Recall Response for Importers and Sellers — Practical Workflow

What Is a Recall of Imported Products?

A recall of imported products refers to the actions taken when safety defects, faults, labeling issues, or the risk of accidents are identified in products manufactured overseas and imported and sold within Japan. These actions include product retrieval, free repairs, parts replacement, provision of alternatives, refunds, inspections, warnings, requests to cease use, sales suspension, and other related measures.

The purpose of a recall is to prevent harm to consumers’ lives or bodies and to control the occurrence and spread of similar accidents.

Recalls are not limited to cases where serious accidents have already occurred. Even before accidents happen, recalls may be implemented to preempt damage if design issues, defective parts, manufacturing process abnormalities, insufficient warning labels, accident information overseas, or defects in the same production lot are discovered.

For imported products, the importer or domestic seller in Japan often plays a central role in communication and coordination with consumers, retailers, e-commerce platforms, administrative authorities, overseas manufacturers, logistics providers, and insurance companies.

Simply requesting the overseas manufacturer to investigate the cause of an accident is not always sufficient as a domestic response in Japan. A system that can implement sales suspension, customer notifications, product retrieval, refunds, repairs, administrative reporting, and disposal of recalled products domestically is necessary.

Scope Covered in This Article

Item	Contents Covered in This Article	Contents Covered in Other Articles
Recall of Imported Goods	Collection, repair, replacement, refund, inspection, safety alerts, suspension of sales, and progress management	Recall systems under individual laws for automobiles, pharmaceuticals, food, etc. are covered in specialized articles
Serious Product Accidents	Practical procedures for parallel confirmation of recall decisions and accident reporting	Determinations involving death, serious injury, permanent disability, carbon monoxide poisoning, and fires are covered under serious product accidents of imported goods
Product Accident Information Reporting	Organization of information on serious and non-serious product accidents	Statutory reporting within 10 days and information provision to NITE are covered under product accident information reporting systems for imported goods
Pre-Sale Regulations	Response when labeling deficiencies or non-compliance with standards are discovered after sales	PSC mark for imports, PSE mark for imports, and safety regulations for imported gas appliances are covered in related product safety regulation articles
Online Sales	Listing suspension, buyer notifications, product page corrections, and responses to e-commerce marketplaces	Institutional initiatives for online marketplaces are covered under imported products and product safety pledge articles
Logistics and Customs Clearance	Domestic consolidation, return shipping, re-export, export for repair, re-import, disposal, and transport of hazardous goods for recalled items	Specific articles handle individual hazardous goods transport methods and waste export regulations
Insurance	Basic distinctions between cargo insurance, product liability insurance, and recall expense insurance	Coverage eligibility for individual incidents should be confirmed according to contract terms and endorsements
Administrative Measures	Hazard Prevention Orders, Request for Reports, on-site inspections, and penalties for violations	Prohibitions on labeling and sales based on specific laws are covered in respective product safety system articles
Roles of Stakeholders	Scope of responsibilities for import sellers, retailers, overseas manufacturers, freight forwarders, customs brokers, and warehouse operators	Civil liability for damages is addressed in product liability and various compensation case articles

Purpose and Basic Concept of Recalls

A recall is not merely complaint handling, accepting returns, or customer service.

It is a product safety crisis response involving the identification of the scope of affected products after sales, determining how to notify consumers, and deciding the speed at which the hazard will be removed.

When assessing the need for a recall, a comprehensive evaluation is made beyond the number of incidents, including the severity of potential harm, likelihood of recurrence, frequency of use, age of the target users, product installation environment, the consumer’s ability to recognize the hazard, ease of discontinuing use, and whether repairs are possible.

Even if there is only one incident, prompt action is required if there is a structural defect that could cause fire, electric shock, suffocation, carbon monoxide poisoning, or serious injury.

Conversely, initiating a recall does not end with simply announcing the notification. As long as affected products remain in consumers’ hands, the possibility of incidents persists, so it is necessary to review responses continuously by monitoring the recall rate, repair rate, notification reach rate, and the number of units still in the market.

Main Recall Response Methods

Response Method	Main Content	Applicable Situation	Practical Considerations
Collection Type	Collect targeted products from consumers, retailers, or installation sites	When it is dangerous to continue using the product	Clearly define affected lot, return method, transportation conditions, storage location, and disposal method
Free Repair Type	Repair defective parts and restore the product to a safe usable condition	When repairs can reliably eliminate the danger	Manage repair centers, worker qualifications, repair parts, completion records, and repaired product identification
Parts Replacement Type	Replace hazardous parts with countermeasure parts	When the problematic parts are identified and safety after replacement can be confirmed	Manage target parts, replacement procedures, workers, replacement parts inventory, and collection of old parts
Substitute Product Exchange Type	Exchange targeted products for safe alternative or improved products	When repair is difficult but countermeasure products can be supplied	Confirm substitute product specifications, legal compliance, stock, warranty, and shipping costs
Refund Type	Refund the purchase price on condition that the product is returned, etc.	When repair or exchange is difficult or continuing use is inappropriate	Decide on proof of purchase, sales price, point payment, resale products, and handling via retailers
Inspection Type	Inspect targeted products and repair or replace if applicable	When individual differences exist and inspection can identify dangerous products	Clarify inspection criteria, inspectors, exclusion judgments, and inspection completion markings
Warning Type	Notify regarding usage methods, conditions, inspection methods, or discontinuation of use	When the danger can be effectively reduced through information provision	Carefully assess if warning alone is sufficient when some risk remains
Sales and Shipment Suspension Type	Suspend sales, shipment, advertising, exhibition, and new orders	During initial stages including investigation of causes and scope	Simultaneously suspend your own stock as well as retailers, warehouses, EC malls, and advertising sites
On-site Visit Type	Personnel visit the installation site to inspect, repair, or replace	For large equipment, installed products, or products difficult for consumers to return	Manage visit schedules, worker qualifications, installation environment, and post-work safety confirmation

Multiple methods may be combined in a single recall. For example, immediate suspension of use may be requested, followed by product collection and exchange with substitute products.

Voluntary Recalls and Measures Involving Administrative Response

Category	Main Content	Decision / Implementation Entity	Practical Considerations
Voluntary Recall	Business operators initiate collection, repair, replacement, refund, inspection, or warnings on their own	Manufacturers, importers, distributors, etc.	Even if voluntary, effectiveness and promptness in hazard prevention are required
Voluntary Recall in Parallel with Administrative Consultation	Business operators implement measures voluntarily while sharing information with administrative agencies	Business operators and relevant administrative agencies	Align accident reporting, notification details, scope of application, and progress management
Measures Based on Hazard Prevention Orders	To prevent occurrence or expansion of serious harm, orders are given to recall or take other necessary measures	Competent Minister, manufacturers or importers	Respond in accordance with the order content, target products, and implementation deadline
Sales and Labeling Restrictions Based on Specific Laws	Issues arise such as suspension of sales or prohibition of labeling for non-compliant or unlabeled products	Relevant administrative agencies and targeted business operators	Confirm applicable laws such as PSC, PSE, PSTG, PSLPG, etc.
Suspension of Listings on EC Marketplaces	Marketplace operators suspend listings, notify buyers, or delete product pages	Online marketplace providers	Ensure prompt provision of product model information and sales history for affected products
Sales Suspension Led by Retailers	Retailers stop sales of in-store and warehouse inventory and notify buyers	Wholesale and retail sellers	Coordinate the scope of application, notification content, and return conditions with the import sellers

A voluntary recall does not eliminate the need to confirm applicable requirements with the relevant authorities. Obligations such as reporting serious product accidents, complying with specific product safety regulations, and confirming hazardous materials, waste, and other legal requirements must be checked regardless of whether the recall was voluntarily initiated.

Information Triggering Recall Decisions

Source of Information	Main Content	Items to Confirm	Initial Action
Accidents/Complaints from Consumers	Smoke emission, ignition, damage, injury, abnormal odor, overheating, etc.	Accident circumstances, usage method, product number, damage, and location of the product	Advise to stop use and secure evidence such as the product, photos, and records
Reports from Retailers or Repair Shops	Similar defects, increased returns, concentrated repair requests	Number of cases, model, lot, sales period, and region	Judge necessity of sales suspension and expand confirmation to all sales channels
Notification from Overseas Manufacturer	Design defects, defective parts, manufacturing process abnormalities, overseas recalls	Identity with products for Japan, target lot, and countermeasure details	Cross-check inventory and sales history of products sold in Japan
Internal Inspections and Quality Audits	Non-compliance with standards, parts changes, inspection omissions, labeling deficiencies	Affected model, manufacturing period, factory, and sales volume	Stop shipment and sales, assess impact on already sold products
Inquiries from Government Agencies or NITE	Accident information, similar accidents, technical investigations, suspected legal violations	Accident products, inspection records, sales destinations, import records, and response history	Preserve materials and organize facts in chronological order
Alerts from e-Commerce Marketplaces	Lack of safety documents, violation of labeling, buyer accidents, overseas recall information	Listed SKU, sales volume, buyer information, and submitted documents	Confirm the scope of suspension of listings and simultaneously investigate other channels
Accidents Involving Competing or Similar Products	Accidents related to the same parts, factory, or design	Commonality with own products and reproducibility of the accident	Consider preventive inspection, additional testing, or sales hold
Confirmation of Laws and Technical Standards	Judgment of applicable items, labeling, inspection or compliance errors	Application to sold products, hazard potential, and possibility of correction	Implement sales suspension, consult with authorities, and identify target scope

Response Flow for Recall Occurrence

1. Receive accident information, defect reports, complaints, overseas recall information, or administrative inquiries.
2. Confirm the urgency of issues such as personal injury, fire, smoke, electric shock, or gas leaks.
3. Preserve evidence including faulty products, photos, videos, packaging, manuals, purchase records, etc.
4. Identify the model, serial number, lot number, manufacturing plant, and manufacturing period of the affected product.
5. Confirm import date, import quantity, sales period, sales quantity, inventory quantity, and sales channels.
6. Assess accident severity, possibility of recurrence, affected parties, usage environment, and the feasibility of hazard avoidance.
7. Determine whether the case possibly qualifies as a serious product accident and if reporting to the Consumer Affairs Agency within 10 days is required.
8. Consider providing accident information to NITE and administrative consultation even for non-serious product accidents.
9. Implement sales suspension, shipment suspension, inventory segregation, advertising suspension, and cessation of e-commerce pages.
10. Notify the overseas manufacturer, retailers, e-commerce platforms, warehouse operators, and logistics providers of the affected scope.
11. Decide on the method of recall, repair, parts replacement, substitute product exchange, refund, inspection, or issuing caution notices.
12. Prepare consumer announcements, retailer notifications, FAQs, customer service contact points, and return procedures.
13. Determine procedures for transport, storage, inspection, repair, disposal, re-export, or evidence preservation of recalled products.
14. Continuously manage numbers including target count, notified count, reception count, recall count, repair count, and unresolved count.
15. If progress stalls, add measures such as re-notification, direct contact with purchasers, and reseller re-notification.
16. Review accident causes, design, parts, manufacturing processes, inspections, labeling, and operation manuals.
17. Organize cost recovery from overseas manufacturers, insurance notifications, and contractual responsibility allocation.
18. Implement recurrence prevention measures and monitor accident information and unrecovered products even after the recall ends.

Identification of the affected range, sales suspension, serious product accident reporting, and urgent consumer notifications may need to proceed before the final conclusion of the cause investigation.

Risk Assessment of Recalls

Assessment Item	Details to Confirm	Examples of Higher Risk	Impact on Response
Severity of Harm	Assumed fatalities, serious injuries, fires, poisoning, electric shocks, etc.	May ignite during use and cause house fires	Immediate suspension of use and consideration of recall
Likelihood of Occurrence	Number of incidents, defect rate, reproduction tests, and structural causes	Breakage of the same component occurring across multiple lots	Necessity to expand the affected scope
User Attributes	Whether infants, elderly, or disabled persons use it	Risk of small parts being ingested by infants	Need for strong warnings and prompt direct communication
Recognizability of Danger	Whether consumers can detect abnormalities in advance	Internal heating without external abnormality	Danger reduction through warnings alone is difficult
Avoidability of Danger	Whether changes in usage can prevent accidents	Accidents occur even with normal use	Suspension of use and recall are more likely necessary
Frequency of Product Use	Whether it is used daily or continuously	Household appliances constantly connected to power	Little time margin before accident occurrence
Sales Volume	Domestic circulation, remaining market stock, and sales regions	Nationwide sales through multiple e-commerce channels	Wide-scale notification and large reception system required
Precision of Target Identification	Whether it can be limited by model, lot, or serial number	No lot records, unable to distinguish between safe and risky products	Recall of all models or a wide manufacturing period may be needed
Reliability of Countermeasures	Whether the risk can be eliminated by repair or replacement	Cause is not confirmed and effectiveness of replacement parts unknown	Consider more certain measures such as refunds or recalls

Differences Between Serious Product Accidents and Recalls

Item	Serious Product Accident	Recall	Practical Relationship
Main Nature	Statutory reporting and disclosure system for certain serious accidents	Specific measures to prevent occurrence or spread of accidents	Both need to be confirmed concurrently
Occurrence of Accident Required	Premised on the actual occurrence of a serious product accident	May be implemented if risk is identified even before an accident occurs	A recall may be necessary even without an accident
Primary Response	Organizing accident details, reporting to the Consumer Affairs Agency, and disclosure	Collection, repair, replacement, refund, inspection, warning, and sales suspension	Prevention measures are not completed by reporting alone
Main Deadline	Manufacturers or importers must report within 10 days including the day they become aware	No uniform start deadline; prompt judgement depending on risk severity	Reporting deadlines proceed separately even while recall is under consideration
Main Responsible Parties	Manufacturers or importers	Manufacturers, importers, and distributors share responsibilities	For imports, domestic importers often take the lead in response
Completion	Progressed through statutory reporting, investigation, and disclosure procedures	Continued verification of unrecovered items, accident recurrence, and remaining stock in market	Recall is not completed by announcement and disclosure alone

Even if a conclusive judgment on whether it qualifies as a serious product accident has not been made, it is necessary at the stage where it may potentially apply to verify the reporting deadlines and required documentation.

Reporting and Providing Accident Information

Information / Accident	Main Recipients / Consultation Contacts	Basic Role	Notes
Serious Product Accident	Consumer Affairs Agency	Statutory report by manufacturer or importer	Manage the deadline within 10 days including the day the accident became known
Non-Serious Product Accident	NITE	Provision of information under the Product Accident Information Collection System	Even for minor accidents, organize information if there is a risk of similar accidents
Consultation on Legal Violations / Applicable Products	Ministry of Economy, Trade and Industry or jurisdictional METI regional bureau, etc.	Administrative consultation related to product safety laws	Confirm applicable systems such as PSC, PSE, PSTG, PSLPG, etc.
Recall Information for Consumers	Consumer Affairs Agency Recall Information Website, etc.	Dissemination of recall information	Ensure consistency with announcements on company website, retailers, EC malls, etc.
EC Sold Products	Online Marketplace Providers	Listing suspension, contacting purchasers, product identification, etc.	Confirm submission formats and deadlines specific to each platform
Insurance Claims	Insurance companies for PL insurance, recall cost insurance, etc.	Accident notification and confirmation of coverage applicability	Confirm notification and approval requirements before incurring expenses

Roles of Importers and Import Sellers

In the recall of imported products, the importer or import seller who brings the product into Japan and sells it domestically may play a central role in managing the response within Japan.

• Identify the model, lot number, serial number, import date, and import quantity of the affected product
• Confirm the sales period, sales quantity, sales destinations, sales channels, and inventory quantity
• Verify the necessity of reporting serious product accidents and providing accident information to NITE
• Issue instructions for sales suspension, shipment suspension, inventory segregation, and advertising suspension
• Obtain from the overseas manufacturer the cause of the accident, affected lots, corrective parts, and replacement product information
• Prepare consumer notifications, FAQs, phone, email, and web inquiry desks
• Decide on the methods for recall, repair, replacement, refund, and inspection implementation
• Coordinate with retailers, e-commerce malls, warehouse operators, repair contractors, and logistics providers
• Manage storage, inspection, repair, disposal, re-export, and evidence preservation of recalled items
• Continuously manage recall progress, number of unrecovered products, accident recurrence, and consumer response
• Organize cost claims to overseas manufacturers, insurance notifications, and contractual liabilities
• Review supplier management, incoming inspections, labeling, instruction manuals, and quality assurance conditions

A risk for import sellers is the judgment that "since the overseas manufacturer will respond globally, it is sufficient for the Japanese side to wait."

Product models, sales channels, laws and regulations, labeling, and consumer response specific to products for Japan need to be individually confirmed by the Japanese side.

Role of Sellers and E-Commerce Businesses

• Extract sales history, order numbers, purchaser information, and sales channels for the affected products
• Halt in-store sales, e-commerce listings, advertisements, pre-orders, and new shipments
• Directly contact purchasers via email, app notifications, mail, phone calls, etc.
• Post warnings on storefronts, websites, product pages, and order history screens
• Provide guidance on returns, refunds, exchanges, repairs, and inquiries
• Isolate inventory of affected products to prevent incorrect shipments
• Notify import sellers of incident and complaint information received from consumers
• Cooperate with recall measures such as product collection
• Accurately identify model numbers and lots to avoid mistakenly halting non-affected products
• After the recall concludes, monitor outstanding purchasers and any relisting of products

While e-commerce sales allow direct contact using purchaser information, tracking all affected purchasers may be incomplete due to multiple accounts, reselling, and movement between marketplaces.

Role of Overseas Manufacturers

• Investigate causes of accidents, design issues, defective parts, and abnormalities in the manufacturing process
• Identify affected models, production lots, manufacturing periods, factories, and countries of shipment
• Disclose accident cases, complaints, recalls, and regulatory actions overseas
• Explain specification differences between products for Japan and those for other markets
• Provide countermeasure parts, repair procedures, substitutes, and technical documentation
• Cooperate in the analysis of defective and recalled products
• Verify issues with Japanese labeling, warnings, and user manuals
• Discuss responsibility for costs related to returns, repairs, replacements, and consumer response
• Notify the Japanese side of future product changes, part changes, and factory changes

Response delays may occur due to time zone differences, language barriers, governing law of contracts, cost allocation, and parts supply involving overseas manufacturers.

It is important to contractually establish, prior to the start of import sales, the contact points for accidents, reporting deadlines, cause investigation, provision of materials, cost bearing, and methods for recovery.

Points Freight Forwarders Should Confirm

Freight forwarders are generally not in the position to make a final decision on whether to recall a product.

However, they may be involved in domestic consolidation of recalled goods, overseas return shipments, export for repair, re-importation, disposal, transportation of hazardous materials, and ensuring safety during transit.

• Whether recalled goods will be consolidated in a domestic warehouse or returned to the overseas manufacturer
• Whether the recalled goods are new, used, defective, damaged, or involved in an accident
• Whether the goods contain or retain batteries, gases, liquids, chemicals, or other hazardous substances
• Whether there is any risk of re-ignition, heating, leakage of liquid or gas, or damage due to product defects
• Whether the same packaging and transportation methods as regular new cargo can be used
• Whether there are any transportation restrictions or prohibitions under air, sea, or land hazardous material regulations
• Whether the overseas return shipment qualifies as export of waste under applicable regulations
• Whether the invoice details for export for repair, return, or re-export are appropriate
• Whether emergency contact information and handling instructions are provided in case of accidents during transportation
• Whether notification to marine cargo insurance, liability insurance, or other insurance policies is necessary

Accident-damaged goods, defective batteries, used gas appliances, or liquid-leaking items may require transportation conditions different from regular new cargo.

Comparison of Freight Forwarder Involvement Scope

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

Category	Main Involvement in Recall Operations	Usual Points to Confirm	Decisions Generally Not Included
Simple Intermediary (単純取次)	Booking return transport, communication, and assistance with document exchange	Cargo condition, return destination, hazardous materials information, and required documents	Final decision on recall implementation or guarantee of product safety
Cargo Transportation Service Provider (貨物利用運送事業者)	Transport services for collected or replacement goods and arrangement of related parties	Transport conditions, packing, storage, hazardous material classification, and delivery schedule	Assumption of accident reporting or consumer response obligations as the importer/seller
NVOCC / House B/L Issuer	Undertakes ocean or multimodal transport as the carrier under contract	Cargo information, transport documentation, hazardous materials declaration, and return conditions	Liability for recall costs based solely on House B/L issuance
Door-to-Door Single Contractor	Integrated coordination from collection point to domestic warehouse, repair site, or overseas return location	Pickup, packing, storage, customs clearance, delivery, collection schedule, and safety conditions	Recall decisions, cause determination, or compensation decisions not included in the contract
Agent/Coordinator for Specific Operations (特定業務の代理・調整者)	Individual coordination of tasks such as collection consolidation, inspection, return, disposal, and repair export	Scope of delegation, work instructions, identification of target items, and completion records	Accident reporting, consumer notification, or sales suspension decisions not delegated

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

Responsibility cannot be determined solely by operation names such as collection, inspection, storage, repair, disposal, or re-export. Contracts, quotation terms, work instructions, transport clauses, and actual handling should be confirmed.

Points Customs Brokers Should Confirm

• Whether the recalled goods will be returned overseas or disposed of domestically
• Whether to treat the goods as returns, repair export, replacement, re-export, or disposal
• Whether the invoice includes the return reason, product condition, quantity, value, and intended use
• Whether there is a plan to re-import the goods to Japan after repair
• Whether the price and declaration method for free import of replacement goods have been confirmed
• Whether the handling of customs duties and consumption tax, drawback, or re-import procedures may cause issues
• Whether the recalled goods qualify as waste and require confirmation under the Act for the Control of Export and Import of Specified Hazardous and Other Wastes (the Basel Act) or other regulations
• Whether other laws related to batteries, gas, chemicals, food, medical devices, etc., apply
• Whether the import regulations or return acceptance conditions of the destination country have been confirmed
• Whether customs and transportation documents necessary for accident investigation, insurance claims, and indemnity have been retained

For customs clearance of recalled goods, simply stating "Return Goods" on the invoice may not sufficiently explain the transaction or the actual status of the cargo.

It is necessary to organize and declare the cause of the defect, purpose of the return, presence or absence of repairs, re-import plans, value, disposal method, and any hazards involved.

Items to Be Confirmed by Warehousing, Repair, and Disposal Operators

Operator	Main Role	Items to Confirm	Points of Caution
Warehouse Operator	Isolation and storage of recalled products and sales suspension inventory	Model number, lot number, quantity, storage section, and shipment prohibition settings	Prevent mixing with regular inventory, mistaken shipment, and fire spread from defective products
Inspection Operator	Identification, appearance check, and sorting of target products	Judgment criteria, work procedures, individual serial numbers, and inspection records	Do not confuse with the scope of delegated final safety judgment
Repair Operator	Free repair, parts replacement, and repair completion confirmation	Work qualifications, repair procedures, countermeasure parts, and repaired product identification	Confirm safety after repair and retain work history
Disposal Operator	Proper handling of recalled items, defective parts, and hazardous materials	Waste classification, disposal methods, manifests, and destruction certificates	Prevent redistribution, resale, information leakage, and improper disposal
Call Center	Consumer inquiries, reception, and guidance	FAQ, identity verification, target determination, and emergency guidance	Do not treat accident information as mere return requests

Importance of Sales Records and Lot Management

In recall handling, it is crucial to confirm which products were sold, when, where, and in what quantities.

Management Item	Main Details	Use During Recall	Impact if Incomplete
Product Name / Brand Name	Name used at the time of sale	Consumer notification and sales history search	Target products may be overlooked due to name discrepancies
Model / Item Number	Manufacturer model, own item number, SKU, etc.	Identification of target products	Potential recall of non-target products
Serial Number	Unique serial number for each unit	Determining the status of individual products	Cannot distinguish between safe and affected products
Lot Number	Manufacturing, import, or inspection unit	Identifying the causal lot and scope of impact	May expand to near-complete recall
JAN Code / Barcode	Sales and inventory management codes	Suspending listings at retailers and e-commerce platforms	Could result in suspension of unrelated products
Import Date / Import Quantity	Record based on import declaration units	Confirming domestic distribution volume and target period	Unable to estimate remaining domestic stock
Sale Date / Sale Quantity	Sales records to consumers or retailers	Contacting purchasers and calculating recall progress rate	Unable to determine the number of products to be recalled
Sales Destination / Sales Channel	Wholesalers, stores, e-commerce platforms, etc.	Notifications, sales suspension, and purchaser communication	Some channels may be missed in recall actions
Manufacturer / Manufacturing Factory	Overseas manufacturers and actual factories	Cause analysis and assessment of impact on other lots	Difficulty matching certificates and test data

Required Information for Recall Notices to Consumers

Notice Item	Content Description	Practical Considerations	Issues if Insufficient
Target Products	Product name, model number, serial number, lot number, sales period, and photos	Enable consumers to easily identify the product they have	Consumers cannot determine if their product is affected
Defects / Hazards	What occurs and what kind of accidents may result	Explain the specific risks clearly in addition to technical terms	The danger is not conveyed, leading to continued use
Urgent Measures	Usage suspension, power disconnection, isolation, etc.	Only instruct on methods that can be safely performed	Consumers keep and use the product in hazardous conditions
Response Methods	Recall, repair, replacement, refund, or inspection	Clarify conditions for selection and required documents	Confusion and complaints increase during reception
Application Method	Phone, website, email, retail store counters, etc.	Specify reception hours, supported languages, and how to handle congestion	Consumers are unable to make contact
Return Method	Packing, pickup, freight charges, and caution for hazardous materials	Do not let consumers send hazardous items by regular mail or similar	Accidents occur during return shipping
Personal Information	Purpose of collection, scope of use, and storage method	Collect only the information necessary for recall processing	Issues arise in personal information management
Update Information	Additional affected items, changes in response, reception status, etc.	Synchronize company website with retailer and government information	Outdated information remains, causing inconsistent responses

Points to Confirm for Transportation and Storage of Recalled Products

Item to Confirm	Main Content	Risks	Measures
Product Condition	Unused, used, damaged, accident occurred, etc.	Hazards different from those when new	Declare condition individually and determine transport requirements
Batteries	Built-in or included batteries, swelling, heat generation, damage, etc.	Short circuit, fire, thermal runaway	Check dangerous goods regulations and carrier’s acceptance conditions
Gas / Fuel	Gas containers, fuel tanks, residual gas, etc.	Gas leakage, explosion, fire	Confirm treatment of residues and dangerous goods declaration
Liquids / Chemicals	Leakage, corrosiveness, flammability, toxicity, etc.	Contamination, corrosion, health hazards	Check absorbents, secondary containers, labels, and SDS
Evidence Preservation of Accident Products	Burn damage, breakage, missing parts, etc.	Loss of condition necessary for cause investigation	Store separately without cleaning, disassembly, or disposal
Inventory Isolation	Separation from sellable stock	Mis-shipment, resale	Prohibit shipment both in system and physical segregation
Long-Term Storage	Increase in quantity stored depending on recall progress	Insufficient storage capacity, accidents, increased costs	Establish processing plan, storage limits, and emergency response

Customs Clearance Procedures for Returns, Repairs, and Re-imports

Processing Method	Main Purpose	Customs Confirmation	Practical Notes
Return to Overseas Manufacturer	Contract cancellation, return of defective goods	Reason for return, declared value, original import record, and acceptance by destination country	Check separately for regulations on hazardous goods or waste
Repair Export	Repair or parts replacement at overseas factory	Purpose of repair, planned re-import, serial number, and declared value	Keep records to verify identity upon re-import
Free Import of Countermeasure Items	Supply of replacements or spare parts	Confirm appropriate declared value and usage even if free of charge	Do not declare value as zero based solely on free supply
Domestic Disposal	Prevent re-circulation and eliminate hazards	Waste classification, disposal contractor, and certification documents	Prevent re-circulation of branded goods, personal data devices, etc.
Overseas Disposal	Disposal in country of manufacture or others	Waste export controls under the Basel Act and destination-country regulations	Avoid disguising waste export as product return
Export for Accident Investigation	Analysis by overseas manufacturer or testing agency	Confirm accident status, export purpose, and planned return	Retain seals on evidence, photographs, and handover records

Relationship with Marine Cargo Insurance, Product Liability Insurance, and Recall Expense Insurance

Insurance / Contract	Main Coverage	Relation to Recall Expenses	Points to Confirm
Marine Cargo Insurance	Accidental physical damage during transportation	Post-sale product defects and normal recall expenses are generally not covered	Confirm cause of incident, insurance period, physical damage, and expenses clause
Product Liability (PL) Insurance	Liability for third-party bodily injury and property damage caused by product accidents	Costs for recall, replacement, refund, etc., may be treated separately from standard PL coverage	Check covered incidents, deductibles, incident notification requirements, and litigation expenses
Recall Expense Insurance	Costs related to recall, notification, disposal, call centers, etc., as defined in the contract	Coverage content, activation conditions, and applicable regions vary by contract	Confirm voluntary recalls, administrative orders, defect causes, and self-payment amounts
Freight Forwarder Liability Insurance	Liability for freight forwarder’s operational negligence	Recall costs due to defects in the product itself are usually a separate issue	Verify presence or absence of operational negligence such as mis-shipment, mis-delivery, or storage accidents
Sales Contract with Overseas Manufacturer	Contract non-conformity, warranties, compensation, and recourse claims	Costs may sometimes be claimed from the manufacturer without involving insurance	Confirm governing law, warranty clauses, cost bearing, liability limits, and evidence

If the insurance contract is checked only after the recall has started, notification deadlines, prior approval, covered expense items, or applicable regions may not be met.

Once incident information is identified, early contact with the insurer or insurance agent is necessary to confirm coverage availability and procedures for expense payment.

Main Cases Requiring Recalls After Customs Clearance and Sales

Case	Main Cause	Key Judgment Points	Initial Response	Subsequent Actions
Received accident notification from overseas manufacturer for the same lot	Incidents such as ignition or breakage occurred overseas	Whether specifications, parts, and manufacturing factory are identical to Japan’s sales products	Halt sales, isolate inventory, verify domestic sales history	Define the affected scope, contact purchasers, and conduct recall
Ignition or smoke incident occurred domestically	Design, parts, usage conditions, etc.	Whether it qualifies as a serious product accident and the likelihood of recurrence	Stop use, preserve accident items, confirm report to Consumer Affairs Agency	Decide recall method concurrently with cause investigation
Multiple complaints of the same type have arisen	Possibility of structural defects or lot quality issues	Number of cases, occurrence rate, damage, and commonalities	Stop shipments, investigate all channels	Consider inspection, repair, or replacement
Deficiencies found in PS mark or other labeling	Legal judgment, inspection, or labeling errors	Simple labeling omission or accompanied by safety standard non-compliance	Stop sales, consult with authorities	Determine feasibility of correction and scope of recall for already sold products
Insufficient warning labels or user manuals identified	Incomplete Japan-specific information	Possibility of serious accidents caused by misuse	Stop sales, issue urgent safety warnings	Judge whether replacement of manuals suffices or product recall is necessary
Manufacturer changed parts without authorization	Deficiencies in change management	Whether parts are safety-critical and impact on testing or certification scope	Stop shipment of the affected lot	Conduct additional testing, define scope, and decide on recall
EC mall pointed out insufficient safety documentation	Deficiencies in notifications, inspections, certificates, or labeling documentation	Whether it is only document insufficiency or involves substantive legal violations	Stop listings, preserve documents	Reconfirm compliance including other sales channels
Unable to identify the affected lot	Insufficient sales, inventory, and manufacturing records	Whether there is objective evidence to distinguish safe from hazardous products	Stop sales and issue warnings over a broad scope	Consider measures close to a full recall

Relation to Administrative Measures and Penalties

If the response to a recall is insufficient, issues may arise related to accident information reporting, administrative investigations, legal violations, Hazard Prevention Orders, and other preventive measures.

Measure	Main Situations	Impact on Business Operators	Practical Response
Request for Reports	When confirmation of accidents, products, sales status, or recurrence prevention measures is necessary	Reports regarding manufacturing, importing, sales, accidents, and responses may be requested	Do not alter records; organize factual information in chronological order
On-site Inspection	When products or records need to be checked at business offices, warehouses, stores, etc.	Books, products, inspection records, inventory, and equipment will be subject to inspection	Clearly identify the location of materials and the responsible person for management
Hazard Prevention Order	When serious harm has occurred or there is an imminent danger of occurrence	Manufacturers and importers may be ordered to conduct recalls or other hazard-prevention measures	Comply with the target products, order details, and deadlines; manage implementation status
Cooperation of Sales Operators	When manufacturers or importers receiving Hazard Prevention Orders conduct recalls, etc.	Sales operators are required to cooperate with recall or related measures	Provide purchaser information, inventory, sales history, and notification methods
Sales and Labeling Measures under Specific Laws	When there are violations of standards or labeling under PSC, PSE, PSTG, PSLPG, etc.	Sales suspension, labeling prohibition, and improvement orders may be issued	Confirm the applicable model and violation details under each relevant law
Publication of Accident and Violation Information	When consumer warnings or administrative measures are necessary	May lead to loss of trust, suspension of transactions, and suspension of e-commerce listings	Standardize facts, affected products, contact points, and response details
Criminal Penalties	If Hazard Prevention Orders or related requirements are violated	Depending on violation type, imprisonment, fines, or both may be imposed	Consult specialists immediately, prioritize order compliance and evidence preservation

Violations of Hazard Prevention Orders under the Consumer Product Safety Act may result in imprisonment of up to one year, a fine of up to 1 million yen, or both.

Legal measures corresponding to the type of violation are also established for obligations such as reporting serious product accidents, Request for Reports, on-site inspections, and other duties.

Recall Progress Management

Management Indicator	Description	Purpose of Confirmation	Response to Stagnation
Number of Units Involved	Total number of units subject to recall within Japan	Basis for scale of response	Reconcile import, sales, and inventory records
Number Reachable	Number directly contactable via purchaser information, etc.	Feasibility of direct notification	Review data coordination with retailers and e-commerce platforms
Number Contacted	Number contacted via email, mail, phone, etc.	Status of notification implementation	Re-notify unreachable recipients by alternative means
Number of Applications Received	Number of requests for recall, repair, etc.	Confirmation of consumer response	Review notification content, application methods, and reception capacity
Number Recalled/Repaired	Number of units successfully recalled, repaired, replaced, or refunded	Achievement in hazard removal	Enhance collection, repair part availability, and substitute product capacity
Number Pending Response	Estimated number remaining in market or with consumers	Understanding of residual risk	Consider re-notification, individual visits, and retailer re-notification
Number of Incident Recurrences	Incidents or complaints occurring after recall initiation	Urgency and effectiveness of countermeasures	Strengthen use cessation advisories and notification methods
Market Retention Rate	Estimated remaining units accounting for disposal and replacement	Evaluation of long-term recalls	Clarify estimation basis and manage separately from execution rate

The conclusion of a recall is not determined solely by the passage of a certain period.

It should be assessed considering the remaining status of the target products, hazards, recall/repair achievements, incident recurrences, product lifespan, and effectiveness of notifications.

Specific Example 1: In Case of a Fire Incident Involving an Imported Mobile Battery

Suppose a mobile battery sold by an importer-seller on an online marketplace catches fire, damaging surrounding furniture.

The importer-seller checks the model, serial number, lot number, usage status, charger, and fire damage of the faulty product, and preserves the product without disposing of it.

Since this could be classified as a serious product incident involving fire, the importer-seller should verify the Consumer Affairs Agency report within 10 days from when they became aware of the incident. Even before the investigation's final conclusion, they stop listing, shipping, and advertising the same model.

The importer-seller contacts the overseas manufacturer to inquire about incident information related to the same battery cell, protection circuit, and factory, and identifies the domestic sales lots involved.

If the possibility of structural recurrence cannot be ruled out, the importer-seller immediately instructs consumers to stop using the product, arranges a safe method for collection, and does not require consumers to return the product voluntarily by regular parcel delivery.

The importer-seller continuously monitors the collection rate, number of unreturned units, and incidents occurring after the recall begins, and if progress stalls, they may conduct re-notifications using purchase history data from the online marketplace.

Example 2: Handle Breakage Found in Imported Electric Kettles

Suppose multiple complaints arise concerning overseas-manufactured electric kettles, reporting that the handle detaches during use, risking scalding from boiling water spillage.

Even if no serious injuries have been confirmed at this point, there is a risk of burns from hot water, and similar products using the same attachment parts may experience recurrence.

The importer and distributor will compare the lot numbers, manufacturing periods, specifications of screws and resin parts, and assembly processes of the complaint products, and will suspend sales and shipments.

If the overseas manufacturer’s investigation reveals insufficient strength in the fastened parts, the affected lots will be recalled, and free exchanges with corrected products or refunds will be provided.

If sales records for the affected products are adequate, direct contact with purchasers is possible. If records are insufficient, it will be necessary to raise awareness through a combination of in-store postings, website notifications, newspapers, and social media.

Example 3: When Receiving a Defect Notification for Gas Appliances from an Overseas Manufacturer

Suppose you receive a notification from an overseas manufacturer that a specific model of gas appliance has a defect in the combustion control component, which may cause carbon monoxide generation.

Even if the Japanese-bound products have the same model number, differences in gas type, nozzle, control circuit board, or manufacturing plant may exist, so the identity between the overseas affected products and the products sold in Japan should be confirmed.

If the same hazards could apply to products sold in Japan, a sales suspension and safety advisory to stop use should be issued, even if no accidents have occurred domestically.

If the product is fixed installed and return by consumers is not appropriate, on-site inspections and part replacements should be carried out.

The installation locations, model numbers, serial numbers, inspection dates, and completion of repairs for the affected products should be individually managed, and contacts should be repeated toward locations where repairs remain incomplete.

Specific Example 4: When the Target Lot Cannot Be Identified for Children's Toys

Consider imported children's toys from which small parts may detach, presenting a risk of accidental ingestion by infants.

The importer and seller received an explanation from the overseas factory that the adhesive was changed only during a certain production period. However, since the products have no lot numbers and it is impossible to distinguish before-and-after changes from warehouse and sales records,

it becomes difficult to restrict the recall scope solely to the problematic production period because there is no objective way to separate safe products from hazardous ones.

Consequently, it may be necessary to expand the recall scope to cover the entire sales period or all affected models, accompanied by instructions to stop using the product and refund customers.

In this case, lot marking on products, linking import lots with sales history, and managing manufacturing changes will directly impact the recall cost and the recall scope.

Common Misconceptions

Misconception	Actual Perspective	Practical Points to Note
Recalls are unnecessary if no serious accidents occur	Recalls may be required as soon as a risk of accident is identified	Evaluate not only the number of incidents but also the severity of harm and recurrence possibility
The overseas manufacturer will handle it, so the Japanese importer does not need to respond	The importer may often take the lead in responding to consumers, authorities, and retailers in Japan	Prepare a domestic contact point, recall method, and cost burden arrangements
Posting a notice on the website completes the recall process	Post-notice, it is necessary to manage recovery/refurbishment rates, unreturned products, and recurrence of accidents	Continue direct communication and re-notification to purchasers
Recall and serious product incident reporting are the same procedures	Serious product incident reports are legally mandated; recall measures are damage prevention steps	Manage reporting deadlines and recall decisions in parallel
Self-initiated recalls require no administrative confirmation	Obligations for statutory incident reporting and separate laws should be individually confirmed	Consider early consultation with the relevant administrative authorities
Stopping retailer inventory is sufficient	Products held by consumers, warehouse stock, e-commerce listings, and advertisements are also subject to recall	Stop all sales channels simultaneously
It is adequate to recall only a part even if the target lots are unknown	If safe and unsafe products cannot be distinguished, the recall scope may broaden	Carefully determine limits when objective lot evidence is lacking
Returned products can be shipped back using normal methods for new goods	Accident items, defective batteries, gas appliances, etc., may be subject to transport restrictions	Confirm hazardous goods status, packaging, and carrier conditions
Writing "return" allows free return shipment overseas	Waste, hazardous goods, destination country regulations, and customs clearance purposes must be confirmed	Accurately declare the cargo’s status and purpose of return
All recall costs are covered by marine cargo insurance	Cargo insurance usually focuses on physical damage during transportation	Separately confirm PL insurance, recall cost insurance, and purchase agreements
No record is needed if repaired products are returned	Records of repair details, corrective parts, work dates, and individual identification are necessary	Prevent repeat incidents and duplicate processing of repaired items
Non-compliance with Hazard Prevention Orders results only in administrative guidance	Violation of orders can lead to criminal penalties	Strictly manage order details and deadlines

Decision Checklist

Confirmation Stage	Contact Party	Check Items	Actions if Issues Arise
Before Sales Launch	Overseas Manufacturer, Quality Control Personnel	Lot number labeling, accident contact, warranty, recall and cost responsibility	Do not start sales until a tracking and accident response system is established
At Accident or Complaint Reception	Consumer, Retailer, Repair Shop	Product, accident circumstances, damage, usage method, and location of the item	Advise cessation of use and preserve evidence
When Inspecting Accident Product	Technical Staff, Overseas Manufacturer	Model, serial number, lot number, parts, and damage status	Do not disassemble or discard the accident product; forward to cause investigation
When Judging Severity	Legal Personnel, Government Contact Point, Experts	Relevance to death, serious injury, fire, carbon monoxide poisoning, etc.	Manage reporting to the Consumer Affairs Agency within 10 days
When Deciding Sales Suspension	Management, Quality Control, Sales Department	Risk, likelihood of recurrence, sales volume, and scope	Halt listing, shipping, and advertising in all sales channels
When Determining Scope	Manufacturer, Inventory and Sales Management Personnel	Model, lot, manufacturing period, import date, and sales period	Do not easily limit the scope if identification is impossible
When Deciding Recall Method	Technical, Legal, Customer Service, Logistics Personnel	Collection, repair, replacement, refund, inspection, and caution notices	Select a method that reliably removes the hazard
When Preparing Announcements	Public Relations, Legal, Call Center	Scope, risk, usage suspension, reception, and return procedures	Unify content across government, retailers, and e-commerce platforms
During Recall Transport	Freight Forwarder, Carrier, Warehouse	Product condition, hazardous goods, packaging, storage, and emergency contacts	Do not accept or ship as normal cargo without conditions
When Returning Overseas	Customs Broker, Overseas Manufacturer	Return, repair, disposal, value, re-import, and destination country regulations	Ensure invoice matches actual cargo
When Confirming Insurance	Insurance Company, Insurance Agent	Accident notification, eligible costs, prior approval, and deductibles	Confirm coverage terms before incurring expenses
During Progress Management	Retailers, E-commerce Platforms, Call Center, Warehouse	Number of targets, contacts, collections, repairs, and unresolved cases	If progress stalls, add re-announcements or direct contact
When Accidents Recur	Consumers, Government, Manufacturer	Whether recall applies, announcement reach, and effectiveness of measures	Strengthen use suspension advisories and recall methods
When Deciding to Close	Management, Quality Control, Legal	Remaining market stock, collection rate, recurrence, and product lifespan	Do not close solely based on elapsed time
When Preventing Recurrence	Manufacturer, Procurement, Quality Control, Sales Department	Design, parts, inspection, labeling, contracts, and record management	Reflect corrective actions in future procurement and sales terms

Situations Requiring Consultation with Experts

• If it is unclear whether the case qualifies as a serious product accident
• If the reporting deadline of 10 days is approaching
• If fire, death, serious injury, carbon monoxide poisoning, or similar incidents occur
• If similar accidents continue without identifying the cause
• If the affected lot cannot be identified, making it impossible to define the recall scope
• If the overseas manufacturer does not disclose accident information or production records
• If violations of laws such as PSC, PSE, PSTG, PSLPG, etc., are discovered
• If contacted by authorities regarding Request for Reports, on-site inspections, or Hazard Prevention Orders
• If returning accident-related products, defective batteries, gas equipment, or chemicals overseas
• If the recalled items may be classified as waste
• If compensation, refunds, or settlements are required for many consumers
• If considering cost recovery or litigation against the overseas manufacturer
• If verifying coverage under PL insurance or recall cost insurance
• If recall progress is stalled and risks of accidents remain

Potential consultation contacts include the Consumer Affairs Agency, Ministry of Economy, Trade and Industry or its regional bureaus, NITE (National Institute of Technology and Evaluation), relevant product regulatory agencies, lawyers knowledgeable in product safety, testing and inspection agencies, insurance companies or insurance agents, and logistics providers experienced in hazardous materials transportation.

Summary

Recall of imported products refers to actions taken when safety defects, faults, or potential accident risks are identified in imported and sold products. These actions may include retrieval, free repair, parts replacement, provision of alternatives, refunds, inspections, advisories, requests to stop usage, or sales suspension.

Recalls are implemented not only after serious accidents occur but also when risks are identified before any incident takes place.

Serious product accidents and recalls are distinct systems. Serious product accidents involve statutory accident reporting and disclosure requirements, while recalls are specific measures to prevent the occurrence and spread of accidents.

When manufacturers or importers become aware of a serious product accident, they must report it to the Consumer Affairs Agency within 10 days, including the day they learned of the accident. Even if cause investigations or recall decisions require more time, the reporting deadline must be managed separately.

For imported products, the domestic importer or distributor in Japan may coordinate responses with consumers, retailers, e-commerce platforms, administrative authorities, overseas manufacturers, logistics providers, and insurance companies.

In recall management, it is essential to be able to trace the model, lot, import quantity, sales volume, and sales destinations of the affected products. Insufficient records may prevent distinguishing between safe and hazardous products, potentially expanding the scope of retrieval significantly.

Retailers and e-commerce businesses cooperate with sales suspension, buyer notification, inventory segregation, and product retrieval. Overseas manufacturers need to provide information on cause analysis, affected lots, technical data, corrective parts, and cost responsibilities.

Freight forwarders and customs brokers are usually not responsible for the final recall decisions but are involved in domestic consolidation of recalled goods, hazardous material transport, export for repair, re-import, overseas return, and disposal.

Accident-related products, defective batteries, gas appliances, leaking items, or used products may not be transportable under the same conditions as normal new cargo. Transport regulations, packaging, waste disposal rules, and import conditions of the destination country must be confirmed.

Cargo insurance generally covers accidental physical damage during transport and does not automatically cover recall costs incurred after sales. Product liability insurance, recall cost insurance, and contractual indemnity clauses with overseas manufacturers should be separately checked.

Failure to comply with Hazard Prevention Orders may result in criminal penalties. Even in voluntary recalls, it is necessary to verify the need for reporting serious product accidents, compliance with product safety laws, administrative consultations, and accident information disclosure.

A recall is not complete simply by making a public announcement. Continuous management of target quantities, contact numbers, retrieval numbers, repair counts, unresolved cases, residual market rate, and recurrence of accidents is fundamental. Additional notifications and retrieval measures should be taken if risks remain.

This article aims to provide a general overview of recalls for imported products and related import sales operations. It does not determine legal obligations, recall requirements, liability for compensation, or insurance applicability in specific incidents. Actual cases require confirmation of the latest laws, official documents, product specifications, accident circumstances, contracts, and relevant administrative authorities.