Safety Regulations for Imported Gas Equipment

Safety Regulations for Imported Gas Appliances in Japan

The safety regulations for imported gas appliances require that gas appliances for city gas or LP gas manufactured overseas must comply with technical standards, business notification, self-inspection, inspection record retention, necessary conformity inspections, and statutory labeling when sold within Japan.

For gas appliances intended for city gas, the PSTG Mark system under the Gas Business Act applies. For liquefied petroleum gas appliances, the PSLPG Mark system applies, based on the Act on the Securing of Safety and the Optimization of Transaction of Liquefied Petroleum Gas.

PSTG stands for Product Safety of Town Gas Equipment and Appliances. PSLPG stands for Product Safety of Liquefied Petroleum Gas Equipment and Appliances.

Gas appliances may cause serious accidents such as carbon monoxide poisoning, fire, explosion, abnormal combustion, gas leaks, or burns if the type of gas, supply pressure, connection method, combustion method, installation location, or ventilation conditions are inappropriate.

Even if gas appliances are legally sold overseas or conform to foreign standards, they may not be eligible for sale in Japan unless they comply with Japan’s gas type, pressure, connection method, technical standards, and labeling system.

Furthermore, obtaining an Import Permit does not automatically authorize sales within Japan. Even after customs clearance, sales or display for sales purposes may be restricted if the required notifications, inspections, PSTG or PSLPG Marks, Notified Business Operator's name, gas type used, installation conditions, and other labeling requirements are not properly fulfilled.

Scope Covered in This Article

Purpose and Background of Safety Regulations for Imported Gas Appliances

The purpose of the gas appliance regulations is to ensure the safety of manufacturing, importing, and selling gas appliances for city gas and LP gas, and to prevent accidents that may harm the life or body of general consumers.

Gas appliances are products that burn fuel, and if gas leakage, incomplete combustion, malfunctioning exhaust, abnormal combustion, or misconnection occurs, it could lead to serious accidents such as carbon monoxide poisoning, fire, or explosion.

Therefore, for gas appliances and liquefied petroleum gas appliances specified by law, manufacturers or importers must verify compliance with technical standards set by the government, conduct self-inspections, and display the PSTG Mark or PSLPG Mark.

Especially, products with a high risk of causing disasters are classified as specified gas appliances or specified liquefied petroleum gas appliances. For these products, in addition to self-inspections by Notified Business Operators, conformity inspections by registered conformity inspection bodies are required.

Legal Classifications for City Gas Appliances and LP Gas Appliances

Even if products share the same trade names such as “gas cookers,” “water heaters,” or “stoves,” city gas appliances and LP gas appliances differ in applicable laws, statutory marks, technical standards, and usage conditions.

This is not simply a matter of replacing nozzles or connection parts to sell the product. The product design, combustion performance, safety devices, labeling, and the applicable model types for conformity inspection all need to be checked.

Specified Gas Appliances and Other Gas Appliances

Under the Gas Business Act, from the perspective of product safety administration, gas appliances for city gas are classified into four specified gas appliance categories and four other gas appliance categories according to combustion method and other factors.

The difference between the Diamond PSTG Mark and the Round PSTG Mark is not just a design variation. Specified gas appliances require conformity inspection by registered conformity inspection bodies and the retention of conformity certificates.

Specified Liquefied Petroleum Gas Appliances and Other Liquefied Petroleum Gas Appliances

Under the Act on the Securing of Safety and the Optimization of Transaction of Liquefied Petroleum Gas, with the addition of portable liquefied petroleum gas burners on February 6, 2025, the product safety administration classifies regulated items into eight types of specified liquefied petroleum gas appliances and nine types of other liquefied petroleum gas appliances.

Differences Between the PSTG Mark and the PSLPG Mark

Differences to Check Between Japanese and Overseas Specifications

Recent Amendments, Effective Dates, and Transitional Measures

Main Situations Where Safety Regulations for Imported Gas Appliances Apply

Requirements for Displaying Statutory Marks

Exclusions, Exceptions, and Situations Requiring Individual Confirmation

Differences from Other Product Safety and Communication Regulations

Obligation Flow for Importers and Sellers

1. Determine the product’s intended use, structure, fuel type, combustion method, and rated specifications.
2. Confirm whether the product is for city gas or LP gas use.
3. Verify whether it falls under the legal definitions of gas appliances or liquefied petroleum gas equipment, etc.
4. Check if it qualifies as a specified gas appliance or specified liquefied petroleum gas equipment, etc.
5. Identify the domestic importer or Specified Import Business Operator responsible.
6. Submit the required business notifications.
7. Obtain specifications, drawings, parts lists, and test documentation from the overseas manufacturer.
8. Confirm compatibility with Japanese gas types, supply pressures, connection methods, and current technical standards.
9. For specified products, undergo conformity inspection by a registered conformity inspection body.
10. Verify the model type, manufacturing plant, and applicable scope on the conformity certificate.
11. Conduct self-inspections and create and retain inspection records.
12. Display the correct PSTG Mark or PSLPG Mark appropriately.
13. Confirm the Notified Business Operator's name, markings related to the registered conformity inspection body, gas type, and ratings.
14. Prepare Japanese-language manuals, installation guides, warning labels, and ventilation conditions.
15. Cross-check the product, packaging, manuals, and sales pages for consistency.
16. Perform pre-sale inspection and ensure the model type and lot can be identified.
17. Establish a system for handling accident reports, repairs, inspections, recalls, and regulatory reporting after sales.

Even if the overseas manufacturer states compliance with PSTG or PSLPG, importers and sellers need to personally verify the applicable model types, test contents, manufacturing plants, responsible entities for markings, and inspection records.

Documents to Obtain Before Import

Items to Verify on the Label

• Whether it is clearly indicated for city gas or LP gas use
• Whether the correct PSTG Mark or PSLPG Mark is selected
• Whether the diamond-shaped mark is displayed for specified products
• Whether the round mark is displayed for other applicable products
• Whether the name or title of the Notified Business Operator is correctly shown
• Whether the registered conformity inspection body is indicated for specified products
• Whether the type of gas used, gas consumption, supply pressure, and rated capacity are appropriate
• Whether the indication for indoor use, outdoor use, and combustion method is appropriate
• Whether warnings regarding ventilation, exhaust, installation distance, and connection are provided
• Whether the product, packaging, user manual, installation manual, and sales page are consistent
• Whether the labeling is easily visible and applied in a durable manner
• Whether inventory does not contain a mix of different gas types, models, or statutory marks

Even if the PSTG or PSLPG Mark image is printed on the product, it is not considered a lawful label unless the notification, technical standards compliance, self-inspection, required conformity inspection, and record-keeping have been properly conducted.

Items Importers and Sellers Should Confirm

• Whether the product is for city gas or LP gas
• Whether the product category and model classification subject to legal regulations can be identified
• Whether it qualifies as a specified gas appliance or specified liquefied petroleum gas appliance
• Whether business notification has been completed
• Whether there are documents explaining conformity with Japanese technical standards
• Whether conformity inspection by a registered conformity inspection body is required
• Whether the model and manufacturing factory on the conformity certificate match
• Whether self-inspection and preparation/retention of inspection records can be conducted
• Whether the PSTG Mark or PSLPG Mark, Notified Business Operator's name, and rating display are appropriate
• Whether it corresponds to Japanese gas type, pressure, connection method, and installation conditions
• Whether compliance with other laws regarding power cords, AC adapters, radio functions, etc. has been confirmed
• Whether Japanese instruction manuals, installation manuals, and warning labels are properly prepared
• Whether there is a system for accident reporting, inspection, repair, recall, and withdrawal after sales

Items Freight Forwarders Should Confirm

Freight forwarders are generally not in a position to make the final judgment on whether gas products fall under regulatory scope or comply with technical standards.

However, if based on the cargo’s name, use, fuel type, accessories, and planned sales, there is a possibility that it is subject to gas product regulations, it is important to prompt the importer to confirm accordingly.

• Whether the cargo includes gas stoves, water heaters, stoves, bath boilers, burners, gas torches, etc.
• Whether it is intended for city gas or LPG use and that this is clearly identified
• Whether it is planned to be sold or provided within Japan
• Whether the importer has confirmed the presence of PSTG or PSLPG Marks
• Whether hoses, regulators, gas valves, power cords, or AC adapters are included
• Whether transport regulations for hazardous materials, PSE, PSC, Radio Law, or other regulations overlap
• Whether inspection, labeling, repacking, or replacement of instruction manuals is scheduled after customs clearance
• Whether the sales start date aligns with the schedule for inspection and labeling work

Simply prompting confirmation by the freight forwarder does not transfer the importer’s legal obligations under the law to the freight forwarder.

Comparison of Freight Forwarders' Scope of Involvement

The following five categories are not classifications established by law or across the entire industry. They are analytical frameworks used in this series to organize the scope of freight forwarders' involvement.

Contracting Carrier and Actual Carrier are concepts indicating legal or contractual status and do not replace the above five categories.

Actual operations such as inspection, label application, storage, repacking, or inland delivery do not themselves constitute a sixth category. The actual extent of responsibility should be determined based on contracts, quotation terms, work instructions, clauses, and practical handling.

Items for Customs Brokers to Verify

• Whether the invoice product names and product documentation suggest the possibility of gas appliances
• Whether it has been confirmed if the product is for city gas or LP gas use
• Whether verification is needed beyond the HS code, including the fuel type, usage, combustion method, and gas consumption
• Whether the importer is repeatedly importing the goods for resale purposes
• Whether the importer has checked the notification requirements, technical standards, inspection, and labeling
• Whether hoses, regulators, gas valves, electrical components, etc., fall under different regulatory scopes
• Whether there is overlapping regulation with PSC, PSE, Radio Law, Household Goods Quality Labeling Act, or other regulations
• Whether inspections, labeling, or repackaging are planned after customs clearance
• Whether the importer is confusing the Import Permit with legal eligibility for domestic sale

The Import Permit signifies the completion of the customs declaration procedure under the Customs Act and does not comprehensively guarantee compliance with domestic sales regulations, including the Gas Business Act or the Act on the Securing of Safety and the Optimization of Transaction of Liquefied Petroleum Gas.

Direct Sales by Overseas Operators

From December 25, 2025 onwards, when overseas operators sell PSTG or PSLPG-targeted products directly to domestic consumers in Japan via online malls, their own e-commerce sites, or other methods without going through importers in Japan, the Specified Import Business Operator requirements apply.

A Specified Import Business Operator must appoint a Domestic Responsible Person in Japan and fulfill the applicable obligations, including business notification, confirmation of conformity to technical standards, self-inspection, any required conformity inspection, labeling, record retention, and accident response.

Shipping directly from overseas, not having a corporation in Japan, or receiving payment overseas alone does not exempt the overseas operator from applying Japanese product safety regulations.

Major Cases Where Customs Clearance Is Granted but Sales Are Prohibited

Relationship with Administrative Measures and Penalties

Violations of gas equipment regulations do not necessarily end with simple label corrections. Depending on the nature of the violation, associated risks, quantity sold, occurrence of accidents, and the company’s response, administrative or criminal measures may come into question.

In cases where required PSTG or PSLPG Marks are missing on products sold or displayed for sale, depending on the type of violation, criminal penalties such as imprisonment for up to one year, fines up to one million yen, or both may apply.

Penalties such as fines are also stipulated for violations of business notifications, self-inspections, inspection record-keeping, reporting, on-site inspections, and other obligations. The specific applicable statutory provisions and penalties need to be confirmed for each violation, including whether the Gas Business Act or the Act on the Securing of Safety and the Optimization of Transaction of Liquefied Petroleum Gas applies.

Relationship with Accidents and Recalls

Gas appliances may cause serious accidents such as carbon monoxide poisoning, fire, explosion, abnormal combustion, gas leaks, or burns.

If an accident or defect is identified after the product has been sold, measures such as sales suspension, cause investigation, consumer warnings, free repairs, replacement, collection, or recall may be necessary.

If gas appliances fall under consumer products and a major product accident occurs, the importer or other responsible entity may have a reporting obligation to the government.

Importers and sellers must establish a system to trace product models, manufacturing lots, import timing, sales destinations, installation locations, accident information, repair history, and communication records with overseas manufacturers.

Even if the PSTG Mark or PSLPG Mark is lawfully displayed, this does not exempt the seller from responsibilities related to post-sale product safety assurance or accident response.

Example 1: Misclassification of Fuel Type for Imported Gas Stoves

An importer intends to procure household gas stoves from an overseas manufacturer for sale in Japan. The person in charge only checked the product name and placed the order without clearly confirming whether the stoves were for city gas or LP gas.

After importation, a review of the product specifications revealed that the stoves were designed for LP gas, although the sales page indicated they were for city gas.

In this case, simply changing the label to city gas for sales is not permissible. This is because the nozzle, combustion performance, supply pressure, safety devices, connection method, and applicable technical standards differ between the fuel types.

Sales must be suspended, and the affected inventory isolated while confirming the applicable PSLPG system, product specifications, and certification. If selling as city gas stoves, it is standard practice to procure a different model type compliant with Japanese city gas specifications.

Example 2: Mistaking a Semi-Enclosed Water Heater for a Round PSTG Product

Assume an importer and seller categorizes an overseas-made gas instant water heater as a general water heater subject to the Round PSTG Mark.

However, upon reviewing the structural diagram, the product is a semi-enclosed combustion type. Semi-enclosed combustion gas instant water heaters are designated as Specified Gas Appliances and require the Diamond PSTG Mark.

In this case, not only must the Notified Business Operator conduct technical standards conformity confirmation and self-inspection, but conformity inspection by a registered conformity inspection body and retention of the conformity certificate are also required.

If the misclassification is discovered after import, the product should not be put on sale. The model, manufacturing plant, test data, and availability of certification should be verified with the registered conformity inspection body.

Example 3: Attempting to Sell Unmarked Gas Torches After the Grace Period Ends

Assume an importer and seller tries to continue selling gas torches, purchased in 2025, on an online marketplace after February 6, 2026.

For portable liquefied petroleum gas burners subject to regulation, the rules began on February 6, 2025. After the one-year grace period ending February 5, 2026, products sold from February 6, 2026 onwards must bear the Diamond PSLPG Mark.

It should be noted that inventory imported during the grace period is not automatically allowed to be sold without conditions after the grace period ends.

It is necessary to verify the product’s construction, manufacturing date, import date, conformity inspection, statutory markings, and planned sale date. If the product lacks the required Diamond PSLPG Mark, listing and shipment must be suspended.

Example 4: When an Overseas Business Sells Directly to Japan

Assume an overseas manufacturer operates a Japanese-language e-commerce site, receives orders from consumers in Japan, and ships gas torches or gas stoves directly from an overseas warehouse.

From December 25, 2025 onward, if this sales activity qualifies as direct sales to domestic consumers, the overseas business must confirm its obligations as a Specified Import Business Operator and appoint a Domestic Responsible Person.

The Domestic Responsible Person is not merely a nominal representative. They must have a system in place domestically capable of liaising with government authorities, maintaining documents, responding to requests for reports and inspections, collecting accident information, and managing recalls.

It is necessary to distinguish the roles of the overseas business, Domestic Responsible Person, e-commerce platform operator, and logistics providers, and to clearly define who will handle notification filing, compliance with technical standards, self-inspections, conformity inspection, labeling, and accident response.

Common Misunderstandings

Decision Checklist

Situations Where Consulting Experts Is Recommended

• When it is not possible to determine from technical documents whether the product is for city gas or LP gas
• When it is unclear whether the product falls under legally regulated items
• When the combustion method or diamond/round shape classification cannot be confirmed
• When it is uncertain if overseas test reports meet Japanese technical standards
• When undergoing conformity inspection for specified gas appliances or specified liquefied petroleum gas equipment for the first time
• When the model type or manufacturing factory on the conformity certificate does not match the actual product
• When it is unclear whether existing certificates can still be used after product modifications
• When products without statutory marks or with incorrect labeling have already been sold
• When carbon monoxide poisoning, fire, explosion, or gas leakage accidents occur
• When receiving notifications from authorities regarding reports, document submissions, on-site inspections, or improvement orders
• When concluding contracts to act as a Domestic Responsible Person for overseas operators
• When deciding policies on sales suspension, recalls, returns, disposal, or consumer compensation

Consultation may be sought from the Ministry of Economy, Trade and Industry or the relevant Regional Bureau of Economy, Trade and Industry, registered conformity inspection bodies, product safety testing institutions, gas-related business operators, lawyers knowledgeable about gas appliance regulations, and other specialists.

Summary

Safety regulations for imported gas appliances apply the PSTG Mark system under the Gas Business Act for city gas appliances, and the PSLPG Mark system under the Act on the Securing of Safety and the Optimization of Transaction of Liquefied Petroleum Gas for LP gas appliances.

The Gas Business Act classifies its coverage into four categories of Specified Gas Appliances and four categories of Other Gas Appliances. Under the Act on the Securing of Safety and the Optimization of Transaction of Liquefied Petroleum Gas, following the addition of portable LP gas burners, eight categories of Specified Liquefied Petroleum Gas Appliances and nine categories of Other Liquefied Petroleum Gas Appliances are covered.

Specified Gas Appliances and Specified Liquefied Petroleum Gas Appliances use a diamond-shaped statutory mark. In addition to self-inspections by Notified Business Operators, conformity inspections by registered conformity inspection bodies and retention of conformity certificates are required.

Other applicable products use a round statutory mark. Even if conformity inspections by registered conformity inspection bodies are not required, confirming compliance with technical standards, conducting self-inspections, maintaining inspection records, and marking are necessary.

In import operations, it is essential not only to distinguish between city gas and LP gas appliances but also to verify Japan’s gas type, supply pressure, connection method, combustion method, installation location, ventilation and exhaust conditions, and Japanese-language markings.

For gas torches subject to regulation, the regulations took effect on February 6, 2025. After a one-year transitional period ending on February 5, 2026, the Diamond PSLPG Mark will be required at point of sale starting from February 6, 2026.

Additionally, from December 25, 2025, when overseas businesses directly sell regulated gas appliances to domestic consumers, the Specified Import Business Operator and Domestic Responsible Person requirements apply.

Having an Import Permit, foreign standards, overseas manufacturer safety explanations, or statutory mark images on products alone does not guarantee lawful sale within Japan.

Freight forwarders and customs brokers are generally not in the position to make final judgments on applicable items or technical conformity. However, if the possibility of coverage is identified, it is important to prompt importers to verify this and coordinate inspection, marking, storage, and the initiation of sales processes.

If violations are discovered, sanctions could include sales suspension, improvement orders, prohibition of markings, danger prevention orders, recalls, public disclosure of violations, and potential criminal penalties.

When selling imported gas appliances, it is fundamental to verify fuel classification, target product category, technical standards, notifications, inspections, markings, and post-sale responses in an integrated manner at the product planning and ordering stages—not just after customs clearance or immediately before sales.

This article aims to provide a general overview of safety regulations and import sales practices related to imported gas appliances and does not guarantee legal compliance or saleability of individual products. For actual products, confirmation should be obtained regarding the latest laws, technical standards, official documents, product specifications, and relevant administrative authorities.