Long-Term Safety Inspection System for Imported Durable Goods

What Is the Long-Term Use Product Safety Inspection System for Imported Goods

The Long-Term Use Product Safety Inspection System for Imported Goods is a system designed to prevent serious accidents such as fires, fatalities, and carbon monoxide poisoning caused by aging deterioration of Specified Maintenance Products manufactured overseas and imported and sold in Japan. This system involves registering owner information, notifying inspection timing, conducting statutory inspections, and establishing inspection and repair frameworks.

Specified Maintenance Products are consumer products that are difficult for owners to maintain themselves and that are likely to pose significant safety risks to the life or body of general consumers due to safety hazards caused by aging deterioration over long-term use.

Under current law, the definition of Specified Maintenance Products is based on Article 2, Paragraph 5 of the Consumer Product Safety Act, with the specific applicable items designated by Article 4 of the Enforcement Order of the Act and Appendix 3.

At present, the applicable items include two products: oil water heaters and oil bath boilers. Initially, nine product categories were designated when the system was established, but seven were removed from designation following revisions to the Enforcement Order effective August 1, 2021.

Importers are required to continuously manage not only customs clearance and pre-sale labeling but also post-sale owner information management, inspection notification, acceptance of inspections domestically, repairs, parts supply, and accident response.

The Long-Term Use Product Safety Inspection System for Imported Goods is not completed solely at the time of import. It assumes safety management throughout the long-term use of the products within Japan.

Scope Covered in This Article

This article covers post-sale management when importing and selling Specified Maintenance Products in Japan. Technical standards for individual products, the preparation of reports on serious product accidents, and recall implementation methods should be confirmed in the related articles.

Purpose of the System

For products used over long periods, issues such as part wear, corrosion, combustion failure, wiring deterioration, leaks, abnormal heating, and ignition may occur even if there were no problems at the start of use.

In particular, for Oil Water Heaters and Oil Bath Boilers, deterioration of fuel systems, combustion parts, heat exchangers, exhaust pathways, and safety devices could lead to fire, carbon monoxide poisoning, or fatal accidents.

It is difficult for owners to assess the condition of internal parts themselves. Therefore, manufacturers or importers set inspection intervals for each product, manage owner information, notify owners of inspection times, and implement inspections accordingly.

Legal Positioning

Due to a legal amendment effective December 25, 2025, there will be renumbering of Articles related to the Long-term Use Product Safety Inspection System. Older guides or explanations may refer to former Article numbers from Article 32-3 onwards, so cross-checking with the current law is necessary.

Specified Maintenance Products Covered by the System

Determination of whether a product falls under the designated target items is based not only on the product name but also on verification of fuel type, structure, capacity, usage, installation method, and the requirements listed in Appendix 3 of the Enforcement Regulations.

Changes in Target Products

The Long-Term Use Product Safety Inspection System was established on April 1, 2009.

Even for products removed from designation, factors such as manufacturing date, transitional measures, manufacturer voluntary inspections, recalls, or the Long-Term Use Product Safety Labeling System may be relevant. The fact that newly imported products are not Specified Maintenance Products does not imply that existing products do not require safety measures.

Differences Between the Long-Term Use Product Safety Inspection System and the Long-Term Use Product Safety Labeling System

Design Standard Usage Period and Inspection Period

The design standard usage period refers to the standard duration during which a product can be safely used under typical conditions without safety issues.

The inspection period is established based on the end of the design standard usage period and defines when inspections should be conducted to prevent hazards caused by aging deterioration.

There is no uniform number of years that applies to all oil water heaters or oil bath boilers. The manufacturing or importing business operator sets these periods in accordance with laws and technical materials, considering factors such as model, structure, components, usage conditions, durability testing, and failure data.

Role Allocation Among Stakeholders

Confirmation Flow for Import Sellers

1. Confirm the product name, usage, fuel type, structure, capacity, and installation method
2. Verify whether it qualifies as a consumer product
3. Confirm applicability as a Specified Maintenance Product based on Article 2, Paragraph 5 of the Act, and Article 4 and Appendix 3 of the Enforcement Order
4. Also verify compliance with the Long-Term Use Product Safety Labeling System and other relevant systems
5. Confirm notification of manufacturing/import business and the classification type
6. Confirm the standard design service life, inspection period, and the basis for setting them
7. Prepare main body markings, user manuals, owner tags, and Japanese warnings
8. Establish methods for receiving owner information, its intended use, management, and update procedures
9. Prepare handover explanation materials for retailers and installation contractors
10. Build a system to create and send inspection notification
11. Set up domestic inspection reception points, technicians, inspection standards, and fees
12. Organize systems for repair, parts replacement, parts supply, and instructions for discontinuation of use
13. Enable tracking of model, lot, sales destination, owner, and inspection history
14. Establish procedures for responding to serious product accidents, recalls, and administrative inquiries
15. Confirm technical support, cost allocation, and parts supply with overseas manufacturers through contracts

Owner Registration and Inspection Notifications

Owner registration is the fundamental basis for managing the system so that inspection notifications are sent at appropriate times.

• Whether owner registration can be done via owner card, web form, phone, or postal mail
• Whether the registration point operates continuously within Japan
• Whether the purpose of use is clearly stated and information is used only within the scope necessary for inspection notifications and execution
• Whether the owner registry can be managed accurately and securely
• Whether updates can be made for changes such as relocation, resale, transfer, inheritance, or ownership changes in rental properties
• Whether notifications can be sent before the inspection period arrives
• Whether procedures for reconfirmation exist when notifications are undeliverable, addresses are unknown, or owners are unidentified
• Whether inquiry handling is available for inspection applications, schedule adjustments, fee explanations, and result notifications

Even if import sellers distribute products, without a reception point for owner information and an inspection notification system, the purpose of the scheme cannot be fulfilled.

Matters to Confirm in Labeling and Delivery Explanation

• Is it identifiable as a Specified Maintenance Product?
• Is the standard design usage period indicated?
• Can the inspection period or timing be confirmed?
• Are the name and contact information of the manufacturer or importer verifiable?
• Is the method for registering owner information clearly stated?
• Is the inspection reception desk functional within Japan?
• Are the instruction manual, owner tag, warranty, and inspection guidance prepared in Japanese?
• Do the sales and installation providers have materials to explain to purchasers?
• Is delivery explanation and owner registration guidance provided even for EC (e-commerce) sales?

Simply translating the instruction manual from an overseas manufacturer may lack necessary explanations for the Japanese statutory inspection system, such as owner registration, inspection notifications, and domestic reception desks.

Relationship with Other Product Safety Regulations

Merely being classified as a Specified Maintenance Product does not confirm compliance with other laws and regulations.

Points Freight Forwarders Should Confirm

Freight forwarders are generally not in the position to make the final determination regarding compliance with the Long-Term Use Product Safety Inspection System. However, in import cases involving residential equipment or combustion appliances, it is practically effective to encourage importers to verify the system requirements after domestic sale.

• Whether the cargo corresponds to oil water heaters, oil bath boilers, heating devices, water heaters, or residential equipment
• Whether the products are intended to be sold and installed for general consumers within Japan
• Whether the importer has confirmed applicability to Specified Maintenance Products
• If the products will be sold or installed immediately after customs clearance, whether labeling, manuals, and owner registration materials are prepared
• Whether compliance with other relevant laws such as PSE, PSTG, PSLPG, PSC has been confirmed
• Whether transportation of replacement parts, repair items, inspection equipment, or recalled products may occur
• Whether there are concerns related to fuel residue, used parts, leaks, or hazardous materials

Standard Five Classifications of Freight Forwarder Involvement

The following five classifications are not categories established by law or the entire industry, but rather an analytical framework used in this series to organize the scope of freight forwarder involvement.

Contracting Carrier and Actual Carrier are concepts denoting legal and contractual status and do not replace the above five classifications.

Physical operations such as packing, storage, inspection, vanning, and devanning do not constitute a sixth classification. These are individual tasks whose scope of responsibility should be confirmed based on the relevant classification, contract, work instructions, and actual handling.

Items Customs Brokers Should Confirm

• Whether the invoice item names, usage, structure, fuel type, and HS codes indicate the possibility of the product being subject to the system
• Whether the importer is bringing in the cargo for resale or installation purposes
• Whether the importer has confirmed the product’s applicability to Specified Maintenance Products
• Whether import business notifications, labeling, owner registration, inspection notifications, and inspection systems are prepared
• Whether domestic sales regulations such as PSE, PSTG, PSLPG, PSC, or others apply
• Whether import permits and the legality of domestic sale or installation are confused
• Whether declarations for free replacement items, repair parts, returns, and inspection parts are appropriate

The Long-Term Use Product Safety Inspection System is not a process completed solely by import declaration. Even if customs clearance with an Import Permit is obtained, issues can arise after domestic sale or installation if notifications, labeling, owner registrations, or inspection frameworks are inadequate.

Key Situations Where Customs Clearance Is Granted but Sales or Long-Term Use Is Restricted

Relation to Administrative Measures

Relationship with Serious Product Accidents and Recalls

Products that have been used for a long time without receiving inspection notifications or undergoing inspections may have an increased risk of accidents due to aging deterioration.

In cases of fire, carbon monoxide poisoning, fatal accidents, etc., in addition to responding to the Long-Term Use Product Safety Inspection System, measures such as reporting serious product accidents, cause investigations, sales suspension, recalls, free inspections, repairs, or usage cessation advisories should be considered.

Merely conducting statutorily mandated inspections does not exempt manufacturers from liability under product liability laws, accident reporting, or recall responsibilities. Conversely, simply conducting a recall does not eliminate the legal obligations related to managing owner information or issuing inspection notifications under this system.

Documents to Confirm in Practice

Example 1: When There Is No Owner Registration System for Imported Oil Water Heaters

Suppose an importer-seller imports an overseas-made oil water heater into Japan, sells and installs it through a housing equipment company, but has not prepared owner labels, web registration, or a domestic registration reception desk.

Oil water heaters are currently classified as Specified Maintenance Products. Even if the Import Permit is obtained and the product operates normally, if owner information cannot be tracked, notifications cannot be sent to owners before the inspection period arrives.

The importer-seller should temporarily suspend new sales and installations, then verify the models, sales destinations, and installation locations of units already sold. They must coordinate with dealers and installers to guide owner registration and establish systems for usage purposes, information management, inspection notifications, and inspection reception.

Example 2: Importing Former Designated Products at the Time of the System Establishment

When importing an overseas-built built-in electric dishwasher, it was assumed that it is still subject to the Long-Term Use Product Safety Inspection System because older documents described it as a "Specified Maintenance Product."

Built-in electric dishwashers were designated products at the time the system was established, but they were removed from the designation as of the revision on August 1, 2021.

However, being excluded from the designation does not mean domestic regulations no longer apply. It is necessary to separately verify compliance with the PSE mark under the Electrical Appliance and Material Safety Act, applicability under the Long-Term Use Product Safety Labeling System, the instruction manual, accident and recall information, and other relevant points.

Example 3: When Parts Supply Has Ended After Inspection Notification

Assume the inspection period for an imported and sold Oil Water Heater is approaching, and inspection notices have been sent to owners, but the overseas manufacturer has already ceased production of key parts.

Even if the inspection is conducted, if defective parts cannot be replaced, responses such as determining whether continued use is possible, discontinuing use, product replacement, substitute parts, or recall may be necessary.

The importer-seller needs to contractually establish, prior to sales launch, the parts supply period, technical documentation, substitute parts, repair costs, product replacement, and cost responsibilities of the overseas manufacturer.

Common Misunderstandings

Decision Checklist

Situations Requiring Consultation with Experts

• When it is unclear whether a product falls under the Specified Maintenance Product category
• When the overseas manufacturer does not provide documentation supporting the design standard usage period
• When the Import Business Notification or model classification cannot be determined
• When there are issues with the intended use, management methods, or personal data protection of owner information
• When there are no technicians or service networks available domestically to conduct legally mandated inspections
• When the inspection period is approaching, but notification to the owner cannot be made
• When repair parts cannot be supplied after inspection
• When it is impossible to identify the applicable models, owners, or installation locations of already sold products
• When fire, carbon monoxide poisoning, death accidents, or serious malfunctions occur
• When authorities request reporting, improvements, submission of documentation, or other actions
• When considering recall, discontinuation of use, or product replacement
• When confirming the applicability of PL insurance or recall cost insurance

Possible consultation contacts include the Ministry of Economy, Trade and Industry or regional bureaus, the Consumer Affairs Agency, NITE, lawyers specializing in product safety, testing and inspection agencies, inspection service providers, insurance companies or insurance agents, and logistics operators experienced in transporting hazardous materials.

Summary

The Long-Term Use Product Safety Inspection System for Imported Goods requires manufacturers and importers of Specified Maintenance Products to set inspection periods and other conditions, provide labeling on the products, register owners, issue inspection notifications, conduct statutory inspections, and establish maintenance systems. This system aims to prevent serious accidents caused by aging deterioration.

Currently, the Specified Maintenance Products under this system are limited to two items: oil water heaters and oil bath boilers. Initially, there were nine designated items, but seven were removed from the list following revisions implemented on August 1, 2021.

Under current law, the definition of Specified Maintenance Products is provided in Article 2, Paragraph 5 of the Consumer Product Safety Act, with specific designations based on Article 4 of the Enforcement Order and Appendix 3 thereto. Manufacturer and importer notifications, setting of inspection periods, labeling, delivery explanations, owner information management, inspection notifications, implementation of inspections, and maintenance systems are stipulated from Article 32-4 onward of the Act.

The Long-Term Use Product Safety Inspection System and the Long-Term Use Product Safety Labeling System are separate schemes. The inspection system centers on owner information management and statutory inspections, while the labeling system focuses on hazard warning labels regarding risks associated with aging deterioration.

Import sellers are required not only to verify products before and after customs clearance but also to establish ongoing owner registrations, inspection notifications, domestic inspections, repairs, spare parts supply, and accident response processes that continue for extended periods after sale.

The standard design service life and inspection periods are not uniform fixed years applicable to all products. The basis for these settings must be confirmed according to factors such as model type, structure, usage conditions, and durability data.

Regulatory frameworks such as PSE, PSTG, PSLPG, and PSC are separate from the Long-Term Use Product Safety Inspection System. The designation as a Specified Maintenance Product alone does not confirm compliance with other statutory requirements.

Freight forwarders and customs brokers are generally not the final decision-makers regarding compliance with this system. However, in practice, when importing oil water heaters, oil bath boilers, combustion equipment, or residential equipment, it is effective to prompt importers to confirm applicable products, labeling, owner registration, inspection systems, and compliance with other relevant laws and regulations.

The ability to clear customs does not equate to lawful sale, installation, and long-term safe operation within Japan. Importers need to design procedures covering both pre-sale compliance and post-sale operation as an integrated process.

This article is intended to provide a general overview of the Long-Term Use Product Safety Inspection System and practical considerations for import sales. It does not determine the applicability of individual products as Specified Maintenance Products, notification obligations, labeling compliance, inspection duties, administrative liabilities, compensation responsibilities, or insurance coverage. Actual import and sale require verification of the latest laws, enforcement orders, official materials from the Ministry of Economy, Trade and Industry, product specifications, model classifications, technical data, contracts, and consultation with the relevant authorities.