Imported Goods and Product Safety Commitment
Interlink編集部Imported Products and Japan's Product Safety Pledge
The Imports and Product Safety Pledge refers to Japan’s version of the “Product Safety Pledge” initiative and the practical import and sales procedures involved when selling products manufactured overseas to Japanese consumers via online marketplaces.
The Japan version of the “Product Safety Pledge” is a voluntary public-private collaboration aimed at protecting consumers from risks to life and body caused by recalled or unsafe products listed and sold on online marketplaces.
In Japan, it was formulated by relevant ministries and major online marketplace operators based on the OECD's “Communiqué on Product Safety Pledges” and launched on June 29, 2023.
The Product Safety Pledge is not established by law, Cabinet Order, or ministerial ordinance.
It provides a framework to prevent the continued circulation of recalled products, products not meeting safety standards, and dangerous products on online marketplaces, separate from obligations under laws such as the Consumer Product Safety Act, Electrical Appliance and Material Safety Act, Gas Business Act, laws relating to Liquefied Petroleum Gas, and other product safety regulations.
Import sellers and sellers must not assume that compliance with Japanese product safety laws has been confirmed simply because they have been able to list products on an online marketplace.
Even if customs clearance is complete, if required notifications, technical standards compliance, inspections, labeling, or product safety documentation cannot be confirmed, measures such as suspension of listings, deletion of product pages, contacting purchasers, returns, refunds, or recalls may be necessary.
Scope Covered in This Article
| Article / System | Main Role | Relation to This Article |
|---|---|---|
| Imported Products and Japan's Product Safety Pledge | Preventing distribution of hazardous, recalled, and non-compliant products on online marketplaces | Focuses on product delisting, document submission, purchaser notifications, and actions by import sellers |
| Imported Goods and the Consumer Product Safety Act | Overview from pre-sale regulation to post-sale measures for consumer products | Deals broadly with product safety laws and regulations |
| PSC Mark on Imported Goods | Technical standards, inspection, and labeling for specified products, specially specified products, and specially specified products for children | Details pre-sale regulations for PSC-target products |
| PSE Mark on Imported Goods | Business notification, technical conformity, inspection, record keeping, and labeling for electrical appliances | Detailed confirmation for electrical products and related power supplies |
| Serious Product Accidents Involving Imported Goods | Definition of serious accidents including death, serious injury or illness, carbon monoxide poisoning, and fire | Details criteria for serious product accidents |
| Imported Goods Product Accident Information Reporting System | Obligation to report serious product accidents, reporting deadlines, and initial response | Details statutory reporting requirements after occurrence of accidents |
| Recalls of Imported Goods | Measures including recall, free repair, replacement, refund, inspection, warnings, and sales suspension | Details harm prevention measures for products already in the market |
This article clarifies that the Product Safety Pledge is not itself law, and organizes what import sellers are required to verify on online marketplaces and what measures they may face when problems arise.
Positioning of the Product Safety Pledge
The Japanese version of the "Product Safety Pledge" is a voluntary framework designed to prevent the continued sale of recalled or unsafe products on online marketplaces.
On online sales platforms, numerous businesses and individuals, both domestic and international, can list many products within a short period.
As a result, there is a risk that recalled products, those lacking required marks such as the PSC mark or PSE mark, products not conforming to Japanese safety standards, or products that may cause serious accidents could be widely distributed.
Online marketplace operators that have signed the Product Safety Pledge take measures based on notifications from government agencies, reports from consumers, their own monitoring, and other information. These measures include removing listings of hazardous products, preventing relisting, notifying sellers, providing information to purchasers, and establishing internal management systems.
Scope of Product Safety Pledge and Signing Businesses
The Product Safety Pledge applies not only to large-scale BtoC-type businesses such as internet malls but also to CtoC-type businesses like online flea markets and internet auctions.
| Sales Format | Main Characteristics | Product Safety Issues | Items to Confirm |
|---|---|---|---|
| BtoC-type Online Marketplace | Businesses sell products directly to general consumers | Responsibility relationships among importer, seller, brand owner, and manufacturer | Confirm seller information, registered businesses, product safety data, and sales history |
| CtoC-type Online Marketplace | Individuals buy and sell new or used items among themselves | Recirculation of recalled products, outdated products, and products with insufficient labeling | Confirm product model, recall information, usage history, and labeling |
| Cross-border Online Marketplace | Overseas businesses sell directly to Japanese consumers | Legal compliance when there is no domestic importer | Confirm Specified Import Business Operators, Domestic Responsible Persons, notifications, and accident-response systems |
| Own EC Site | Import sellers manage product pages and payment internally | May lack involvement of businesses that have signed the Product Safety Pledge | Establish internal systems for legal checks, monitoring, purchaser notifications, and recall management |
The main party responsible for initiatives under the Product Safety Pledge is the online marketplace operator that has signed the pledge.
The Product Safety Pledge initiatives are not uniformly applied to all online sales services.
However, even in cases where sales occur on platforms that have not signed the pledge or on own EC sites, obligations under the Consumer Product Safety Act, Electrical Appliance and Material Safety Act, and other laws are not exempted.
Since participating online marketplace operators may be added or changed, the latest list of participating operators should be confirmed on the official website of the Consumer Affairs Agency.
Differences Between Legal Regulations and Product Safety Pledge
| Item | Legal Regulations | Product Safety Pledge | Implications for Import Sellers |
|---|---|---|---|
| Nature | Obligations based on laws, government ordinances, and ministerial orders | Voluntary public-private initiative by government ministries and signed business operators | Both should be confirmed separately |
| Main Subjects | Manufacturers, importers, sellers, and overseas businesses | Signed online marketplace operators | Sellers must comply with both the law and marketplace regulations |
| Core Content | Notification, conformity to technical standards, inspection, labeling, accident reporting, and recalls | Removal of listings, response to reports, prevention of relisting, internal management, and information sharing | Prepare to submit legal compliance documents to the marketplace |
| When Issues Occur | Sales restrictions, administrative orders, information requests, on-site inspections, and penalties | Product page removal, suspension of listings, document submission requests, and account-level measures | Handle administrative responses and platform actions concurrently |
| Direct Enforceability | Enforceable administratively or criminally under law | The pledge itself is not a law | Penalties based solely on pledge violations do not apply; measures are mainly based on marketplace regulations |
| Relation to Sales Permission | Sales may be prohibited if legal compliance is not met | Listings may be disallowed based on the marketplace’s safety judgment | Differentiate customs clearance, legal compliance, and possibility of listing |
The product safety pledge does not exempt or substitute legal obligations.
For products requiring PSE Mark, PSC Mark, PSTG Mark, or PSLPG Mark, separate confirmation of the required notifications, conformity to technical standards, inspection, labeling, and record retention under each applicable law is necessary.
Major Initiatives by Online Marketplaces
| Initiative | Main Content | Impact on Sellers | Practical Preparations |
|---|---|---|---|
| Removal of Listings for Recalled Products | Cross-check recall information provided by government agencies with product listings | Suspension of sales or removal of product pages for affected items | Link model number, serial number, and lot number with sales records |
| Removal of Listings for Products Violating Laws | Verify products that violate safety standards or labeling requirements | Requests for submission of compliance documents or suspension of sales | Keep documentation of notifications, inspections, certificates, and product labeling |
| Response to Reports from Consumers, etc. | Accept information related to hazardous or recalled products | Inquiries to sellers and temporary suspension of product pages | Assign contact persons and establish response deadlines |
| Prevention of Relisting | Prevent the relisting of removed products under the same or different accounts | Restrictions on identical models, similar products, or accounts | Avoid relisting by only changing product names without resolving the root cause |
| Notifying Sellers | Provide information about product safety laws, prohibited items, and required documents | Requests for additional documents or corrections to product listings | Review the latest terms and product safety rules of each marketplace |
| Providing Information to Buyers | Communicate risk information, usage discontinuation, or recall notices to buyers as needed | Cooperate with buyer contact, returns, refunds, and product recalls | Retain sales history and buyer information |
| Establishing Internal Management Systems | Continuously manage government notices, consumer reports, listing removals, and prevention of relisting | Listing reviews and document verification may be strengthened | Ensure accuracy and consistency of submitted documents |
Main Actions for Import Sellers and Sellers
- Confirm whether the imported products are subject to Japanese product safety laws and regulations.
- Check the necessity of PSC, PSE, PSTG, PSLPG, technical conformity marks, and similar requirements.
- Confirm that the product or the same model is not subject to a recall.
- Do not judge legality based solely on overseas manufacturers' or overseas EC sites' product descriptions.
- Keep submission documents, technical data, inspection data, certificates, inspection records, and instruction manuals.
- Ensure images, model numbers, specifications, labels, and actual products match on product pages.
- Be prepared to respond promptly if an online marketplace requests document submission.
- Be able to trace suppliers, manufacturers, production factories, lot numbers, sales quantities, and purchasers.
- After starting sales, continue monitoring recall information, accident reports, and notifications from marketplaces.
- Establish a system to contact purchasers, issue usage stop notices, and handle returns, refunds, repairs, exchanges, and product recalls.
Listing products on an online marketplace does not mean that compliance with product safety laws and regulations has been guaranteed by administrative authorities or the platform.
Importer Seller Confirmation Flow
- Confirm whether the product is intended for sale to general consumers within Japan.
- Verify the product’s usage, structure, target age, power supply, communication functionality, and accessories.
- Check if the product falls under the Consumer Product Safety Act, Electrical Appliance and Material Safety Act, Gas Business Act, regulations related to liquefied petroleum gas, Radio Act, or other applicable laws.
- Confirm the necessity of PSC, PSE, PSTG, PSLPG, Technical Conformity Mark (Giteki Mark), and other required markings, certifications, or notifications.
- Obtain specifications, test data, certificates, parts lists, and user manuals from the overseas manufacturer.
- Create Japanese-compliant labels, warnings, user manuals, and product pages.
- Verify that the product name, model number, lot, and manufacturing factory match the submitted documentation.
- Check domestic and international recall information and incident reports.
- Confirm whether the planned online marketplace requires signing the Product Safety Pledge.
- Review the online marketplace’s listing terms, prohibited product lists, and rules for submitting product safety documents.
- Confirm consistency among the product page descriptions, images, model numbers, labels, and actual products.
- Establish a system to track sales volume, inventory, sales destinations, and purchaser information.
- Set up procedures for receiving incident reports, issuing usage cessation notices, halting sales, and handling recalls.
- After sales commence, continuously monitor government publications, recall information, incident reports, and marketplace notifications.
- If any problems are identified, suspend new sales, shipments, advertising, and relisting of the product.
Main Process of Product Delisting and Sales Suspension
| Stage | Main Event | Impact on Seller | Required Response |
|---|---|---|---|
| Issue Detection | The target product is identified through government notifications, recall information, consumer reports, or internal monitoring | An investigation into the affected products is initiated | Verify model numbers, lot numbers, listing information, and sales records |
| Initial Inquiry | The platform requests documents or explanations from the seller | A response deadline may be set | Submit official filings, inspection records, and actual product photos rather than guesses |
| Temporary Suspension | The product page is suspended until safety or compliance is confirmed | New orders, advertisements, and search listings are halted | Stop shipping inventory and confirm the scope of affected products |
| Delisting / Sales Suspension | The product is identified as subject to recall, legal violation, or significant lack of documentation | Product pages are deleted, sales suspended, or account measures taken | Identify sold products and unshipped orders |
| Customer Response | Depending on the risk level, instruct to stop use, return, refund, or recall the product | There may be an influx of customer inquiries | Prepare standardized guidance documents, reception points, and recall procedures |
| Prevention of Relisting | Monitoring for relisting of the same or similar products | Sales of identical accounts or related products may be restricted | Do not relist until the cause and legal issues have been resolved |
Import sellers may face burdens beyond sales suspension, including inventory backlog, returns, refunds, customer communication, advertising suspension, account restrictions, and explanations to business partners.
Products Prone to Being Subject
| Product Group | Main Issues | Relevant Regulations | Reference Documents |
|---|---|---|---|
| Products Subject to Recall | Products with known hazards being redistributed | Recall, Product Safety Pledge | Model, serial number, recall scope |
| Mobile Batteries / Lithium-Ion Storage Batteries | Fire risk, abnormal heating, lack of labeling and inspection records | Electrical Appliances and Materials Safety Act, PSE Mark | Test data, inspection records, labeling photos, and import records |
| AC Adapters / Chargers | Checking only the main unit and overlooking included power accessories | Electrical Appliances and Materials Safety Act, PSE Mark | Certification of conformity inspection, model, and manufacturing factory |
| Toys and Infant Products for Children | Lack of target age, warnings, small parts, PSC markings, etc. | Consumer Product Safety Act, Child PSC Mark | Target age documentation, test reports, and labeling |
| Lighters / Laser Products | Failure to confirm classification as specially specified products | Consumer Product Safety Act, Diamond PSC Mark | Specifications, certification of conformity inspection, and inspection records |
| Gas Appliances / LP Gas Appliances | Mismatch in gas type, connection method, technical standards, and labeling | Gas Business Act, Regulations concerning Liquefied Petroleum Gas | Model, gas type, inspection records, PSTG/PSLPG markings |
| Products with Wireless / Communication Functions | Only confirming product safety labeling and overlooking radio regulations | Radio Law, Telecommunications Business Act | Technical conformity number, communication specifications, and certification data |
| Products Certified Only Overseas | Misunderstanding CE, UL, and other foreign standards as compliance with Japanese law | Various product safety laws and regulations | Differences from Japanese standards, additional tests, and domestic labeling |
Points Freight Forwarders Should Confirm
Freight forwarders are not the parties responsible for signing the product safety pledge or deciding on the removal of listings from online marketplaces.
Nor do they generally have the position to guarantee the legal compliance of imported products.
However, in practice, it is effective for freight forwarders to encourage the cargo owner to check product safety regulations and the risk of sales suspension for goods intended for sale on online marketplaces within Japan.
- Whether the cargo is planned to be sold on an online marketplace within Japan
- Whether the products fall under electrical appliances for general consumers, children’s products, gas appliances, or household goods
- Whether the importer has confirmed compliance with PSE, PSC, PSTG, PSLPG, Technical Conformity Mark (Giteki Mark), and similar certifications
- Whether the products are not subject to recalls or publicly disclosed serious incident information
- Whether they can respond if the marketplace requests submission of product safety documents
- If sold immediately after customs clearance, whether labeling, inspection, and instruction manuals are ready
- Whether there is a possibility of returns, recalls, re-export, or disposal in case of sales suspension or recall
- Whether recalled items contain lithium batteries, gases, liquids, or other hazardous materials
Standard Five Classifications of Freight Forwarder Involvement
The following five classifications are not legally or industry-established categories but serve as an analytical framework to organize the scope of freight forwarder involvement in this series.
| Classification | Main Involvement in the Product Safety Pledge | Typical Items Confirmed | Judgments Usually Excluded |
|---|---|---|---|
| Simple Intermediary | Assistance with transport bookings, communications, and document exchange | Cargo description, importer, planned sales, and availability of necessary documents | Compliance with laws, eligibility for listing, or product safety guarantees |
| Cargo Transportation Service Provider | Transport of imported cargo, returns, or recalls | Transport conditions, packaging, hazardous goods classification, storage, and delivery timing | The importer's notification, inspection, or marketplace document-submission obligations |
| NVOCC / House B/L Issuer | Undertaking sea or multimodal transport as Contracting Carrier | Cargo information, transport documents, shipper, consignee, and hazardous goods declarations | Product safety liability based solely on issuing House B/Ls |
| Door-to-Door Single Contractor | Comprehensive coordination from collection through customs clearance, inspection, storage, and inland delivery | Inspection, labeling, inventory segregation, delivery, and return conditions | Legal judgments outside the contract scope, listing review, or product certification guarantees |
| Agent/Coordinator for Specific Operations | Individual coordination of inspection, labeling, return consolidation, re-export, or disposal | Delegation scope, targeted products, work instructions, and completion records | Undelegated seller interactions, consumer notifications, or recall decisions |
Contracting Carrier and Actual Carrier denote legal or contractual statuses and do not replace the above five classifications.
The scope of a freight forwarder’s responsibility is determined not only by the service name but also by contracts, quotation terms, work instructions, transport clauses, and actual handling practices.
Items Customs Brokers Should Confirm
- Whether the importer plans to sell the cargo online
- Whether the product name, usage, and specifications potentially fall under PSE, PSC, gas appliances, lithium batteries, children's products, or similar categories
- Whether compliance with labeling, notification, inspection, record-keeping, and instruction manuals has been verified before sales after customs clearance
- Whether there is any confusion between the Import Permit and the legality of domestic sales
- Whether any listing restrictions or documentation submission requirements remain on the online marketplace
- Whether returns, re-exports, export for repair, disposal, or import of replacement goods could occur in case of sales suspension or product recall
- Whether hazardous materials regulations, waste disposal laws, or destination country regulations apply to re-exporting defective or recalled products
- Whether appropriate invoice values and import purposes are confirmed even for free replacement goods
The Product Safety Pledge is not part of the customs clearance system.
Obtaining an Import Permit and being able to sell products safely and continuously on an online marketplace are separate matters.
Points Import Sellers Should Confirm
- Whether the imported products comply with Japanese product safety laws and regulations
- Whether required notifications, technical standards conformity, inspections, labeling, and record retention are properly conducted
- Whether test data and certifications from overseas manufacturers correspond to Japanese laws
- Whether the actual product, packaging, user manual, and product page have matching model numbers, specifications, and labels
- Whether prohibited items and product safety document submission rules of online marketplaces have been checked
- Whether recall information, serious product accident reports, and government notices are monitored even after sales begin
- Whether sales volume, sales destinations, buyers, and relevant lots can be tracked
- Whether instructions to stop use, returns, refunds, repairs, replacements, and recalls can be carried out for purchasers
- Whether plans are in place for inventory, advertising, delivery dates, and dealing with business partners in case of product delisting or sales suspension
- Whether product liability insurance, recall cost insurance, and recourse terms toward overseas manufacturers have been confirmed
Listing products directly from overseas e-commerce sites onto Japanese online marketplaces without confirming Japan’s product safety regulations and listing rules can lead to significant sales risks.
Major Risks Faced by Import Sellers
| Risk | Main Causes | Impact on Business | Required Response |
|---|---|---|---|
| Product Page Removal | Subject to recall, violation of laws, or insufficient documentation | New sales are suspended | Confirm the affected scope and reasons for removal |
| Search Hidden / Advertising Suspension | Under safety verification or suspected violation of terms | Loss of sales opportunities and advertising effectiveness | Stop advertising and check already sold products |
| Request for Product Safety Documentation Submission | Declaration, inspection, or labeling verification required | Delay in sales resumption if unable to respond | Organize and submit documentation by model type |
| Contacting Buyers | Accidents, recalls, or identified hazards | Inquiries, returns, and refunds surge | Prepare unified notices and a dedicated contact point |
| Account Actions | Repeated violations, unauthorized relisting, or insufficient explanations | May affect sales of other products | Resolve the cause and explain according to terms |
| Inventory Stagnation | Products that cannot be sold domestically remain in the warehouse | Storage fees, return costs, and disposal expenses incur | Consider returns, re-export, repairs, or disposal |
| Loss of Trust | Sale of hazardous products or delayed response to incidents | Lowered reputation, suspension of transactions, and demands for explanations | Clarify facts and present recurrence prevention measures |
Relationship with Other Laws and Regulations
| Laws and Systems | Main Targets | Main Checks | Relationship with Product Safety Pledge |
|---|---|---|---|
| Consumer Product Safety Act | Specified products, specified children’s products, serious product accidents, etc. | PSC mark, notification, inspection, labeling, accident reporting, and recalls | Could lead to the removal of listings for non-compliant or recalled products |
| Electrical Appliance and Material Safety Act | Electrical appliances, AC adapters, power cords, and storage batteries, etc. | PSE mark, technical standards compliance, inspection records, and labeling | Products unable to submit PSE documents could be suspended from sale |
| Gas Business Act | Gas appliances for city gas | PSTG mark, gas type, connection method, and technical standards | Could lead to the removal of non-compliant gas appliances from listings |
| Liquefied Petroleum Gas Related Laws | Liquefied petroleum gas appliances for LP gas | PSLPG mark, gas type, inspection, and labeling | Could result in sales suspension of non-compliant LP gas appliances |
| Radio Law / Telecommunications Business Act | Bluetooth, Wi-Fi, communication terminals, and IoT devices | Technical Conformity Mark, certification of conformity to technical standards, and communication functions | May require submission of wireless certification documents |
| Household Goods Quality Labeling Act | Clothing, sundries, synthetic resin processed goods, and electrical machinery and equipment, etc. | Quality labeling, Japanese labeling, labeler name, and handling instructions | May require corrections to product pages in case of labeling deficiencies |
| Recall System | Products involved in or at risk of accidents | Collection, repair, replacement, refund, warnings, and sales suspension | Central to listing removal, notifying purchasers, and preventing relisting |
The Product Safety Pledge is an effort that crosses these individual laws to suppress the distribution of hazardous products on online marketplaces.
Administrative Measures under Laws and Measures on Platforms
The product safety pledge itself is not a law, so violating the pledge alone does not subject import sellers to criminal penalties.
However, if the relevant product violates specific product safety laws, administrative measures or penalties based on those laws could become a separate issue.
| Type of Measure | Legal Basis | Main Measures | Practical Notes |
|---|---|---|---|
| Measures on Platforms | Product Safety Pledge, Listing Rules, Sales Terms, and Safety Policies | Inquiries, requests for document submission, suspension of listings, deletion of product pages, and restrictions on relisting | Check the terms and notifications of each platform operator |
| Buyer Protection Measures | Platform safety responses and seller recall measures | Buyer notification, discontinuation of use, returns, and refunds | Clarify the roles of the seller and the platform |
| Administrative Measures under Product Safety Laws | Consumer Product Safety Act, Electrical Appliance and Material Safety Act, and other laws | Demand for reports and documents, on-site inspections, improvement orders, prohibition of labeling or Hazard Prevention Orders, etc. | Responding to the online marketplace alone does not conclude administrative action |
| Sales Restrictions | Individual product safety laws | Prohibition of sale or display for sale of products lacking required labeling | Products may not be sellable even after customs clearance |
| Recalls | Voluntary measures by businesses or legally mandated harm-prevention measures | Collection, repair, replacement, refunds, inspection, and warnings | Deleting listings online does not complete market response |
| Criminal Penalties | Penalty provisions under specific laws | Penalties for violation of orders, unlabeled sales, false reporting, etc. | Distinguish between violations of the product safety pledge and legal violations |
Specific Example 1: When Sales of Overseas Manufactured Mobile Batteries Are Suspended
An importer-retailer lists mobile batteries purchased from an overseas e-commerce site on a Japanese online marketplace.
The product image displays something resembling a circular PSE mark, but the registered business name, technical standards conformity documents, and voluntary inspection records cannot be verified.
Although the online marketplace requests submission of PSE-related documentation, if the importer-retailer can only provide the overseas manufacturer’s product page and test reports, the product listing may be temporarily suspended or removed.
The importer-retailer should not simply relist the item under a different product name but must verify the scope of application under the Electrical Appliance and Material Safety Act, the registered domestic business operator, technical standards conformity, voluntary inspections, inspection records, and proper labeling.
If there are products already sold, purchaser information and sales lot numbers should be checked, and any reports of fire or other accidents should be investigated.
Example 2: Resale of a Recalled Electric Heater
Suppose an overseas manufacturer announces a recall for a specific model of electric heater due to a risk of fire, and the same model is found being sold on a domestic online marketplace in Japan.
The online marketplace operator may cross-check the recall information provided by authorities or the manufacturer with the product listings and remove the affected items.
The importer and seller must not consider deleting the product page as a sufficient response.
They should verify the quantity sold domestically, buyers, lot numbers, unshipped orders, and warehouse inventory, then provide guidance on discontinuing use, returns, refunds, exchanges, or product retrieval.
Relisting the same product under a different name, with altered images, or through a different seller account continues to pose a risk to consumers and could result in further sanctions on the account.
Specific Example 3: When PSC Documentation for Children's Toys Cannot Be Submitted
An importer-retailer lists overseas-manufactured toys intended for children under three years old on an online marketplace.
The product page includes the target age and cautionary statements; however, compliance with specific children's product regulations, technical standards, self-inspection records, and the children's PSC mark cannot be confirmed.
If the online marketplace requests product safety documentation, general safety certificates from the overseas manufacturer alone may not be sufficient to demonstrate compliance with Japan’s Consumer Product Safety Act.
The importer-retailer should suspend sales and shipments while verifying the target age, product structure, import date, transitional measures, technical standards, self-inspection, and labeling.
If there are accident reports related to detachment of small parts or similar issues from already sold products, the importer-retailer must not only correct the product page but also issue usage cessation notices to purchasers, verify accident information, and consider whether a recall is necessary.
Common Misunderstandings
| Misunderstanding | Actual Concept | Practical Notes |
|---|---|---|
| Product Safety Pledge is a law | It is a voluntary initiative established through public-private cooperation between relevant government ministries and signing companies | Distinguish it clearly from individual product safety laws |
| If the Product Safety Pledge exists, confirmation of product safety laws is unnecessary | The pledge does not substitute for statutory notifications, inspections, or labeling | Verify PSC, PSE, and other applicable laws for each product |
| All online sales platforms are signing companies | The entities responsible under the pledge are the operating companies that have joined and signed | Check the latest participating companies on the official website |
| Sites that have not signed can sell dangerous products | Laws apply regardless of the platform’s signing status | Ensure legal compliance and recall systems even on your own ecommerce site |
| If products can be listed on an online marketplace, they have passed safety confirmation | Listing eligibility and legal compliance are separate issues | Confirm notifications, inspections, labeling, and record-keeping on your own |
| If Import Permit has been obtained, online sales are permitted | Customs clearance and domestic sales regulations are different systems | Check product safety regulations and mall rules before starting sales |
| If foreign certification exists, Japanese documentation is unnecessary | Overseas standards do not always match Japanese technical standards | Check differences with Japanese standards and any additional tests needed |
| Deleting a product page completes recall handling | Contacting purchasers and recall of sold products may still be necessary | Confirm sales volume, purchasers, and affected lots |
| Relisting under a different product name resolves the issue | The product’s inherent hazards or legal violations are not resolved by changing the product name | Do not relist until the root cause is addressed |
| If the product page image shows the PS mark, that is sufficient | Physical labeling, notifications, inspections, and records must be verified | Compare physical photos with supporting documentation |
| The freight forwarder is responsible for product safety because they handled transport | Logistics operations and the legal obligations of importers and sellers are normally independent | Confirm contract terms and scope of delegation |
| Recall information does not have to be checked until contacted by the marketplace | The importing seller must continuously monitor administrative and manufacturer information | Assign personnel to monitor post-sale |
| Cargo insurance covers suspension of listings and recall costs | Cargo insurance typically covers fortuitous physical damage during transport | Separately verify PL insurance, recall cost insurance, and manufacturer recourse claims |
Decision Checklist
| Check Stage | Check Partner | Items to Confirm | Actions if Issues Arise |
|---|---|---|---|
| Product Planning Stage | Product Planning Staff, Overseas Manufacturer | Usage, Structure, Target Age, Power Source, Communication Functions, and Sales Method | Halt orders until applicable laws are confirmed |
| Before Ordering | Overseas Manufacturer, Inspection Agency | Specifications, Test Data, Certificates, Manufacturing Factory, and Model | Clarify missing documents and additional tests |
| Upon Importer Confirmation | Import Seller, Legal Department | Responsible Party for Notification, Inspection, Labeling, and Record Retention | Do not import without a clear responsible party |
| Before Shipment | Overseas Manufacturer, Freight Forwarder | Product Labeling, Accessories, Packaging, Model, Lot, and Quantity | Do not ship products with inappropriate labeling |
| Before Import Declaration | Importer, Customs Broker | Product Name, Usage, HS Code, Product Safety Regulations, and Planned Sales | Obtain additional necessary documents |
| After Customs Clearance | Importer, Warehouse | Inspection, Labeling, Instruction Manual, and Inventory Classification | Separate saleable inventory from unconfirmed inventory |
| Before Listing | Import Seller, Regulatory Staff | Notification, Inspection Records, Certificates, Actual Labeling, and Product Page | Do not list until confirmation is complete |
| Marketplace Terms Confirmation | Online Marketplace Operator | Prohibited Products, Submitted Documents, Safety Policy, and Response Deadlines | Establish system to submit necessary documents |
| Sales Start | Quality Control, Sales, EC Staff | Sales Volume, Customers, Purchasers, and Lot Management | Do not sell in an untraceable condition |
| Administration Information Check | Consumer Affairs Agency, Ministry of Economy, Trade and Industry, NITE | Recall, Incidents, Legal Amendments, and Safety Alerts | Temporarily suspend sales and shipments of the affected products |
| Marketplace Inquiry | Online Marketplace Operator | Inquiry Target, Submitted Documents, Deadline, and Product Page | Respond based on documented evidence, not speculation |
| Listing Suspension | EC Staff, Quality Control, Management | Reason for Suspension, Affected Models, Sold Quantity, and Inventory | Confirm shipment, advertising, and sales on other marketplaces |
| Accident Occurrence | Consumer, Seller, Administrative Agency | Accident Details, Damage, Model, Lot, and Severity | Preserve accident items and consider reporting and sales suspension |
| Recall Decision | Management, Quality, Legal, Overseas Manufacturer | Risk Level, Recurrence, Scope, and Countermeasures | Start purchaser notification, collection, repair, replacement, or refund |
| Return and Collection | Freight Forwarder, Warehouse, Carrier | Product Condition, Batteries, Gas, Liquid, and Hazardous Goods Classification | Do not transport casually as regular cargo |
| Overseas Return | Customs Broker, Overseas Manufacturer | Return, Repair, Investigation, Disposal, Declared Value, and Destination Country Regulations | Prepare documents suitable for cargo condition and purpose |
| Re-listing | Quality Control, Legal, Marketplace Staff | Elimination of Legal Violations, Correction Records, and Recurrence Prevention Measures | Do not re-list by simply changing the product name |
Situations to Consult with Experts
- When it is unclear whether a product is subject to PSC, PSE, PSTG, PSLPG, or other regulatory requirements
- When it is difficult to determine if overseas test reports comply with Japanese technical standards
- When an online marketplace requests documentation confirming legal compliance
- When suspension of listings or removal of product pages is related to legal violations
- When accidents, fires, damages, or serious complaints occur involving the same product
- When the affected model or lot for a recall cannot be identified
- When notifying many buyers to stop use, return, or request refunds
- When the overseas manufacturer does not provide technical data, inspection records, or manufacturing logs
- When transporting recalled items, damaged batteries, gas appliances, or hazardous goods
- When returned or re-exported products might qualify as waste
- When receiving requests for reports, on-site inspections, or harm prevention measures from governmental agencies
- When confirming the applicability of product liability (PL) insurance or recall cost insurance
Potential consulting sources include the Consumer Affairs Agency, Ministry of Economy, Trade and Industry or regional offices, NITE, lawyers specializing in product safety, registered inspection bodies, product safety testing organizations, insurance companies or insurance agents, and logistics providers knowledgeable about hazardous goods transportation.
Summary
Japan's version of the "Product Safety Pledge" is a voluntary public-private initiative designed to protect consumers from recalled or unsafe products sold on online marketplaces.
The Product Safety Pledge is not a law itself and does not replace obligations under the Consumer Product Safety Act, Electrical Appliance and Material Safety Act, Gas Business Act, or other laws and regulations.
The entities responsible for implementing the Product Safety Pledge are the operators of online marketplaces who participate in and sign the pledge.
On marketplaces operated by these signatory entities, recalled products, legally non-compliant products, or unsafe products are subject to measures such as delisting, taking reports, prevention of re-listing, notifying sellers, and providing information to buyers.
Platforms that have not signed the pledge or independent e-commerce sites are not exempt from obligations under product safety laws.
Importers and sellers must confirm applicable laws, notifications, technical standards, inspections, labeling, instructions for use, and recall information before sales, and continue monitoring accident information, public administrative announcements, and notifications from marketplaces after sales.
Obtaining an Import Permit, being able to list products on an online marketplace, having overseas certifications, or displaying a PS mark in product images do not by themselves prove lawful and safe sales within Japan.
Even if a product page is removed, separate follow-up measures such as contacting buyers, advising suspension of use, returns, refunds, repairs, exchanges, or recalls for already sold products may be necessary.
Freight forwarders and customs brokers are not parties operating the Product Safety Pledge, but in actual logistics practice, it is effective for them to confirm product safety laws, labeling, inspection documents, recalls, and transportation conditions for returns or recalls with the importer regarding imported products planned for online sale.
Violations of the Product Safety Pledge itself and violations of individual product safety laws should be distinguished. Apart from platform measures such as product page removal, legal violations may lead to sales restrictions, administrative orders, or penalties.
Safety management of online sales does not start only after inquiry from the marketplace.
Basic practice is to manage from product planning and ordering stages through to applicable laws, technical documents, inspections, labeling, sales records, accident information, buyer communications, and recall responses.
This article aims to provide a general overview of Japan’s "Product Safety Pledge" and import sales practice. It does not determine legal compliance of individual products, eligibility for listing on online marketplaces, continuation of sales, recall obligations, liability for damages, or insurance coverage. For actual products, confirmation of the latest laws, official materials, online marketplace terms of use, product specifications, test documentation, accident and recall information, and relevant authorities is necessary.
