Amazon Japan Product Compliance: Basic Knowledge

Course Path and Content

This course outlines the key areas of product compliance for Amazon Japan sellers.

Table of Contents

1. 3. Japan Product Compliance Introduction
2. 3.1 Overview of Japan Site Compliance Items and Requirements
3. 3.2 Introduction to Japan's "Four Major Product Safety Laws" Compliance Requirements
4. 3.3 Introduction to Other Legal Requirements and Compliance Items for the Japan Site

3. Japan Product Compliance Introduction

Understanding the compliance requirements for selling on Amazon Japan is fundamental. This guide outlines key compliance laws and policies for major product categories in Japan, such as electronics and toys. It aims to help sellers identify reasons for product delisting and prepare necessary compliance materials for appeals, ensuring smooth sales.

Note: The information on laws, regulations, policies, and declaration requirements is for reference only and does not constitute an exhaustive list. It does not represent Amazon's interpretation or legal advice. For any questions regarding relevant laws, regulations, policies, or declaration requirements, please contact the relevant government authorities or your legal and tax advisors.

3.1 Overview of Japan Site Compliance Items and Requirements

When selling on Amazon Japan, sellers must first meet product safety compliance policy requirements. The table below outlines Amazon's compliance items and the corresponding measures sellers should take:

3.2 Introduction to Japan's "Four Major Product Safety Laws" Compliance Requirements

In summary, sellers starting sales on Amazon Japan must comply with Japanese legal regulations and Amazon's global compliance requirements. These requirements fall into three main categories:

3.2.1 Introduction to the "Four Major Product Safety Laws"

The "Four Major Product Safety Laws" (METI) are promoted by Japan's Ministry of Economy, Trade and Industry (METI). They aim to prevent hazards caused by electrical appliances, gas appliances, and general consumer products, ensuring consumer safety. These laws are mandatory compliance requirements for sellers on the Japan site and include:

• Electrical and Material Safety Act (457 items)
• Consumer Product Safety Act (10 items)
• Gas Business Act (8 items)
• Liquefied Petroleum Gas Safety Assurance and Optimization of Transactions Act (16 items)

Electrical and Material Safety Act

This act applies to regulated electrical products, categorized into specific products (Category A) and non-specific products (Category B).

• Specific Products (Category A) (116 items): Use the PSE mark (diamond shape), representing specific products such as AC/DC power adapters, extension cords, electric toys, and portable generators.
• Non-Specific Products: Use the PSE mark (circular shape), representing non-specific products such as refrigerators, air conditioners, water heaters, washing machines, electric fans, air purifiers, vacuum cleaners, TV receivers, furniture with sockets, LED lights, LED lighting fixtures, lithium-ion batteries, and toys made of magnetic materials.

Consumer Product Safety Act

This act applies to regulated consumer products, classified into specially designated products (Category A) and other designated products (Category B) from a safety perspective.

• Specific Products (Category A) (4 items): Use the PSC mark (diamond shape), including: ① baby cribs; ② portable laser application devices; ③ bathroom water circulation heaters; ④ lighters and practical lighters.
• Other Designated Products (Category B) (6 items): Use the PSC mark (circular shape), including: ① household pressure cookers and cooker pots; ② riding helmets (for two-wheeled motor vehicles, electric bicycles); ③ climbing ropes; ④ petroleum water heaters; ⑤ oil bath boilers; ⑥ fuel oil heaters.

Gas Business Act

This act applies to regulated natural gas and gas appliances, categorized into specific products (Category A) and non-specific products (Category B).

• Specific Products (Category A) (4 items): Use the PSTG mark (diamond shape), including: ① gas water heaters (with open flue); ② gas space heaters (with open flue); ③ gas heating bathroom water heaters (with open flue); ④ gas ignition devices for bathing water heaters.
• Non-Specific Products (Category B) (4 items): Use the PSTG mark (circular shape), including: ① gas water heaters (unventilated, direct exhaust, outdoor); ② gas space heaters (unventilated, direct exhaust, outdoor); ③ gas water heaters (direct exhaust, outdoor); ④ gas stoves.

Liquefied Petroleum Gas Safety Assurance and Optimization of Transactions Act

This act applies to regulated liquefied petroleum gas products, categorized into specific products (Category A) and non-specific products (Category B).

• Specific Products (Category A) (7 items): Use the PSLPG mark (diamond shape), including: ① liquefied petroleum gas water heaters (with natural draft); ② liquefied petroleum gas space heaters (with natural draft); ③ liquefied petroleum gas heating bathroom water heaters (with open flue); ④ bathroom heaters; ⑤ liquefied petroleum gas ignition devices for bathing water heaters; ⑥ liquefied petroleum gas cylinder stoves; ⑦ liquefied petroleum gas valves.
• Non-Specific Products (Category B) (9 items): Use the PSLPG mark (circular shape), including: ① liquefied petroleum gas water heaters (unventilated, direct exhaust, outdoor); ② liquefied petroleum gas space heaters (unventilated, direct exhaust, outdoor); ③ liquefied petroleum gas water heaters (direct exhaust, outdoor); ④ liquefied petroleum gas stoves; ⑤ regulators; ⑥ high-pressure hoses; ⑦ low-pressure hoses; ⑧ anti-shock automatic liquefied petroleum gas circuit breakers; ⑨ liquefied petroleum gas leak detectors.

3.2.2 Key Points of Japan's "Four Major Product Safety Laws" (METI)

1. The "Four Major Product Safety Laws" include hazardous goods designated by Japan's Ministry of Economy, Trade and Industry (METI). Manufacturers and importers of these products must notify METI before commencing production or import.
2. METI requires manufacturers and importers who have completed the prior notification to comply with the technical standards set by the Japanese government.
3. Circular PSE Mark: Japanese manufacturers and importers can affix the circular PSE mark to compliant products after self-assessment and "self-confirmation."
4. Diamond PSE Mark: Products requiring the diamond PSE mark must undergo technical inspection by a registered testing laboratory (accredited laboratory) in addition to the "self-confirmation" procedure. Refer to ISO/IEC 17065 (conformity assessment).
5. Products designated by the "Four Major Product Safety Laws" are prohibited from sale if they do not bear the "PS mark" and the name of the manufacturer/importer who has provided prior notification.

3.2.3 Compliance Process for Japan's "Four Major Product Safety Laws"

The "Four Major Product Safety Laws" require Japanese manufacturers and importers to complete the following compliance process:

1. Step 1: Understand the projects and technical regulations (standards) designated by METI and confirm the applicable regulations.
2. Step 2: Send a business notification to METI (refer to subsequent compliance documents for details).
3. Step 3: Complete the technical requirements conformity assessment.
   • Circular PSE Mark: Japanese manufacturers and importers conduct self-conformity assessment (i.e., "self-confirmation") and save inspection records. After the product meets the standards, affix the circular PSE mark. (Only manufacturers and importers who have notified METI in advance can affix the PSE mark to products).
   • Diamond PSE Mark: After completing the assessment process consistent with the circular PSE mark, third-party conformity assessment is required.

Note: Products designated by the "Four Major Product Safety Laws" are prohibited from sale in Japan if they do not bear the "PS mark" and the name of the manufacturer/importer who has provided prior notification to METI.

2 Amazon Compliance Document Requirements

In addition to the PSE certification requirements, sellers must submit the following documents to Amazon: business notification, self-inspection report, third-party conformity assessment, abbreviation mark approval, and PSE mark.

Business Notification (NOB)

For any manufacturer or importer dealing with "Electrical Appliances and Materials," notification to the relevant department of the Ministry of Economy, Trade and Industry is required within 30 days of commencing such business. If the business is transferred to another party, the business content changes, or the business is to be terminated, similar notification must be given to the Ministry of Economy, Trade and Industry.

You can refer to the business notification template below to send a notification to METI:

Example 1: Notification of Business for Manufacturing Electrical Appliances and Materials

Key elements to include in the notification:

• 1. Date of Commencement of Business: [Date]
• 2. Classification of Electrical Appliances to be Manufactured: Specify the classification of electrical appliances and materials (refer to the table on the next page).
• 3. Classification of Product Models: As per the attached separate sheet.
• 4. Name and Location of Factory or Business Site for Manufacturing Electrical Appliances: Provide names and addresses for all manufacturing plants.
• 5. For those engaged in the business of manufacturing electrical appliances solely for export: Indicate "None" if intending to sell products in Japan. If products are solely for export (not for sale in Japan), state this clearly.
• Contact Information: Quality Assurance Department, Phone: [Phone Number]

Classification of Electrical Appliances and Materials

Electrical and materials are broadly classified into 20 categories:

This classification table includes businesses that produce or import notified items. Business notifications are issued per category, so a new business notification must be submitted when manufacturing or importing electrical appliances and materials in different categories.

You can click here to view the "Electrical and Material Safety Act Business Implementation Guide" (Version 4.0) for more details on electrical and material classifications.

Self-Inspection Report

Suppliers who have notified METI are obligated to inspect electrical appliances and materials they manufacture or import to confirm compliance with technical requirements. After fulfilling the technical requirements, they must prepare and retain inspection records for three years. According to Article 8, Paragraph (2) of the Act (Article 11, Paragraph (2) of the Enforcement Regulations), these suppliers (manufacturers and importers) must include the following six items in their inspection records:

• Overview of the product name and classification (product type), structure, materials, and performance of the electrical appliances and materials.
• Date and location of inspection.
• Name of personnel.
• Quantity of electrical appliances and materials inspected.
• Inspection method.
• Inspection results.

Specific Electrical and Material Product Inspection Items

Non-Specific Electrical and Materials Product Inspection Items

Additionally, all finished products must undergo a one-by-one technical standard conformity inspection (for all products).

Third-Party Conformity Assessment

If you are selling products that require the diamond PSE mark, you are obligated to undergo a third-party conformity assessment. This involves having your specific electrical appliances and materials evaluated by a registered conformity assessment body, and obtaining and retaining a valid conformity certificate.

The types of products that require third-party conformity assessment are shown in the table below:

3.3 Introduction to Other Legal Requirements and Compliance Items for the Japan Site

When selling products on the Japan site, in addition to complying with Japan's "Four Major Product Safety Laws," you must also pay attention to other legal requirements and compliance items to avoid compliance risks.

3.3.1 Radio Law

Most general radio equipment is affixed with a technical regulation conformity certification mark, indicating that the specific radio equipment complies with the regulations. When selling such equipment, sellers must pay attention to the compliance requirements of the "Radio Law."

Technical Conformity Mark

1. Compliance Certificate: If you plan to sell radio equipment on the Japan site, the certification body will inspect your equipment to confirm its compliance with the technical standards of the "Radio Law." If your equipment meets the standards, the registered certification body will issue you a compliance certificate for technical regulation conformity.
2. Technical Conformity Mark (Giteki Mark): The Technical Conformity Mark (Giteki Mark) is primarily affixed to the model name and manufacturer's identification plate of radio equipment. For wireless LAN devices, this mark is mainly affixed to the bottom of fixed equipment or the identifier of card-type equipment. If the radio equipment you sell does not bear this mark, it may be a violation of the "Radio Law."

GITEKI (MIC) Mark

• The diameter of the mark must exceed 3mm for easy identification without a magnifying glass.
• Radio Certification Mark: Place "R" inside the square as shown in the figure.
• Certification Type Number: The certification type number specific to this equipment.

You can click here to visit the MIC website for information on technical conformity marks and the purchase and use of radio equipment.

3.3.2 Major Laws for Consumer Protection

You can also briefly understand the following laws aimed at protecting consumers on the Japan site:

1. General Policies
   • Consumer Protection Basic Act (Act No. 78 of 1968) [CAA]
   • Consumer Education Promotion Act (Act No. 61 of 2012) [CAA]
2. Product Safety and Labeling Laws
   • Consumer Product Safety Act (Act No. 50 of 2009) [CAA]
   • Food Safety Basic Act (Act No. 48 of 2003) [MAFF]
   • Food Sanitation Act (Act No. 233 of 1947) [MAFF]
   • Act on Control of Household Products Containing Harmful Substances (Act No. 112 of 1973) [MWHL]
   • Consumer Product Safety Act (Act No. 31 of 1973) [METI]
   • Electrical and Material Safety Act (Act No. 234 of 1961) [METI]
   • Act Against Unjustifiable Premiums and Misleading Representations (Act No. 134 of 1962) [CAA]
   • Household Product Quality Labeling Act (Act No. 104 of 1962) [CAA]
   • Food Labeling Act (Act No. 70 of 2013) [MAFF]
3. Contracts and Others
   • Consumer Contract Act (Act No. 61 of 2000) [CAA]
   • Act on Specified Commercial Transactions (Act No. 57 of 1976) [CAA]
   • Product Liability Act (Act No. 85 of 1994) [CAA]

3.3.3 PA TOY Project

The PA TOY policy covers the sale of children's toys on the Japan site. "Children's toys" refer to any product or material designed or intended for use by children under 15 years of age (14 years and under) in play. You can determine if your product falls under the "children's toy" category (and thus is within the scope of the PA TOY policy) based on the following criteria:

• Intended Use: Does the ASIN fall within the scope of use by children?
• Packaging: Is the ASIN marketed towards children?
• Packaging Labeling: Age grouping for children under 15 years old.
• General Recognition: Is the ASIN generally used by children?

The compliance requirements for the PA TOY policy are divided into two categories: "Toys and Games for Children Under 6 Years Old" and "Toys and Games for Children Aged 6-14 Years Old." You can refer to the table below for detailed safety requirements. You only need to submit the corresponding compliance documents for one of these categories to list your product:

For more information, please refer to the additional resources on the Amazon seller platform.

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Course Path

• 2.1 Product Compliance Overview
• 2.2 Restricted Products Policy
• 2.3 Japan Product Compliance Introduction

Product Compliance: Basic Knowledge

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