Product Recall and Defect Response: A Compliance Playbook for Ecommerce Sellers in Japan

Why This Is a Market-Entry Question, Not an Incident Question

Most overseas brands plan for Japan's product rules at the gate: certification before the goods can be sold, labeling before they reach the shelf. Those are pre-launch problems with pre-launch fixes. Defect response is different in kind. It is triggered after sale, by an event you did not choose, on a clock that starts when you learn of the accident — and the obligations fall on whichever party Japanese law regards as having put the product on the Japanese market.

That last point is where cross-border sellers get caught. Many assume that without a Japanese entity the obligation lands on someone else — the marketplace, the courier, the customer. For direct sales, the Consumer Affairs Agency says otherwise, in writing. The practical consequence is that your market-entry structure — direct shipping, a Japanese distributor, or your own importer of record — is also your recall structure. It decides who reports, who recalls, and whose name the regulator publishes.

This article covers the general consumer-products regime under the Consumer Product Safety Act (消費生活用製品安全法, Act No. 31 of 1973), which reaches almost everything a household buys that is not food, a drug, a cosmetic or a vehicle. Food and cosmetics run on separate statutes and are covered briefly below.

Who Japan Holds Responsible

The Act puts the reporting obligation on businesses that manufacture or import consumer products (Article 35). Retailers are asked, as an effort obligation, to pass accident information up to the manufacturer or importer (Article 34(3)); marketplaces are asked to do the same (Article 34(4)). The legal weight sits with whoever brought the product into the Japanese market.

Selling direct from abroad: you are the importer

The Consumer Affairs Agency and METI's joint 2025 handbook on the accident reporting system states that, under the Act, the act of importing includes an overseas party causing goods to be carried into Japan and received by a general consumer, and that an overseas business selling consumer products directly to Japanese consumers through a transaction digital platform is deemed to be the importer. Its Q&A section then asks the question in its broadest form — a product sold directly by an overseas business to a consumer in Japan through internet mail order causes a serious accident; who must report? — and answers that the overseas business must. The same handbook states that the obligation applies regardless of company size or form.

Selling through a Japanese importer: they hold it

The handbook is equally direct in the other direction: for imported products, the reporting obligation sits with the importer, not the overseas manufacturer. If a Japanese distributor buys your goods, imports them in its own name and resells them, it is the importer and it carries the 10-day obligation. It defines an importer as the party that in substance imports consumer products repeatedly and continuously, and says that where an import agent is involved, the importer is determined from the contracts behind the import. Hiring an importer-of-record service does not by itself move the obligation — the paperwork decides, so read it.

Specified products: the Domestic Administrator

For products subject to Japan's PSC regime (the Electrical Appliance and Material Safety Act carries a parallel requirement for PSE products), the amendments to the four product safety acts that took effect on 25 December 2025 added a structural requirement. An overseas business importing specified products — a "Specified Importer" (特定輸入事業者) under Article 6(2) — must appoint a Domestic Administrator (国内管理人) in Japan to take the measures needed to prevent harm from those products. We cover the appointment mechanics in our guide to PSE and PSC certification. For defect response, two details matter. The Agency's handbook says submitting a Specified Importer's serious accident report via its Domestic Administrator is one option. And METI's April 2026 overview of the amendment includes model contract wording between the two parties under which each must report an accident — in Japan or overseas — to the other and to the authorities, and consult on the response. If you appoint one, that clause is the core of your recall readiness, not boilerplate.

Outside the PSC list there is no Domestic Administrator requirement, but the reporting obligation still applies to you as importer — with no designated party in Japan unless you arrange one.

What Starts the Clock: A Serious Product Accident

The Act defines a product accident (Article 2(6)) as an accident arising from use of a consumer product that either harmed a consumer or damaged the product in a way that risks harm — excluding accidents that are clearly not caused by a defect, and a short Cabinet Order list of accidents handled under other laws. The burden runs one way: an accident whose cause is unknown is still a product accident.

A serious product accident (Article 2(7)) is one meeting the tests in Article 6 of the Enforcement Order:

• Death;
• an injury or illness needing 30 days or more of treatment, or leaving a residual disability of a kind listed in the Cabinet Office Ordinance;
• carbon monoxide poisoning; or
• a fire.

Two boundaries from the Agency's materials save a lot of confusion. Accidents that occur outside Japan are not reportable, even for a model sold in Japan. And "fire" means a fire the fire service has recognised as such; the Agency warns explicitly that a call-out does not mean recognition has been made, and tells businesses to confirm with the fire service. It also treats a case as outside the system where a public body such as the fire service has concluded the accident was clearly caused by the consumer's own carelessness and the product investigation is complete.

The 10-Day Report

Article 35(1) requires a manufacturer or importer that learns of a serious product accident to report the product's name and model, what happened, and the quantities manufactured or imported and sold. The Cabinet Office Ordinance on serious accident reports sets the deadline at 10 days from the day you learned of it, on the prescribed form, to the Commissioner of the Consumer Affairs Agency. The Agency's handbook adds the working rules:

• the day you learned of it counts as day one, and weekends and public holidays count; only if the tenth day itself falls on a weekend, holiday or the 29 December–3 January closure does the deadline move to the next working day;
• the form is completed in Japanese;
• the report goes to the Consumer Affairs Agency, which forwards it to METI or whichever ministry has jurisdiction over the product — you do not need to work out which ministry first.

Read against a cross-border operation, the tight part of the clock is not the form. It is the time between a Japanese customer writing to your support inbox — or a marketplace forwarding a complaint — and someone who understands the definition above reading it. A complaint that says 発火 (ignited) or 火傷 (burn) in a Japanese marketplace message and sits in a queue for four days has used 40% of your deadline before the question "is this reportable?" has been asked.

What Happens After You Report

Reporting is the start of a public process. The Agency states that after receiving a report it and METI publish the accident on their websites promptly — in principle within one week, and its overview material says these publications go out on Tuesdays and Fridays. The legal basis is Article 36. What gets published depends on the case:

• Gas and oil appliances: business name and model are published straight away.
• Other products, where the accident is suspected to be product-related: business name and model are published.
• Other products, where it is not yet known whether the product caused it, or where it is thought not to be product-related and is going to the joint review meeting: product name, accident details, dates, prefecture and harm are published — without the business name or model.

METI may then have the National Institute of Technology and Evaluation (NITE) carry out a technical investigation (Article 36(4)), and the Agency notes that it expects Domestic Administrators to cooperate with NITE's investigations. Results feed a second-stage publication after review by the joint expert meeting. NITE's search tool, SAFE-Lite, which since April 2024 combines its former accident search and recall search, is where accident and recall records remain publicly searchable afterwards.

Note what this does to your incentives. A business that reports on day nine with no product in hand and no view on cause has less to say than one that retrieved the unit on day two. The deadline is the same; what you can usefully say inside it is not.

Deciding to Recall: Duty, Order, and Method

The voluntary duty

Article 38(1) is an effort obligation on manufacturers and importers: where a product accident occurs, investigate the cause, and where it is necessary to prevent harm occurring or spreading, take measures including recall. It applies to product accidents generally, not only serious ones. Sellers and transaction platforms must endeavour to cooperate (Article 38(2)), and must cooperate — no longer merely endeavour — with measures taken under a ministerial order (Article 38(3)).

The order

Article 39 lets the competent minister — for most consumer products, METI — order a manufacturer or importer to recall a product, or take other necessary measures, where a defect has caused a serious product accident or there is otherwise an imminent danger of serious harm. The minister must publish the order (Article 39(2)). Breaching it carries up to one year of imprisonment or a ¥1 million fine for the individual (Article 58), and a fine of up to ¥100 million for the company (Article 60). Orders are the backstop; the system is built on businesses acting before one is needed.

What a recall actually is

Japan's working definition, as set out in the Agency's handbook, is wider than "take the product back". It covers four types of action:

1. stopping manufacture, distribution and sale, and retrieving stock from the distribution and retail stages;
2. giving consumers appropriate information about the risk;
3. alerting consumers, including usage precautions to prevent similar accidents;
4. exchanging, repairing (inspection, repair, part replacement) or taking back products consumers already hold.

For notifying consumers, the handbook separates cases where you can identify who bought the product — direct mail, phone, email, visits, or contact through distributors — from cases where you cannot: newspaper notices, press releases, broadcast, magazines and flyers, your own website, in-store notices. Direct ecommerce sellers hold an advantage offline brands lack: an order database. The handbook advises establishing in advance how far you can trace distribution to the end consumer.

When a manufacturer or importer starts a recall, the handbook asks it to report to METI's Product Accident Countermeasures Office using a set form, and to submit progress reports periodically; recalls are then listed on METI's site and in SAFE-Lite. For the detailed method, the Agency's handbook points to METI's Recall Handbook 2022. And the costs of all this — retrieving stock, notifying buyers, replacing units — are a separate question from liability to injured consumers, as we explain in our guide to product liability insurance for Japan importers: standard PL cover typically does not pay for the recall itself.

Where the Marketplace Comes In

Sellers on Amazon.co.jp, Rakuten Ichiba or Yahoo! Shopping should expect the platform to move in parallel with, and sometimes ahead of, the regulator.

The statutory track. Article 34(1) puts an effort obligation on manufacturers, importers and retailers to collect accident information and pass it to consumers. The Act also gives transaction platforms defined roles: an effort obligation to cooperate with a manufacturer's or importer's information collection (Article 34(2)), to notify the manufacturer, importer or retailer of serious accidents they learn of (Article 34(4)), and to cooperate with recalls (Article 38). Article 39-2 lets the competent minister request a platform to stop a product's sale where the manufacturer or importer cannot be identified, cannot be located, or otherwise cannot be expected to take the necessary measures — and a platform that complies is not liable to the seller for the loss (applying Article 32-3(3)).

The voluntary track. Japan's Product Safety Pledge, launched on 29 June 2023, is a public–private commitment between regulators and marketplace operators. As of 30 January 2026 it has nine signatories: Amazon Japan (Amazon.co.jp), eBay Japan (Qoo10), au Commerce & Life (au PAY Market), Mercari, Mobaoku, LINE Yahoo (Yahoo! Shopping and others), Rakuten Group (Rakuten Ichiba and Rakuma), Mitsui Fudosan (&mall) and Whaleco Japan (Temu). Signatories commit to remove recalled or unsafe product listings within two business days of a regulator's request and report back what they did, and to build and maintain systems to stop recalled products being re-listed. The Agency publishes the results: in December 2025, 17 listings were identified on regulators' requests and all 17 were removed within the two-day window, with LED lighting, DC power supplies and lithium-ion batteries the main product groups. Rakuten states on its own safety page that it passes recall information published by government bodies on to its shops.

The operational point: once a recall is public, your listings for that model are likely to be removed on the marketplace's timetable, and relisting is designed to be hard. Plan the customer-service and inventory side of a recall on the assumption that the storefront goes dark first.

Food and Cosmetics Run on Different Rails

If your range includes food or cosmetics, the consumer-products regime above is not the one that governs recalls of those goods.

• Food. Article 58 of the Food Sanitation Act requires a business that recalls food, additives, or food-contact apparatus and packaging on specified grounds to notify the prefectural governor without delay that it has started a recall and how it is progressing; the governor passes it on to the national government. The system dates from the 2018 amendment and has applied since June 2021. See our guide to Food Sanitation Act compliance for who the business operator is in an import chain.
• Cosmetics. Article 68-11 of the Pharmaceutical and Medical Device Act requires the marketing authorization holder of cosmetics (among other products) to report to the Minister of Health, Labour and Welfare when it starts a recall and how it progresses. That duty sits with the MAH, which is one of the reasons the choice of MAH matters so much — see our guide to marketing authorization holders for cosmetics.

A Defect-Response Playbook, in Order

1. Name the importer for each channel. Direct-to-consumer from abroad: you. Through a Japanese distributor that imports: them. Through an import-agent service: whatever the contracts say — check them. Write the answer down per channel, because many brands run two or three at once.
2. If you sell PSC products, treat the Domestic Administrator contract as your recall contract. METI's model clauses on mutual accident reporting and consultation are a floor. Add who drafts the Japanese report, who files it, and who pays for retrieval.
3. Route Japanese complaints to someone who knows the definition. Customer messages, marketplace case notes, reviews and retailer forwards all count as ways you may "learn of" an accident. Build a short Japanese keyword triage — ignition, smoke, burn, injury, hospital, carbon monoxide — that escalates the same day.
4. On a possible serious accident, start the clock on day one. Confirm the facts, ask whether the fire service has recognised a fire, request the unit, and prepare the Japanese form in parallel rather than in sequence. The ten days include the weekend.
5. Assemble the cause picture before publication. The Agency's publication table rewards clarity: for products other than gas and oil appliances, where cause is still undetermined, the business name is not published at first. Get the product examined and keep records of what you found.
6. Decide on recall scope with the order database open. Identify affected lots or date ranges, map how many units went to identifiable buyers, and pick notification methods accordingly. Report the recall start to METI and keep progress reports going.
7. Coordinate with every marketplace the same day. Expect listings to be removed and relisting to be blocked. Prepare customer-service replies, refund or exchange mechanics and stock quarantine at your Japanese warehouse before the public notice, not after.
8. Price it before you need it. Recall costs sit outside standard PL insurance. Decide whether you carry recall cover, and in whose name, while you are negotiating your distributor or 3PL contracts.

Where we fit is narrow and worth stating plainly. LAUNOVA runs Japanese storefronts and marketplace operations for overseas brands. We are not a law firm, a recall contractor, a testing laboratory or a Domestic Administrator; we do not file accident reports on a client's behalf, we do not make recall decisions, and we do not take on importer responsibility. Those decisions belong to the importer of record, with Japanese counsel and, where relevant, your Domestic Administrator. What we do is build the Japanese-language operation around your store — marketplace accounts, customer messages, storefront changes — so that an accident complaint reaches the right person on day one rather than day eight, and so that a recall notice can go live across your channels quickly. If you are working out how to sell cross-border into Japan and want that routing settled before launch, tell us what you are planning to sell. Scope and pricing are quoted against the work rather than published as a rate card.