to allow domestic verification |
| Same Act Article 9 | Conformity Inspection for Specified Electrical Appliances and Preservation of Certificates | Confirm inspections by registered inspection bodies and validity of certificates for applicable models and manufacturing plants |
| Same Act Article 10 | Marking | Notifying businesses that fulfill legal obligations display PSE marks and related indications |
| Same Act Article 12 Paragraph 1 | Order to Prohibit Marking | Marking may be prohibited if technical standards are not met or other issues arise |
| Same Act Article 27 | Sales Restrictions | Do not sell or display for sale items subject to this Act without the prescribed markings |
| Same Act Article 28 | Restrictions on Use | Confirm restrictions on use of unmarked items in certain business uses |
| Same Act Article 42-5 | Danger Prevention Order | May be ordered to recall or take other necessary measures to prevent hazards |
| Same Act Articles 43 and 45, etc. | Reporting, Collection, On-Site Inspections, etc. | Be prepared to present records related to manufacturing, import, inspection, sales, and inventory |
| Same Act Articles 57 to 61 | Penalties, Joint Penalties, Administrative Fines | Check applicability of criminal penalties, corporate penalties, and administrative fines for unmarked sales, order violations, false notifications, etc. |
Electrical Appliances Subject to the Act
The Electrical Appliance and Material Safety Act does not apply to all electrical products. It is limited to electrical appliances specified in Article 2, Paragraph 1 of the Act and the attached table of the Enforcement Order.
When determining whether a product is subject, it is necessary to check not only the product or catalog name but also the rated voltage, rated power consumption, structure, use, connection method, power supply type, location of use, accessories, built-in batteries, and other factors.
| Classification | Legal Status | Main Examples | Pre-Import Checks |
|---|---|---|---|
| Specified Electrical Appliances | Electrical appliances designated in the first attached table of the Enforcement Order that have a particularly high risk of danger or malfunction | Electric wires, fuses, wiring devices, small single-phase transformers, DC power supplies, electric massagers, portable generators, etc. | Conformity inspection by a registered testing body, certificates, type/model, manufacturing factory, diamond-shaped PSE mark |
| Electrical Appliances Other Than Specified Items | Electrical appliances designated in the second attached table of the Enforcement Order | Electric refrigerators, electric washing machines, electric kotatsu, televisions, audio equipment, LED lighting fixtures, lithium-ion batteries, etc. | Compliance with technical standards, voluntary inspections, inspection records, round-shaped PSE mark |
| Main Unit Exempt but Accessories Subject | Accessories are evaluated as independent electrical appliances | AC adapters, power cords, plugs, chargers, storage batteries | Verify subject items, inspection documents, and markings separately from the main unit |
| Products Possibly Not Subject | Items not covered by the scope or entries in the Enforcement Order’s attached tables | Some devices powered only by batteries, industrial-use-only products, devices with ratings or uses outside the specified scope, etc. | Save the rationale for exclusion in specifications and interpretation examples |
The Ministry of Economy, Trade and Industry (METI) publicly provides lists including 116 specified electrical appliances and 341 other electrical appliances. However, because item names alone do not definitively determine the scope, the Enforcement Order, Enforcement Regulations, and related interpretation examples for inclusion or exclusion should be checked together.
Main Cases Where the Electrical Appliance and Material Safety Act Does Not Apply or Normal Domestic Sales Regulations Are Not Directly Applicable
Not all products using electricity fall under the Electrical Appliance and Material Safety Act. Conversely, labeling a product as "for business," "industrial," or "research" does not automatically exempt it from the Act.
| Scenario | Basic Treatment | Reasoning | Practical Notes |
|---|---|---|---|
| Products not listed under either Appendix 1 or Appendix 2 of the Enforcement Order | Generally not subject to the Electrical Appliance and Material Safety Act | The Act applies only to electrical appliances specified in the Enforcement Order | Determine based on structure, usage, rating, connection method, and interpretation examples—not just product name |
| Products whose rated voltage, capacity, structure, or usage method fall outside the specified scope | May be considered exempt | The same general product name may not fall within the scope in the Enforcement Order or by interpretation | Confirm compliance for each model, as specification changes may place the product within the scope |
| Products operated only by batteries such as dry cells, where neither the main unit nor included items correspond to specified electrical appliances | Generally exempt | The main unit does not fall under electrical appliances listed in the Enforcement Order, nor does it include regulated AC adapters or rechargeable batteries | Separately determine compliance for standalone or bundled chargers, AC adapters, or lithium-ion rechargeable batteries |
| Lithium-ion rechargeable batteries for automotive, medical, or industrial use excluded by usage in the Enforcement Order | Exempt if usage requirements are met | There are usage-based exemptions within the specified scope for lithium-ion rechargeable batteries | Simply labeling as "for business use" by the operator is insufficient; verify actual dedicated usage and specifications |
| Components incorporated into finished products that themselves do not fall under specified electrical appliances | May be exempt as standalone components | Determined by whether the component itself, not just its name, corresponds to electrical appliances under the Enforcement Order | Power cords, plugs, fuses, transformers, etc., may independently fall under regulation even as components |
| Products imported by individuals for personal use without domestic sales or sales display purposes | Normally not directly subject to import business notifications or sales regulations | Not a recurring commercial import and sales business, and no domestic sales are conducted | If the product is sold after import or if the import is effectively commercial, separate judgment is necessary |
| Electrical appliances handled exclusively for export and not sold domestically in Japan | Special provisions for export-only electrical appliances may apply | This is a special commercial flow not intended for domestic consumer sales | If resold domestically, diverted to tourist models, or repurposed, the special provisions may no longer apply |
| Cases where the Minister of Economy, Trade and Industry grants an exceptional approval for specific uses | May allow treatment differing from standard technical standards compliance and labeling regulations | Individual approval based on the legal exception approval system | Strictly comply with approved product, usage, sales destination, labeling, and other conditions; do not divert for general sales |
Determination of exemption is not based solely on the product name. The Ministry of Economy, Trade and Industry publishes interpretation examples of applicable and non-applicable products by category and type of electrical appliance. Even when a product is judged exempt, it is important to keep records of product specifications, circuits/structure, ratings, usage, included items, and the basis for the judgment.
Differences Between Specified Electrical Appliances and Other Electrical Appliances
| Item | Specified Electrical Appliances | Other Electrical Appliances | Practical Considerations for Import |
|---|---|---|---|
| PSE Mark | Diamond-shaped PSE | Circle-shaped PSE | Confirm not only the shape but also the notified business operator’s name and other displayed information |
| Business Notification | Required | Required | Accurately notify the electrical appliance category and model classification |
| Conformity to Technical Standards | Required | Required | Do not assume compliance with Japanese standards based on CE, UL, or similar marks alone |
| Self-Inspection | Required | Required | Link the inspection results to each import lot |
| Retention of Inspection Records | Required | Required | Check the statutory retention period, required details, and storage location |
| Conformity Inspection by Registered Inspection Bodies | Required | Generally Not Required | Verify the validity of certificates, model, factory, and inspection methods |
| Display of Registered Inspection Body Name | Required | Usually Not Required | Compare conformity inspection certificates with the displayed information |
| Sales Risks | Without proper certificates, sales preparation cannot be completed | Even without third-party inspection, notification, self-inspection, and marking obligations remain | Do not assume “circle-shaped PSE is simpler” |
Main Obligations Prescribed by the Electrical Appliance and Material Safety Act
| Obligation | Legal Basis | Implementation Details | Verification Documents |
|---|---|---|---|
| Notification of Import Business | Article 3 of the Act | Submit notification of product categories, model classifications, etc., within the prescribed period after starting business | Notification form, acceptance record, model classification documents |
| Compliance with Technical Standards | Article 8, Paragraph 1 | Ensure imported electrical appliances conform to technical standards | Test reports, circuit diagrams, parts lists, design documents |
| Self-Inspection | Article 8, Paragraph 2 | Conduct inspections in accordance with legal procedures | Inspection procedures, inspection equipment, inspection results |
| Creation and Retention of Inspection Records | Article 8, Paragraph 2 | Record and retain model, quantity, inspection date, method, results, etc. | Lot-specific inspection records, retention ledger |
| Provision of Records to Domestic Administrator | Article 8, Paragraph 3, etc. | Specified importers provide copies of inspection records to their Domestic Administrator | Provision records, Domestic Administrator’s retention materials |
| Conformity Assessment | Article 9 | Undergo conformity assessment by a registered testing organization for specified electrical appliances and retain certificates | Conformity certificates, inspection reports, factory information |
| Display of PSE Mark, etc. | Article 10 | Display according to prescribed method after meeting statutory requirements | Display diagrams, product photos, label management records |
| Verification of Display at Point of Sale | Article 27 | Do not sell electrical appliances lacking statutory display | Incoming inspection, product webpages, inventory photos |
| Post-Sale Danger Prevention Measures | Article 42-5, etc. | Upon hazard discovery, investigate cause, suspend sales, recall, repair, issue warnings, etc. | Incident records, customer lists, recall plans |
Specified Importers and Domestic Administrators
As of the amendment to the four product safety laws effective December 25, 2025, certain overseas businesses selling PS mark-targeted products directly to consumers in Japan through online malls, etc., will also be regulated as specified importers.
The term "specified importers" here mainly refers to businesses that do not maintain a regular importer within Japan but sell directly from overseas to domestic consumers. This term is not used in the same sense as companies in Japan that import products through normal commercial channels and sell them domestically.
| Item | Regular Importers in Japan | Specified Importers | Practical Notes |
|---|---|---|---|
| Location of Business | Within Japan | Outside Japan | Confirm the parties to the sales contract and the actual import situation |
| Sales Method | Wholesale, retail, or e-commerce sales after domestic import | Direct sales from overseas to consumers in Japan | Do not judge mechanically based only on use of online malls |
| Notification under Article 3 | Notification as an importer | Notification as a specified importer | Must include Domestic Administrator information |
| Domestic Administrator | Generally not required by the system | Appointment required | Confirm requirements, authority, and communication structure of the Domestic Administrator |
| Inspection Records | Kept by the domestic importer | Copies must be provided to the Domestic Administrator, etc. | Ensure ability to respond domestically to administrative inquiries and on-site inspections |
| Accidents and Administrative Responses | Handled by domestic importer | Coordinated between specified importer and Domestic Administrator | Clearly define responsibility allocation through contracts and operational procedures |
The Domestic Administrator is not merely a postal recipient or nominal representative. A practical system must be in place to handle notification documentation, inspection records, administrative notifications, requests for reports, on-site inspections, accident information, and other matters.
Verification Flow for Import Sales
- Create a list of the main product, accessories, included items, and replacement parts
- Confirm rated voltage, power consumption, power supply type, structure, application, and usage location
- Verify applicability as electrical appliances based on Article 2, Paragraph 1 of the Act and the Enforcement Order appendix
- Identify the legal electrical appliance name and classification, not just the product name
- Determine whether it is a specified electrical appliance or a non-specified electrical appliance
- Individually assess AC adapters, chargers, power cords, plugs, and storage batteries
- Confirm if the importer is a domestic import business or an overseas specified import business
- Check import business notification, Domestic Administrator, and model classification
- Review conformity documents for Japanese technical standards
- If specified electrical appliances apply, verify conformity inspections and certificates
- Prepare self-inspection methods, equipment, personnel, and inspection records
- Confirm PSE mark, notified business operator name, registered inspection agency name, and rated display, etc.
- Check Japanese-language manuals, warning labels, sales pages, and product photos
- Ensure traceability of import lot, model, manufacturing factory, sales destination, and inventory
- Establish procedures for responding to accidents, administrative inquiries, sales suspensions, and recalls
Verification of AC Adapters, Chargers, Power Cords, and Rechargeable Batteries
With imported goods, there are cases where only the main unit is checked, causing the PSE compliance of accessories to be overlooked.
| Component | Possible Subject to Regulation | Main Points for Verification | Typical Oversights |
|---|---|---|---|
| AC Adapter | May be classified as a specified electrical appliance when considered a DC power supply device | Input/output ratings, capacity, model, certificate of conformity, diamond-shaped PSE mark | Assuming the adapter is exempt because the main unit is exempt |
| Charger | May fall under DC power supply device or equivalent depending on design and use | Charging method, output, target battery, circuit configuration | Excluding based solely on the overseas manufacturer’s product name |
| Power Cord / Plug | May be subject as electric wire or plug connector | Rating, conductor, insulation, plug shape, markings | Judging the cord set as compliant only by the adapter’s certificate |
| Lithium-Ion Rechargeable Battery | May be subject depending on requirements such as volumetric energy density | Cell configuration, capacity, energy density, protection circuit, use | Failing to distinguish whether embedded in device or sold separately |
| Replacement Accessories | May independently be subject if sold separately | Sales format, packaging, markings, inspection records | Simply reusing documentation bundled with the finished product |
If accessories bundled with the product are replaced with parts from another manufacturer, reconfirm consistency in model, factory, parts, certificates, inspection records, and markings.
Differences between CE, UL, IEC, and PSE
| Item | CE, UL, IEC, etc. | Electrical Appliance and Material Safety Act (PSE) | Considerations in Import Practice |
|---|---|---|---|
| System / Standard Region | Europe, North America, International standards, etc. | Japanese domestic law | Do not automatically substitute overseas conformity with compliance to Japanese law |
| Scope | Varies by system and standard | Electrical appliances designated by the Enforcement Order | Confirm the electrical appliance name under Japanese law |
| Technical Requirements | Varies by each standard | Japanese technical standards ministerial ordinances and interpretations | Check for differences or conduct additional testing |
| Business Notification | Does not replace notification requirements in Japan | Notification under Article 3 of the Act is required | To be conducted separately as an obligation of the importer |
| Self-Inspection and Records | Overseas test reports alone may not be sufficient | Inspection and record-keeping based on Article 8 of the Act are required | Confirm correspondence to the imported lot |
| Marking | CE, UL, etc. markings | PSE mark, etc. | Overseas marks alone do not fulfill domestic sales requirements |
Relationship with Other Product Safety Laws
| System / Marking | Governing Law | Main Targets | Relationship with the Electrical Appliance and Material Safety Act (PSE) |
|---|---|---|---|
| PSE Mark | Electrical Appliance and Material Safety Act | Specified Electrical Appliances and Other Electrical Appliances | Marking based on this Act |
| PSC Mark | Consumer Product Safety Act | Lighters, motorcycle helmets, pressure cookers, infant products, etc. | Even for electrical appliances, overlapping confirmation may be required depending on product classification |
| PSTG Mark | Gas Utility Act | Gas appliances for city gas | Check together for gas-electric combined appliances |
| PSLPG Mark | Act on Ensuring Safety and Proper Transactions for Liquefied Petroleum Gas | LP gas appliances, etc. | Check together for LP gas-electric combined appliances |
| Technical Conformity Mark | Radio Act | Wireless devices such as Wi-Fi, Bluetooth, LTE, etc. | Separate confirmation from PSE required for electrical products with wireless functions |
| Technical Standards Certification for Terminal Equipment | Telecommunications Business Act | Terminal equipment connected to communication lines | Confirm if communication functionality is present |
| Household Goods Quality Labeling | Household Goods Quality Labeling Act | Some electrical appliances and miscellaneous goods | Quality labeling is confirmed separately from safety regulations |
| Food Sanitation Regulations | Food Sanitation Act | Cooking equipment with food contact parts, etc. | Materials in contact with food should be separately confirmed |
| Medical Device Regulation | Pharmaceuticals and Medical Devices Act (PMD Act) | Electrical devices intended for medical use, etc. | Confirm whether it qualifies as a medical device depending on efficacy and usage |
Matters Freight Forwarders Should Confirm
Freight forwarders are generally not responsible for determining whether goods fall under the Electrical Appliance and Material Safety Act, ensuring technical standard compliance, or guaranteeing PSE marking. However, based on cargo information before import, it is practical to prompt the cargo owner to verify domestic sales regulations.
- Whether the goods are electrical products sold within Japan
- Whether an AC adapter, charger, power cord, plug, or storage battery is included
- Whether the products fall under categories such as home appliances, LED devices, electric toys, beauty devices, measuring instruments, communication equipment, or power tools
- Whether the importer has confirmed if the goods are subject to or exempt from the Electrical Appliance and Material Safety Act
- If the goods are sold immediately after customs clearance, whether notification, inspection records, conformity certificates, and markings are prepared
- Whether conditions for transporting lithium-ion storage batteries classified as dangerous goods have been confirmed
- Whether other regulations such as the Radio Act (Technical Conformity Mark), the Telecommunications Business Act, PSC (Consumer Product Safety Act), the Food Sanitation Act, or the Pharmaceuticals and Medical Devices Act (PMD Act) are also applicable
Standard Five Classifications of Freight Forwarder Involvement Scope
The following five classifications are not defined by laws or the entire industry but serve as an analytical framework to organize the scope of freight forwarder involvement in this series.
| Classification | Main Involvement in This System | Commonly Confirmed Items | Judgments Usually Excluded |
|---|---|---|---|
| Simple Intermediary | Assistance with transportation bookings, communications, and document exchange | Product name, purpose, included items, importer, sales plan | Final determination of the target items or guarantee of PSE compliance |
| Cargo Transportation Service Provider | Transportation of electrical products, storage batteries, replacement or repair goods, etc. | Packing, dangerous goods, temperature, impact, short circuit prevention, delivery schedule | Import Business Notification, voluntary inspection, or labeling judgments |
| NVOCC / House B/L Issuer | Undertakes sea and multimodal transport as a contracting carrier | Cargo information, transport documents, dangerous goods declaration, shipper and consignee | Product safety liability solely based on House B/L issuance |
| Door-to-Door Single Contractor | Comprehensive coordination from collection, customs clearance, storage, to inland delivery | Bonded and post-customs operations, labeling work location, delivery conditions, return logistics | Legal judgments on technical standards compliance or PSE labeling outside the contract |
| Agent/Coordinator for Specific Operations | Individual coordination for inspection, labeling, repacking, accessory replacement, etc. | Scope of delegation, work instructions, target models, completion records | Notifications, inspection decisions, or sales approvals not delegated |
Contracting Carrier and Actual Carrier denote legal and contractual statuses and do not replace the above five classifications.
Operational tasks such as packing, storage, inspection, PSE label application, accessory replacement, vanning, and devanning do not constitute a sixth classification. Responsibility scope should be confirmed based on the applicable classification, contract, work instructions, and actual handling.
Items Customs Brokers Should Confirm
- Whether the invoice item names, HS codes, intended use, ratings, and components suggest the possibility of regulated electrical products
- Whether the importer is bringing in the cargo for resale purposes
- Whether not only the main unit but also AC adapters, cords, plugs, and storage batteries are included
- Whether the importer has confirmed filing notifications, technical standards compliance, self-inspections, conformity inspections, and labeling
- Whether there are plans to replace labeling or accessories while the goods are in bonded status or after customs clearance
- Whether the Radio Act (Technical Conformity Mark), Telecommunications Business Act, PSC (Consumer Product Safety Act), Food Sanitation Act, Pharmaceuticals and Medical Devices Act, or other laws are involved
- Whether import permit by customs is being confused with the legality of domestic sales
The Electrical Appliance and Material Safety Act does not require all confirmations to be completed at the time of import declaration. Customs clearance without cargo detention does not guarantee the legality of domestic sales.
Main Situations Where Clearance Is Granted but Sales Are Prohibited
| Situation | Main Issue | Impact on Business | Required Actions |
|---|---|---|---|
| Identified as Applicable Electrical Appliance after Import | Notification, inspection, and labeling are incomplete | Sales suspension, inventory stagnation | Confirm the applicable category and required procedures |
| Import Business Notification Has Not Been Submitted | Omission of procedures under Article 3 of the Act | Administrative action, changes to sales plans | Confirm with the relevant Regional Bureau of Economy, Trade and Industry |
| No Documentation of Compliance with Japanese Technical Standards | Only foreign standard documentation available | Unable to confirm sales eligibility | Check differences, conduct testing, and implement design corrections |
| Certificate for Specified Electrical Appliances Does Not Match Model or Factory | Outside scope of conformity inspection | Unable to display diamond-shaped PSE mark or sell the product | Reconfirm with the registered testing laboratory |
| No Voluntary Inspection Records | Unable to prove statutory inspections were performed | Lack of basis for labeling and sales | Establish inspection system and lot record management |
| Only AC Adapter Does Not Comply with PSE | Overlooked regulation of included accessories | Cannot sell the entire set product | Replace with compliant items, verify labeling and documentation |
| PSE Mark Present but No Notified Business Operator Name Displayed | Incomplete labeling information | Sales suspension, correction of labeling | Reconfirm statutory labeling requirements |
| Unable to Meet EC Mall Documentation Inspection Requirements | Lack of certificates, notifications, and inspection records | Listing suspension, account restrictions | Organize evidential documentation at the product level |
Relationship with Administrative Measures and Penalties
| Measures / Liability | Main Legal Basis | Main Content | Practical Notes |
|---|---|---|---|
| Display Prohibition Order | Article 12, Paragraph 1 of the Act | In cases of non-compliance with technical standards, PSE marking may be prohibited | Immediately check inventory already marked, shipment destinations, and sales pages |
| Sales Restriction | Article 27 of the Act | Prohibits sale and sales display of target electrical appliances without the prescribed marking | Sales outlets and e-commerce operators should also verify the marking |
| Danger Prevention Order | Article 42-5 of the Act | May require recalls or other measures to prevent hazards | Manage model types, lot numbers, sales destinations, inventory, and recall progress |
| Reporting, Collection, and On-site Inspections | Articles 43, 45, etc. of the Act | Reports and inspections related to business operations, testing, marking, sales, and inventory | Organize notifications, tests, inspections, certificates, and sales records in chronological order |
| Violation of Danger Prevention Order | Article 57, Item 6 of the Act | May be subject to imprisonment up to 1 year, fines up to 1 million yen, or both | Strictly manage order contents, deadlines, applicable model types, and implementation records |
| Penalties for Corporations | Article 59, Item 1 of the Act | Corporations may be fined up to 100 million yen for certain violations | Responsibility of the corporation's management, not just the individual staff member, should be considered |
| Other Penalties and Fines | Articles 57 through 61 of the Act | Actions such as unmarked sales, order violations, false notifications, and failure to notify are dealt with according to violation types | Individually confirm the violation actions and applicable articles |
It is not appropriate to assume that "any deficiency in PSE marking immediately results in the same penalties." Confirm distinctions based on the type of violation, presence or absence of administrative orders, intent or negligence, sales situation, and applicability to corporations.
Relation to Recalls and Serious Product Accidents
Compliance verification under the Electrical Appliance and Material Safety Act (PSE) and the reporting of serious product accidents or recalls after sales are separate systems.
Even if the PSE mark is properly displayed, if incidents such as fire, smoke, abnormal heating, electric shock, or leakage occur, it is necessary to investigate the cause, confirm whether it qualifies as a serious product accident, and consider measures such as suspension of sales, recalls, repairs, replacements, refunds, or issuing warnings.
Conversely, even if no accident has occurred, if it is found that technical standards are not met, defective parts are present, insulation is insufficient, charging control is faulty, or there is a risk of harm, suspension of sales or voluntary recall may be required.
Typical Practical Cases
| Case | Main Legal Issues | Required Checks | Initial Actions |
|---|---|---|---|
| Importing miscellaneous goods with an AC adapter | The main body may be exempt, but the adapter could be classified as a specified electrical appliance | Range of DC power supply devices, certificates, diamond-shaped PSE mark | Assess the main body and accessories separately |
| Importing LED lighting with CE mark | Differences between overseas compliance and Japanese standards compliance | Electrical appliance name, technical standards, round-type PSE mark, voluntary inspections | Verify differences from Japanese standards |
| Online sales of mobile batteries in the EC market | Scope of battery safety, labeling, inspections, hazardous goods transportation | Energy density, protection circuits, PSE mark, transport tests | Confirm product safety and transport safety concurrently |
| Importing household appliances with Wi-Fi functionality | Overlap between PSE and Radio Act requirements | Electrical appliance classification, wireless modules, certification numbers | Check the Electrical Appliance and Material Safety Act and Radio Act separately |
| Overseas business sells directly to Japanese consumers | Specified import business operator and Domestic Administrator | Sales contracts, notification, Domestic Administrator, inspection records | Establish domestic responsibility system before starting sales |
| Factory on certificate differs from actual manufacturing factory | Scope of conformity inspection certificates | Model, factory, parts, inspection methods | Halt shipment and sales; confirm with the designated conformity inspection body |
| PSE label deficiency discovered after customs clearance | Labeling and sales restrictions | Mark, notified business operator name, designated conformity inspection body name, ratings | Stop sales and confirm legally compliant corrective measures |
| Repeated fire incidents after sales | Serious product accidents, harm prevention, recall | Incident models, lots, causes, sales destinations, inventory | Report the incidents, stop sales, and conduct recalls simultaneously |
Specific Example 1: When Only the AC Adapter is a Specified Electrical Appliance
Suppose a desktop beauty device manufactured overseas is imported and sold on a domestic Japanese e-commerce site. The main unit operates on low-voltage direct current and is determined to be outside the scope of the Electrical Appliance and Material Safety Act; however, the included AC adapter qualifies as a Specified Electrical Appliance due to its rated capacity and other requirements as a DC power supply.
In this case, the product set cannot be sold solely on the basis that the main unit is exempt. For the AC adapter, confirmation is required for the import business notification, compliance with technical standards, voluntary inspection, certificate of conformity inspection, the diamond-shaped PSE mark, the notifying business operator’s name, and the registered testing organization’s name.
If the overseas manufacturer changes to a different adapter, even if the appearance is similar, the model, factory, circuit, components, and scope of the certificate must be rechecked.
Specific Example 2: When an Overseas Business Sells Directly to Japan
Consider an overseas home appliance manufacturer that sells electrical products directly to Japanese consumers via an online marketplace, without involving a Japanese corporation or domestic import company.
From December 25, 2025, under this sales model, the overseas business could become subject to registration as a Specified Importer, and may be required to appoint a Domestic Administrator.
The Domestic Administrator is not merely a contact point. They must establish a system within Japan capable of handling registration information, inspection records, administrative notifications, accident response, reports and data collection, as well as on-site inspections.
Example 3: Discovery of Discrepancies in Certificate of Conformity After Customs Clearance
Consider a case where an AC adapter classified as a Specified Electrical Appliance is imported and, after customs clearance, preparations are underway for sales at a domestic warehouse. It is then discovered that the manufacturing plant listed on the certificate of conformity differs from the actual manufacturing plant.
Even if the certificate lists the same product name or brand, if the applicable model, manufacturing plant, or testing method do not match, the certificate may not serve as a valid basis for sales.
The importer and seller should suspend sales and shipment, and consult with the overseas manufacturer and the registered inspection agency. If necessary, they should consider retesting, obtaining a new certificate, correcting product labeling, or returning the merchandise.
Common Misconceptions
| Misconception | Actual Understanding | Practical Points to Note |
|---|---|---|
| If a product is sold overseas, it can also be sold in Japan | Target determination, technical standards, notification, inspection, and labeling are required under Japanese regulations | Differentiate specifications for the overseas market and for Japan |
| If a product has CE marking or UL certification, it complies with PSE requirements | Foreign standards and certifications do not substitute for Japanese legal obligations | Confirm differences from Japanese standards |
| Simply printing the PSE mark allows for sales | Display is done after completing notification, conformity to technical standards, inspection, and obtaining certificates | Do not treat labeling as the starting point of compliance |
| Self-inspection is not required for circular PSE marks | Self-inspection and record-keeping are required even for electric appliances other than specified electrical products | Do not confuse exemption from third-party inspection with exemption from self-inspection |
| If the main unit is not subject, neither are included accessories | AC adapters, cords, rechargeable batteries, etc. must be individually assessed | Create a complete list of all components inside the package |
| Once customs clearance is granted, domestic sales are permitted | Customs procedures and domestic sales regulations are separate | Confirm legal compliance before starting sales |
| Certificates of conformity can be reused for products with the same name | Model, factory, structure, parts, and other scope factors are important | Match certificates with actual products |
| Inspection can be entrusted entirely to the overseas manufacturer | The importer must be able to explain the fulfillment of statutory obligations | Obtain and retain inspection methods and records |
| The Domestic Administrator can just be the recipient of mail | Requires an operational system to handle administrative responses and managing inspection records | Define authority, requirements, and duties contractually |
| The freight forwarder’s transport guarantees PSE compliance | Transport contracts and obligations under the Electrical Appliance and Material Safety Act are usually separate | Check contract terms and actual scope of operations |
| Having PSE means no liability in case of accidents | PSE marking, product liability, accident reporting, and recalls are separate matters | Continuously monitor post-sale accident information |
| If there is a violation, the same penalty is always immediately imposed | Confirm each violation act, administrative order, and applicable penalty separately | Differentiation of the structure of Articles 57 to 61 should be made |
| If a product can be listed on an e-commerce platform, it complies with the law | Platform screening is not legal compliance verification by authorities | Manage sales eligibility and legal compliance separately |
Checklist for Judgment
| Confirmation Stage | Party to Confirm With | Points to Verify | Actions if Issues Are Found |
|---|---|---|---|
| Product Planning | Overseas Manufacturer, Product Manager | Usage, Structure, Ratings, Power Supply, Accessories | Halt orders until applicable regulations are confirmed |
| Determining Applicable Items | Legal, Quality, Testing Organizations | Article 2 of the Act, Enforcement Ordinance Table, Examples of Inclusion/Exclusion Interpretation | Document the basis for inclusion or exclusion |
| Classification Judgment | Quality, Registered Testing Organizations | Specified Electrical Appliances or Non-Specified | Confirm the required inspection method |
| Verification of Commercial Flow | Sales, Legal, Overseas Partners | Domestic Importer, Direct Sales, Specified Importer | Confirm the responsible entity and Domestic Administrator |
| Business Notification | Importer, Regional Bureau of Economy, Trade and Industry | Electrical Appliance Category, Type Classification, Domestic Administrator | Correct notification details |
| Technical Document Review | Overseas Manufacturer, Testing Organization | Circuit Diagrams, Parts Lists, Test Reports, Specifications | Request missing documents or additional tests |
| Conformity Inspection | Registered Testing Organization | Type, Factory, Certification, Validity Period | If discrepancies occur, halt sales preparations |
| Designing Voluntary Inspections | Quality, Overseas Factory | Inspection Items, Equipment, Frequency, Judgment Criteria | Adjust to comply with statutory methods |
| Import Lot Acceptance | Warehouse, Quality, Overseas Factory | Type, Quantity, Inspection Records, Appearance | Isolate affected lots |
| Accessory Confirmation | Product Manager, Quality | AC Adapters, Cords, Plugs, Rechargeable Batteries | Check documents and labeling for each component |
| Labeling Confirmation | Quality, Sales, Warehouse | PSE Mark, Business Entity Name, Testing Organization Name, Ratings | Correct using lawful methods before sales |
| Before Import Declaration | Importer, Customs Broker | Product Name, HS Code, Usage, Other Regulations | Obtain additional documents |
| Before Sales Start | Management, Legal, Quality | Notification, Inspection, Certification, Labeling, Manuals | Do not sell if not completed |
| When Listing on EC Platforms | EC Manager, Marketplace | Product Photos, PSE Labeling, Certification Documents | Match product pages with actual items |
| When Receiving Accident Reports | Consumers, Retailers, Consumer Affairs Agency | Ignition, Smoke, Electric Shock, Type, Lot | Stop use, preserve evidence, begin reporting and evaluation |
| Recall Judgment | Management, Legal, Quality, Overseas Manufacturer | Risk Level, Scope, Sales Destinations, Measures | Implement sales suspension, recall, repairs, etc. |
| Administrative Inquiry | Ministry of Economy, Trade and Industry, Regional Bureaus | Notification, Tests, Inspections, Labeling, Sales Records | Organize and submit facts chronologically |
Situations When Consulting an Expert Is Advisable
- When the specific electrical product subject to the law cannot be identified
- When it is unclear whether the product is a Specified Electrical Appliance or not
- When differences between overseas test reports and Japanese technical standards cannot be evaluated
- When the conformity certification does not match the actual model or manufacturing plant
- When the status as a Specified Importer or Domestic Administrator is uncertain
- When the method of self-inspection or the contents of inspection records cannot be confirmed
- When deficiencies in PSE marking or notification are discovered after customs clearance
- When judgment regarding products such as AC adapters, cords, or storage batteries is complex
- When incidents involving fire, electric shock, smoke, or abnormal heat occur
- When the Ministry of Economy, Trade and Industry requests reports, document submission, on-site inspection, or corrective actions
- When considering sales suspension, recall, cessation of use, or product replacement
- When confirming the applicability of Product Liability (PL) insurance or recall cost insurance
Potential contacts for consultation include the Ministry of Economy, Trade and Industry or regional economic bureaus, registered testing laboratories, test organizations knowledgeable about the Electrical Appliance and Material Safety Act, lawyers specializing in product safety, insurance companies or insurance agents, and logistics providers experienced in hazardous goods transportation.
Summary
The Electrical Appliance and Material Safety Act (PSE) for imported goods is a regulatory system that requires import business registration, conformity to technical standards, self-inspection, inspection records, conformity inspection, PSE marking, sales restrictions, and post-sale danger prevention measures when importing and selling designated electrical appliances manufactured overseas into Japan.
Electrical appliances are divided into specified electrical appliances and non-specified electrical appliances. Specified electrical appliances require a diamond-shaped PSE mark and conformity inspection by a registered testing organization, while non-specified electrical appliances use a circular PSE mark. However, both categories are subject to obligations for conformity to technical standards, self-inspection, inspection records, and marking.
The legal foundations include: the definition of specified electrical appliances in Article 2, Paragraph 2; business registration under Article 3; conformity to technical standards, self-inspection, and inspection records under Article 8; conformity inspection for specified electrical appliances under Article 9; marking under Article 10; sales restrictions under Article 27; and Danger Prevention Orders under Article 42-5.
From December 25, 2025, certain overseas businesses that directly sell PS mark target products to consumers within Japan will also be regulated as specified importers. Where applicable, these businesses must appoint a Domestic Administrator, include this information in the notification under Article 3, and establish a system to verify inspection records domestically.
Even if the main product itself is outside the scope, components such as AC adapters, chargers, power cords, plugs, or lithium-ion batteries may be independently regulated. All components included in the packaging must be individually checked.
Compliance with CE marking, UL certification, or IEC standards does not substitute for Japanese requirements under Japan’s Electrical Appliance and Material Safety Act such as notification, inspection, certificates, or PSE marking.
Customs clearance and legality of domestic sales are separate matters. If there are deficiencies in registration, conformity to technical standards, self-inspection, certificates of conformity, or marking, sales restrictions, correction of markings, replacement of accessories, return, disposal, or recalls may be required even after customs clearance.
Responses to violations include prohibition orders on marking, sales restrictions, Danger Prevention Orders, requests for reports, inspections, and penalties under Articles 57 to 61. Violations of Danger Prevention Orders may lead to severe criminal penalties and corporate fines against both the actor and the corporation.
Freight forwarders and customs brokers are generally not the final decision-makers on PSE conformity. However, in practice, for imports involving products with AC adapters, batteries, home appliances, LED devices, electrical toys, communication devices, etc., it is effective to encourage importers to review applicability, registration, inspection, marking, and compliance with other related laws.
This article aims to provide a general overview of the Electrical Appliance and Material Safety Act and related import and sales practices. It does not determine the electrical appliance applicability, conformity to technical standards, PSE marking, status as a specified importer, administrative liability, criminal liability, liability for damages, or insurance coverage for individual products. Actual import and sales activities should be verified against the latest laws, enforcement orders, enforcement regulations, technical standards, official documents from the Ministry of Economy, Trade and Industry, product specifications, model classifications, test data, contracts, and consultations with relevant authorities.
