PSC Mark for Imported Products — Notifications and Labeling under the Consumer Product Safety Act

What is the PSC Mark?

The PSC Mark is a product safety mark displayed by businesses that have fulfilled obligations such as necessary notifications, confirmation of compliance with technical standards, inspections, and record-keeping for specified products, based on the Consumer Product Safety Act.

PSC stands for Product Safety of Consumer Products. It applies to products designated by law that pose a high risk of harm to the life or body of general consumers.

For imported goods, even if the overseas manufacturer claims compliance with foreign standards, the Japanese importer must confirm compliance with the obligations under the Consumer Product Safety Act. Compliance with foreign standards, CE marking, overseas test reports, or product descriptions on overseas e-commerce sites do not by themselves guarantee legal sales eligibility within Japan.

Note that in maritime operations, PSC may refer to Port State Control. The PSC discussed in this article is not Port State Control as a ship inspection system, but the product safety mark under the Consumer Product Safety Act.

Scope Covered in This Article

Item	Content Covered in This Article	Content Covered in Other Articles
Basics of the PSC Mark	Legal status of the mark, sales restrictions, practical significance in import sales	The overall structure of the Consumer Product Safety Act is covered
Classification of Specified Products	Relationship between specified products, specially specified products, and specified children's products	Technical standards for each target product are covered in product-specific articles
Child PSC Mark	Classification of infant beds, infant toys, infant bed guards, and strollers	Details on target age, warning labels, and individual test methods are covered in product-specific articles
Obligations of Importers and Sellers	Notification, conformity to technical standards, voluntary inspections, conformity inspections, labeling, record retention	Preparation methods for import declaration documents are covered in customs documentation and pre-declaration checks
Direct Overseas Sales	Specified Import Business Operators, Domestic Responsible Persons, and points to confirm in cross-border e-commerce	Initiatives by online marketplaces are covered in product safety pledges
Post-Sales Measures	Sales suspension, accident information collection, recalls, and coordination with administrative responses	Detailed procedures for reporting serious product accidents and recalls are covered in separate articles
Other Safety Marks	System differences involving the PSE Mark, ST Mark, and other marks	Details of the Electrical Appliance and Material Safety Act and toy safety standards are covered in the respective system articles
Roles of Logistics Stakeholders	Scope of checks required by freight forwarders, customs brokers, and warehouse operators	Legal liability of customs brokers and customs-related indemnities are covered in customs indemnity and E&O case articles

Purpose and Background of the PSC Mark System

Among products used by general consumers in households and elsewhere, some pose a high risk of causing serious injury or harm to life or body due to their structure, materials, methods of use, or the nature of potential accidents.

Under the Consumer Product Safety Act, products designated by government ordinance as specified products are regulated. Manufacturers or importers are required to confirm compliance with technical standards, conduct inspections, submit notifications, maintain records, and display the prescribed markings.

In particular, products for which voluntary confirmation by manufacturers or importers may not sufficiently ensure safety are designated as specially specified products. For these products, conformity inspections by registered inspection bodies are required in addition to voluntary inspections.

Furthermore, to prevent accidents involving children's products, a system for specified children's products has been established. For these products, compliance with technical standards is supplemented by requirements concerning the intended age group, warnings, and precautions for use.

Categories of PSC Marks

The PSC Marks are not three completely independent categories of “Round PSC Mark,” “Diamond PSC Mark,” and “Child PSC Mark.”

The Round PSC Mark is used for specified products other than specially specified products, while the Diamond PSC Mark is used for specially specified products. For specified children's products, either the Round Child PSC Mark or the Diamond Child PSC Mark is used, depending on whether the product is classified as a specially specified product.

Legal Category	Mark	Basic Inspection Structure	Main Labeling and Practical Features
Specified products other than specially specified products	Round PSC Mark	Confirmation of compliance with technical standards and voluntary inspection	The name of the notified business operator must be displayed, and inspection records must be retained
Specially specified products	Diamond PSC Mark	Voluntary inspection plus conformity inspection by a registered inspection body	A conformity certificate must be obtained and retained, and the required information concerning the registered inspection body must be displayed
Specified children's products classified as specified products	Round Child PSC Mark	Confirmation of compliance with technical standards, voluntary inspection, and confirmation of child-specific labeling	The intended age group, precautions for use, warnings, and other required information must be confirmed
Specified children's products classified as specially specified products	Diamond Child PSC Mark	Voluntary inspection, conformity inspection by a registered inspection body, and confirmation of child-specific labeling	Both third-party conformity inspection and child-specific warning information are required

Products Subject to the PSC Mark

The applicable products cannot be determined solely by product names or sales-page categories. They must be assessed against the statutory product definitions based on their structure, intended use, target age, output, dimensions, and other specifications.

Category	Applicable Products	Main Examples	Basic Mark
Specially Specified Products	Portable Laser Devices	Laser pointers, laser sights, and devices that emit certain laser beams	Diamond PSC Mark
Specially Specified Products	Bathtub Hot-Water Circulators	Jet-flow devices and so-called 24-hour bath systems	Diamond PSC Mark
Specially Specified Products	Lighters	Disposable lighters and multipurpose lighters	Diamond PSC Mark
Specified Products Other than Specially Specified Products	Household Pressure Cookers and Pressure Vessels	Household pressure cookers and cooking appliances that generate a prescribed level of pressure	Round PSC Mark
Specified Products Other than Specially Specified Products	Riding Helmets	Helmets for motorcycles, motorized bicycles, and similar vehicles	Round PSC Mark
Specified Products Other than Specially Specified Products	Mountaineering Ropes	Ropes used to secure a person's body during mountaineering	Round PSC Mark
Specified Products Other than Specially Specified Products	Oil-Fired Water Heaters	Household oil-fired water heaters	Round PSC Mark
Specified Products Other than Specially Specified Products	Oil-Fired Bath Boilers	Household oil-fired bath boilers	Round PSC Mark
Specified Products Other than Specially Specified Products	Oil Stoves	Household oil stoves	Round PSC Mark
Specified Products Other than Specially Specified Products	Magnetic Recreational Products	Recreational products that use strong magnets in combination	Round PSC Mark
Specified Products Other than Specially Specified Products	Water-Absorbent Synthetic Resin Toys	Balls and other toys that expand by absorbing water	Round PSC Mark
Specified children's products classified as specially specified products	Infant Beds	Baby beds and similar products	Diamond Child PSC Mark
Specified children's products classified as specified products	Infant Toys	Toys primarily intended for use by children under three years of age	Round Child PSC Mark
Specified children's products classified as specified products	Infant Bed Guards	Rails and other devices intended to prevent infants from falling from beds	Round Child PSC Mark
Specified children's products classified as specified products	Strollers	Small manually operated wheeled vehicles used to transport infants	Round Child PSC Mark

Even where a product name resembles an item listed above, the product may fall outside the regulation if it does not meet the statutory definition. Conversely, a product marketed under a different name may still be regulated if its structure or intended use falls within the statutory definition.

Effective Dates and Grace Periods for the Child PSC Mark

The effective dates and grace periods for specified children's products vary by product. When handling existing inventory, businesses must check the manufacturing date, import date, presence of an earlier mark, expiration of the applicable grace period, and the date on which the product will be sold.

Product	Regulation Start Date	Grace Period Details	Practical Verification Points
Infant Toys	December 25, 2025	Products manufactured in or imported into Japan before the effective date may be sold without the Child PSC Mark where the transitional conditions are satisfied	Confirm the import completion date, manufacturing and import records, intended age group, and identity of the relevant inventory
Infant Beds	December 25, 2025	A grace period for products bearing the former mark is available until March 24, 2027	Confirm whether the product bears the former Diamond PSC Mark or the Diamond Child PSC Mark, together with its manufacturing, import, and sales dates
Infant Bed Guards	July 8, 2026	Sales of unmarked products may be permitted until July 7, 2027 under the grace period	Identify the relevant products and control inventory in anticipation of the end of the grace period
Strollers	July 8, 2026	Sales of unmarked products may be permitted until July 7, 2028 under the grace period	Separate grace-period inventory from products compliant with the new requirements at the SKU and lot levels

The existence of a grace period does not mean that every product may be sold unconditionally until the stated deadline. The applicable product, manufacturing or import date, earlier labeling, inventory identity, and other statutory conditions must be confirmed.

Main Situations Where the PSC Mark System Applies

Situation	Relation to Regulation	Main Responsible Party	Key Verification Points
Importing overseas products for domestic sale	Notification, inspection, labeling, record-retention, and other obligations of the importer become relevant	Importer and seller	Product classification, technical standards, inspection system, and labeling
Manufacturing and selling products in Japan	Obligations of the domestic manufacturer become relevant	Domestic manufacturer	Manufacturing process, inspection, records, and labeling
Selling products through an e-commerce platform	Compliance must be confirmed before sale and cannot be established solely by displaying an image of the mark	Seller and sales business operator	Product page, actual product labeling, and consistency of submitted documents
Providing products following crowdfunding	The substantive supply and sales relationship must be examined even where the transaction is described as support or a reward	Project organizer, importer, and seller	Method of supply, importer, quantities, and planned start of distribution
An overseas business operator sells directly to consumers in Japan	The Specified Import Business Operator and Domestic Responsible Person requirements become relevant	Overseas seller and Domestic Responsible Person	Business notification, appointment of a Domestic Responsible Person, technical standards, and accident-response system
Selling used products	Used products may also be subject to sales restrictions	Used-goods seller	Marking, product classification, manufacturing period, and special provisions for used specified children's products
Displaying products in a store for the purpose of sale	Applicable products without the required marking may not be displayed for the purpose of sale	Retailer	Product marking, packaging, and inventory classification
Applying labels in a domestic warehouse after import	All required procedures and labeling must be completed before sale	Importer, seller, and contracted warehouse operator	Authority to apply the label, work instructions, lot management, and reinspection

Requirements for Displaying the PSC Mark

Requirement	Verification Points	Main Documents	Practical Notes
Determination of Applicable Product	Whether the product falls within a statutory definition of a specified product	Specifications, drawings, intended-use descriptions, and target-age information	Do not reach a final conclusion solely from the product name or HS code
Business Notification	Whether the notification required before commencing the manufacturing or import business has been submitted	Business notification forms and records of submission or acceptance	Changes in the relevant product category or business details may also require confirmation
Compliance with Technical Standards	Whether the product complies with the technical standards prescribed by the government	Test reports, design documents, and material certificates	Compliance with overseas standards alone may not satisfy Japanese requirements
Voluntary Inspection	Whether the required inspections have been performed on the manufactured or imported products	Inspection procedures, inspection records, and lot records	Obtaining a type-test report is not necessarily the same as completing the required voluntary inspection
Conformity Inspection	Whether a specially specified product has undergone conformity inspection by a registered inspection body	Conformity certificate, inspection application, and model information	Confirm the applicable models, manufacturing facilities, and scope of the certificate
Child-Specific Labeling	Whether the intended age group, warnings, and precautions for use comply with the applicable requirements	Draft labels, packaging, and instruction manuals	Do not change the intended age group merely to avoid regulation
PSC Mark Display	Whether the correct form of the mark and the name of the notified business operator are displayed	Product photographs, label specifications, and inspection records	Simply affixing an image of the mark is not sufficient
Record Retention	Whether inspection records, certificates, and manufacturing or import lots can be traced	Inspection ledgers, import records, purchase records, and inventory ledgers	The business should be able to trace the products and their distribution destinations if an accident occurs

Situations Requiring Confirmation of Exemptions, Exceptions, and Transitional Measures

In the following situations, the applicable treatment may differ from that for ordinary domestic sales. Procedures should not be omitted merely because a product appears to fall within an exception. The statutory conditions and any notification or approval requirements must be confirmed.

Situation	Basic Approach	Necessary Checks	Precautions
Products outside the statutory product definition	A product that does not meet the definition of a specified product is outside the PSC Mark system	Intended use, structure, dimensions, performance, and target age	Do not determine exclusion solely from the seller's product name
Products imported by an individual for personal use	Personal use differs from commercial domestic sale, but repeated imports or later resale may change the assessment	Quantity, frequency, intended use, sales plans, and identity of the importer	A personally imported product cannot necessarily be resold without further compliance
Products exclusively for export	An exception may apply where the products will not be sold to general consumers in Japan	Export destination, absence of domestic sales, and required notification or approval	Any domestic distribution must be assessed separately
Special-purpose products supplied to specified users	An approval system may apply where the product is supplied for a special use rather than ordinary consumer use	User, intended purpose, conditions of supply, and approval requirements	Labeling a product “for business use” does not automatically exclude it from regulation
Imports for testing or evaluation	Limited imports for testing may be treated differently, but subsequent general sale is a separate issue	Quantity, intended use, whether the product will be sold, and method of disposal or return	Previous sample customs clearance does not establish the legality of commercial sales
Infant toys manufactured or imported before the effective date	They may qualify as pre-enforcement inventory or be covered by transitional measures	Manufacturing or import date, lot records, and identity of the inventory	Inventory without reliable date evidence may be difficult to classify
Infant beds bearing the former mark	Sale may be permitted during the prescribed transitional period	Former mark, manufacturing or import date, and planned sales date	Control the date on which sale must cease after the transitional period
Used specified children's products	A special approval system involving safety assurance and purchaser warnings may apply	Product condition, labeling, inspection, purchaser warnings, and approval	Used products are not automatically exempt from sales restrictions

Differences between the PSC Mark, PSE Mark, ST Mark, and Other Requirements

System or Mark	Legal Basis and Nature	Main Scope	Inspection or Verification Features	Relationship to the PSC Mark
PSC Mark	Statutory marking under the Consumer Product Safety Act	Specified products and specially specified products	Compliance with technical standards, voluntary inspection, and conformity inspection for specially specified products	Sale and display for the purpose of sale are restricted where the required marking is absent
Child PSC Mark	Statutory marking under the Consumer Product Safety Act	Specified children's products	Verification of technical standards, inspection, intended age group, warnings, and precautions	The mark may be round or diamond-shaped depending on the legal category of the product
PSE Mark	Statutory marking under the Electrical Appliance and Material Safety Act	Electrical appliances, power supplies, power cords, and other electrical products	Compliance with technical standards must be confirmed according to the relevant electrical-appliance category	A product with electrical functions may require PSE compliance separately from PSC compliance
ST Mark	Voluntary mark based on toy safety standards	Toys	Inspection and marking under standards administered by the relevant organization	The voluntary ST Mark does not replace statutory obligations under the Child PSC Mark system
Food Sanitation Act Requirements	Statutory requirements under the Food Sanitation Act	Certain toys and products that may come into contact with an infant's mouth	Materials, migration of substances, and classification as a designated toy may need to be confirmed	These requirements may apply concurrently with the Child PSC Mark requirements
Radio Act Requirements	Statutory requirements under the Radio Act	Products equipped with wireless communication functions	Technical standards conformity certification and related requirements may need to be confirmed	Radio Act compliance must be considered separately even where the PSC Mark is present

Multiple regulatory systems may apply to a single product. For example, a children's product with electrical or wireless functions may require simultaneous confirmation under the Child PSC Mark system, the Electrical Appliance and Material Safety Act, the Radio Act, the Food Sanitation Act, labeling rules, and other applicable regulations.

Importer and Seller Obligations Flow

1. Determine the product's intended use, structure, target age group, and specifications.
2. Confirm whether the product is a consumer product covered by the Consumer Product Safety Act.
3. Determine whether it is a specified product, specially specified product, or specified children's product.
4. Identify the applicable technical standards and required labeling.
5. Identify the domestic importer or Specified Import Business Operator responsible for compliance.
6. Submit the required business notification.
7. Obtain design documents, material information, and test documentation from the overseas manufacturer.
8. Confirm compliance with Japanese technical standards.
9. Establish the voluntary inspection method, inspection units, and record-retention procedure.
10. For a specially specified product, obtain conformity inspection from a registered inspection body.
11. For a specified children's product, determine the intended age group, warnings, and precautions for use.
12. Display the correct PSC Mark, the name of the notified business operator, and all other required information.
13. Cross-check the product, packaging, instruction manual, and sales-page content.
14. Conduct a pre-sale inspection and ensure that each lot and inventory group can be identified.
15. Establish systems for collecting accident information, handling inquiries, conducting recalls, and making required reports after sale.

Even where an overseas manufacturer states that a product is “PSC compliant,” the importer and seller must verify the precise basis for that statement, including the test scope, applicable models, manufacturing facilities, entity responsible for the marking, and inspection records.

Documents to Obtain Before Import

Document	Purpose of Verification	Details to Confirm	Action if Missing
Product Specification Sheet	Determination of product scope	Structure, dimensions, materials, intended use, and performance	Request model-specific specifications from the manufacturer
Target-Age Documentation	Determination of whether the product is a specified children's product	Designed age range and advertised target age	Document the factual basis for the stated target age
Test Report	Confirmation of compliance with technical standards	Test standards, test items, applicable model, and testing laboratory	Identify differences from Japanese standards and arrange additional testing where necessary
Material Certificate	Verification of material requirements	Materials used, chemical substances, and component composition	Request a supplier certificate or arrange additional analysis
Product Drawings	Verification of structural requirements	Dimensions, moving parts, openings, and protective structures	Confirm consistency between the drawings and mass-produced products
Quality-Control Documents	Confirmation of continuing compliance	Inspection processes, defect control, and change management	Strengthen the importer's receiving inspection where necessary
Draft Labeling	Verification of statutory marking	PSC Mark, business name, warnings, and target age	Finalize the Japanese labeling before mass production
Manufacturing and Import Lot Documents	Traceability and application of transitional measures	Manufacturing date, import date, quantity, and model	Establish a reliable lot-numbering and inventory-control method

Items to Check on the Label

• Whether the form of the PSC Mark is correct for the applicable product
• Whether a specified children's product bears the required Child PSC Mark rather than an ordinary PSC Mark
• Whether the name of the notified business operator is correctly displayed
• Whether the required information concerning the registered inspection body is displayed for a specially specified product
• Whether the intended age group, warnings, prohibitions, and precautions for use are appropriate
• Whether the mark is displayed in a visible location on the product using a durable method
• Whether the packaging, instruction manual, sales page, and actual product are consistent
• Whether the manufacturer, brand owner, importer, and notified business operator are correctly distinguished
• Whether different models or different markings are mixed within the same inventory group
• Whether transitional products can be distinguished from products compliant with the new requirements

The PSC Mark is not a safety-mark image that may be attached freely. It may be displayed only by a notified business operator that has fulfilled the applicable notification, technical-standard conformity, inspection, labeling, and record-retention obligations.

Matters Freight Forwarders Should Confirm

Freight forwarders are generally not responsible for assessing compliance with technical standards or making the final legal determination as to whether a product is subject to the PSC Mark requirements.

However, where the cargo description, intended use, target age, product documentation, or transport schedule indicates that the PSC Mark system may apply, the freight forwarder should prompt the importer to verify the applicable requirements.

• Whether the cargo is intended for general consumers
• Whether it consists of pressure cookers, helmets, lighters, laser products, oil-fired equipment, children's products, or similar goods
• Whether it consists of samples, exhibition goods, crowdfunding products, or products intended for e-commerce sale
• Whether domestic sales will begin immediately after customs clearance
• Whether inspection, label application, reinspection, or replacement of instruction manuals is planned
• Whether the importer has confirmed the applicable notification, technical standards, and sales restrictions
• Whether PSE requirements, the Radio Act, the Food Sanitation Act, or other regulations may apply concurrently

Prompting the importer to verify compliance does not transfer the importer's or seller's statutory obligations to the freight forwarder. Conversely, coordinating the logistics process does not mean that the freight forwarder guarantees compliance with product safety regulations.

Comparison of Freight Forwarders' Involvement Scope

The five classifications used in this article are not established by law or industry-wide consensus. They serve as an analytical framework within this series to clarify the scope of freight forwarder involvement.

Classification	Main Involvement in PSC Practices	Usual Checks	Judgments Generally Excluded
Simple Intermediary（単純取次）	Assistance with transport bookings, communications, and document exchange	Product name, importer, planned sales, and availability of required documents	Determination of compliance with technical standards or a guarantee of the legality of the PSC Mark
Cargo Transportation Service Provider（貨物利用運送事業者）	Provision of transport services and arrangement of related service providers	Transport schedule, inspection location, labeling location, and cargo-handling conditions	Assumption of the importer's business-notification or product-inspection obligations
NVOCC / House B/L Issuer	Undertaking ocean or multimodal transport as a contractual transport service provider	Transport documents, cargo information, and the party responsible for regulatory confirmation	Product-safety compliance responsibility based solely on issuance of a House B/L
Door-to-Door Single Contractor	Integrated coordination of logistics processes from pickup to final delivery	Inspection and marking processes, warehouse operations, delivery conditions, and the effect of delays	Legal determination or product-certification guarantees not included in the contract
Agent/Coordinator for Specific Operations（特定業務の代理・調整者）	Individual coordination of inspection appointments, label application, warehouse work, and other assigned operations	Assigned scope of work, work instructions, and completion records	Notifications, testing, or sales-eligibility judgments outside the delegated scope

Contracting Carrier and Actual Carrier are legal or contractual status concepts and do not replace the Standard Five Classifications used in this article.

Practical operations such as inspection, label application, repacking, storage, and inland delivery do not by themselves constitute a sixth classification. The actual scope of responsibility must be determined from the contract, quotation terms, work instructions, applicable clauses, and actual conduct of the parties.

Items Customs Brokers Should Verify

Customs brokers may identify cargo requiring confirmation of domestic sales regulations when reviewing the product name, intended use, specifications, importer, and planned sales for an import declaration.

• Whether the invoice description and product documentation indicate that the cargo may be a specified product
• Whether the structure, intended use, and target age must be confirmed in addition to the HS code
• Whether the importer repeatedly imports the product for commercial sale
• Whether the importer has confirmed the procedures required under the Consumer Product Safety Act
• Whether laws other than the PSC Mark system must also be checked
• Whether inspection, labeling, repacking, or replacement of instruction manuals is planned after customs clearance
• Whether the importer is confusing an Import Permit with legal eligibility for domestic sale

An Import Permit signifies completion of the import declaration formalities under the Customs Act. It does not comprehensively establish compliance with domestic sales regulations, including the PSC Mark system.

Direct Sales by Overseas Businesses

Where an overseas business sells a product subject to the PSC Mark directly to consumers in Japan through an online marketplace, its own e-commerce site, or another method without using an importer in Japan, the Specified Import Business Operator requirements may apply.

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

Item to Confirm	Overseas Business	Domestic Responsible Person	Practical Notes
Business Notification	Prepare the information required as a Specified Import Business Operator	Assist with the notification procedures and domestic administrative communications	The Domestic Responsible Person should not submit a notification without the overseas business's authorization and supporting documents
Technical Standards	Provide product documentation, test data, and manufacturing information	Maintain a system in Japan for reviewing and retaining the relevant documents	The parties must be capable of responding to Japanese administrative authorities
Labeling	Ensure that the correct labeling is applied to products supplied to Japan	Confirm the labeling of products distributed in Japan	Images displayed on the overseas website must be consistent with the actual products sold in Japan
Accident Response	Provide accident information, manufacturing-lot data, and sales records	Handle domestic communications, document submissions, recalls, and other required measures	The system must prevent loss of contact, inadequate records, and delays in safety measures

Shipping the product directly from overseas, receiving the sales proceeds overseas, or having no Japanese corporation does not automatically exempt the transaction from Japanese product safety regulations.

Main Cases Where Customs Clearance Is Possible but Sale Is Prohibited

Case	Main Cause	Documents to Check	Key Point for Judgment	Initial Response
A lighter is found to be subject to the Diamond PSC Mark after import	The order was placed based only on a commercial product category without checking the regulation	Specifications, import records, and test data	Whether the required notification and conformity inspection can lawfully be completed	Stop sales and shipments and consult a registered inspection body or the relevant authority
The output category of a laser product is unclear	The manufacturer's documents do not contain sufficient laser classification or specification data	Output data, wavelength data, and test reports	Whether the product falls within the statutory definition of a portable laser device	Isolate the product and obtain the necessary technical data and test results
Toys intended for children under three years of age lack the Child PSC Mark	The overseas manufacturer did not correctly assess the intended age group	Product descriptions, packaging, import date, and target-age documentation	Whether the inventory was imported before or after the effective date	Suspend sales and confirm the import date and applicable requirements
Old inventory and products compliant with the new stroller requirements are mixed	SKU and lot controls were inadequate	Purchase ledger, import dates, product photographs, and inventory records	Whether products covered by transitional measures can be individually identified	Separate the inventory and control the applicable sales deadlines
A pressure cooker has only overseas certification	The importer assumed that overseas certification replaced Japanese requirements	Overseas test reports and a comparison with Japanese technical standards	Whether all tests required under the Japanese technical standards have been completed	Identify missing tests and confirm compliance before sale
An e-commerce marketplace requests product-safety documents	Labels were present, but notification and inspection documents had not been organized	Notification forms, inspection records, certificates, and product photographs	Whether the business can prove fulfillment of the obligations supporting the marking	Temporarily suspend the listing and verify the consistency of all documents
A sample import is subsequently offered for commercial sale	Sample customs clearance was confused with compliance for general sale	Purpose of import, quantity, sales records, and product data	Whether the purpose changed from testing or evaluation to commercial sale	Stop the sale and confirm the ordinary import and sales requirements
An overseas business ships directly to consumers in Japan	The Specified Import Business Operator requirements were not considered	Sales pages, delivery records, and Domestic Responsible Person documentation	Whether the transaction constitutes direct sale to consumers in Japan	Stop new sales, appoint a Domestic Responsible Person, and establish the required notification and compliance system

Administrative Measures and Penalties

Violations of the PSC Mark system are not necessarily treated as minor labeling deficiencies. Administrative or criminal measures may apply depending on the nature of the violation, the level of danger, the number of products distributed, and the business operator's response.

Measure	Typical Situation	Impact on the Business Operator	Practical Response
Improvement Order	Obligations concerning technical-standard compliance, inspection, or record retention have not been properly fulfilled	The operator may be required to correct its business methods, inspection system, or quality controls	Identify the affected lots, determine the cause, and prepare corrective and preventive measures
Prohibition of Marking	The PSC Mark has been displayed without fulfillment of the statutory requirements	The operator may be prohibited from displaying the mark on the relevant products for a prescribed period	Stop marking and sales and identify all affected products and inventory
Hazard Prevention Order	Measures are required to prevent the occurrence or spread of serious harm	The operator may be ordered to recall products, stop sales, notify consumers, or take other safety measures	Trace distribution destinations, isolate inventory, notify consumers, and establish a recall system
Request for Reports or On-Site Inspection	The authority needs to verify compliance or investigate an accident	The operator may be required to submit ledgers, inspection records, products, sales records, and other materials	Preserve the records without alteration and organize the facts chronologically
Publication of Violation Information	Administrative action or a consumer warning is required	The operator may suffer reputational damage, suspension of transactions, or removal of e-commerce listings	Establish a consistent factual account, identify the affected products, and create a consumer contact point
Criminal Penalties	Sales restrictions, marking prohibitions, or administrative orders have been violated	Imprisonment, a fine, or both may apply depending on the violation	Immediately stop sales and consult a specialist familiar with product safety regulations

Where a specified product is sold or displayed for the purpose of sale without the required marking, the applicable violation may be punishable by imprisonment for up to one year, a fine of up to one million yen, or both.

Other penalties may apply to violations involving inspections, record retention, notifications, warning information for specified children's products, or administrative orders. The applicable statutory provision and penalty must be confirmed for the particular violation.

Relationship with Accidents and Recalls

Displaying the PSC Mark lawfully does not eliminate the obligation to respond to accidents or defects discovered after sale.

If an accident, defect, design issue, labeling problem, or manufacturing-lot anomaly is identified, it may be necessary to collect accident information, investigate the cause, suspend sales, warn consumers, recall products, repair or replace products, and report to the authorities.

In particular, manufacturers or importers may be required to report a serious product accident under the applicable law. Sellers, repair businesses, and installation businesses that become aware of accident information should have a system for promptly transmitting that information to the manufacturer or importer.

Example 1: A Laser Pointer Is Found to Be Subject to the Diamond PSC Mark after Import

Suppose an importer and seller purchases a laser pointer from an overseas e-commerce site and, after import customs clearance, attempts to begin domestic sales. The sales platform then requests submission of PSC-related documents.

The first issue is not the commercial product name but whether the product falls within the statutory definition of a portable laser device. The laser output, wavelength, intended use, construction, portability, and other specifications must be checked against the product specifications and test reports.

If the product falls within the definition, it is a specially specified product. The importer must therefore consider the import-business notification, voluntary inspection, conformity inspection by a registered inspection body, record retention, and Diamond PSC Mark requirements.

Even if an image of the Diamond PSC Mark has been printed on the product, the business should not begin sales without confirming the notification, conformity inspection, and identity of the operator entitled to display the mark. Sales and shipments should be suspended, the inventory isolated, and the registered inspection body or relevant authority consulted.

Example 2: Different Treatment Based on the Import Date of Toys for Children under Three

Assume that an importer stores infant toys of the same model in the same warehouse, with one lot imported in November 2025 and another lot imported in January 2026.

The Child PSC Mark requirements for infant toys took effect on December 25, 2025. The treatment of inventory imported before that date may therefore differ from the treatment of inventory imported after that date.

The products should not be treated as a single group merely because they look identical. The Import Permit date, purchase lot, warehouse receipt records, manufacturing numbers, and packaging labels should be cross-checked to identify the inventory imported before the effective date.

For applicable products imported after the effective date, the importer must confirm compliance with technical standards, intended-age and warning information, voluntary inspection, the Child PSC Mark, and the other applicable requirements. If the lots cannot be distinguished, the business may be unable to prove that particular inventory was imported before the effective date, and sales should be suspended pending further confirmation.

Example 3: Selling Existing Stroller Inventory during the Transitional Period

Strollers became specified children's products on July 8, 2026, but a transitional period applies until July 7, 2028.

During that period, products compliant with the Child PSC Mark requirements and unmarked inventory covered by transitional measures may both be present in the market.

Importers and sellers should not assume that every stroller may be sold without the mark merely because a transitional period exists. They must confirm the statutory product scope, manufacturing or import date, inventory lot, planned sales date, and conditions of the transitional measures.

Continuing to purchase old inventory shortly before the end of the transitional period may leave the business with stock that cannot be sold after the deadline. Products compliant with the new requirements and products covered by transitional measures should be separated by SKU and lot, with the sales deadline, product page, warehouse inventory, and actual labeling managed consistently.

Example 4: An Overseas Business Sells Directly to Consumers in Japan

Suppose an overseas manufacturer operates an e-commerce site directed at Japan, accepts orders from consumers in Japan, and ships lighters directly from an overseas warehouse.

Shipment from overseas and the absence of a Japanese sales company do not exempt the business from Japanese product safety regulations. If the transaction constitutes direct sale to consumers in Japan, the overseas business must comply as a Specified Import Business Operator and appoint a Domestic Responsible Person.

The Domestic Responsible Person is not merely a nominal representative. The person must be able to communicate with the authorities, retain the required documents, respond to accident information, support recalls, and implement other safety measures in Japan.

Domestic logistics providers, sales-support companies, and nominal representatives should not submit notifications without the overseas business's authorization, the required documents, and a clear allocation of compliance responsibilities.

Common Misunderstandings

Misunderstanding	Actual Understanding	Practical Considerations
A product that has received an Import Permit may be sold in Japan without further checks	An Import Permit and compliance with domestic sales regulations are separate matters	Confirm notification, inspection, labeling, and record retention before beginning sales
Attaching a PSC Mark sticker is sufficient	The mark may be displayed only after the applicable notification, technical-standard compliance, inspection, and other obligations have been fulfilled	Prepare and verify the documents supporting the mark before applying it
A CE mark eliminates the need for the PSC Mark	Compliance with an overseas standard does not establish compliance with Japanese law	Identify and address differences between the overseas standard and Japanese technical standards
There is only one form of the Child PSC Mark	The Child PSC Mark may be round or diamond-shaped depending on whether the product is a specially specified product	Do not treat infant beds, infant toys, bed guards, and strollers as having identical requirements
A product is not an infant toy if the seller removes the child-use description	The assessment is based on the design, function, dimensions, advertising, intended use, and other objective factors	Do not attempt to avoid regulation merely by changing the stated target age
A product cleared as a sample may automatically be sold commercially	Import for testing or evaluation and supply to general consumers are assessed separately	Confirm the ordinary commercial-sale obligations before offering the product for sale
Used products are outside the PSC Mark system	Used products may remain subject to sales restrictions and special approval requirements	Confirm the special provisions applicable to used specified children's products
All old products may be sold freely during a transitional period	The applicable conditions differ according to product, manufacturing or import date, earlier marking, and deadline	Control the lot number, evidence of dates, and final permitted sales date
A freight forwarder that handled the transport bears the PSC compliance responsibility	The statutory duties of the importer or seller are generally separate from the freight forwarder's logistics duties	Confirm the delegated work, contract terms, and actual scope of involvement
Japanese regulation does not apply where the product is shipped directly from overseas	The Specified Import Business Operator requirements may apply to direct sales to consumers in Japan	Appoint a Domestic Responsible Person and establish notification, compliance, and post-sale response systems
PSC means Port State Control in every context	PSC in this article refers to the product safety mark under the Consumer Product Safety Act	Distinguish the product-safety meaning from the maritime inspection meaning

Decision Checklist

Check Point	Party to Confirm With	Items to Confirm	Actions if Issues Are Found
During Product Planning	Product planning staff and manufacturer	Intended use, structure, target age group, and method of sale	Place the order on hold until the applicable product classification is resolved
Before Ordering	Overseas manufacturer and testing body	Technical data, test reports, and mass-production specifications	Identify missing documents and additional testing requirements
When Identifying the Importer	Importer, seller, and regulatory-affairs staff	Entity responsible for notification, labeling, inspection, and record retention	Do not begin importing until the responsible entity has been identified
Before Shipment	Manufacturer and freight forwarder	Labels, packaging, model, lot number, and quantity	Stop shipment of products with incorrect or incomplete labeling
Before Import Declaration	Importer and customs broker	Product name, intended use, other applicable regulations, and planned sales	Obtain the additional documents needed for regulatory confirmation
After Customs Clearance	Importer and warehouse operator	Inspection, labeling, reinspection, and inventory segregation	Separate saleable products from products whose compliance has not been confirmed
When Creating the Sales Page	Sales staff and regulatory-affairs staff	Actual product marking, intended age, warnings, and product description	Do not publish the page until discrepancies with the actual product are corrected
Before Sales Begin	Quality-control staff	Notification, inspection records, certificates, labeling, and inventory identity	Stop shipment until final compliance approval is obtained
When Selling Products under Transitional Measures	Inventory staff and regulatory-affairs staff	Manufacturing or import date, lot number, applicable conditions, and sales deadline	Implement controls preventing sale after the deadline
When an Accident or Complaint Occurs	Purchaser, manufacturer, and relevant authority	Accident details, product number, sales date, injury, and affected lot	Consider sales suspension, evidence preservation, reporting, and recall
During an Administrative Inquiry	Government officials and relevant specialists	Notification, inspection, sales records, and history of the response	Organize the facts chronologically and respond without delay
When Product Specifications Change	Manufacturer, testing body, and regulatory-affairs staff	Changes to materials, structure, factory, model, and test scope	Do not automatically rely on an existing certificate; confirm whether retesting or a new conformity inspection is required

Situations Where Consultation with Experts Is Advisable

• When it is unclear whether a product falls within a statutory product definition
• When it cannot be determined whether an overseas test report satisfies Japanese technical standards
• When a conformity inspection for a specially specified product is being arranged for the first time
• When the intended age range or warning information for a specified children's product cannot be determined
• When the manufacturing or import date of inventory subject to transitional measures cannot be proven
• When products without the required PSC Mark have already been sold
• When a product accident, injury, fire, ingestion, or other serious harm has occurred
• When the authorities request reports or documents, conduct an on-site inspection, or direct the business to suspend sales
• When entering into an agreement to act as a Domestic Responsible Person for an overseas business
• When deciding how to conduct a recall, accept returns, dispose of products, or compensate consumers

Possible consultation contacts include the Ministry of Economy, Trade and Industry, the relevant Regional Bureau of Economy, Trade and Industry, registered inspection bodies, product-safety testing organizations, lawyers familiar with product safety regulation, and other specialists.

Summary

The PSC Mark is a statutory product safety mark under the Consumer Product Safety Act. It may be displayed only after the applicable obligations concerning technical-standard compliance, business notification, inspection, record retention, and marking have been fulfilled.

The Round PSC Mark applies to specified products other than specially specified products, while the Diamond PSC Mark applies to specially specified products. For specified children's products, either the Round Child PSC Mark or the Diamond Child PSC Mark applies depending on the legal category of the product.

As of July 2026, infant beds, infant toys, infant bed guards, and strollers are specified children's products. Their effective dates and transitional measures differ, so the manufacturing date, import date, marking, inventory lot, and planned sales date must be checked separately for each product.

An Import Permit, compliance with an overseas standard, an overseas manufacturer's safety explanation, or an image of the PSC Mark printed on the product does not by itself establish lawful eligibility for sale in Japan.

Importers and sellers must manage the entire process, including determination of product scope, notification, technical-standard compliance, voluntary inspection, any required conformity inspection, marking, record retention, and post-sale measures.

Freight forwarders and customs brokers are generally not responsible for making the final determination of technical-standard compliance. However, where a product may be subject to the PSC Mark system, they should prompt the importer to verify the requirements and coordinate the inspection, marking, storage, and sales schedule within the scope of their assigned work.

Violations may result in sales suspension, prohibition of marking, improvement orders, Hazard Prevention Orders, recalls, publication of violation information, and criminal penalties. Product safety requirements should therefore be confirmed during product planning and before ordering, rather than after shipment or customs clearance.

This article provides a general explanation of the system and related import practices. It does not guarantee the legal conformity or sales eligibility of any individual product. For an actual product, the latest laws, official documents, product specifications, and guidance from the relevant authorities must be confirmed.