Can you sell this in Japan?
Costs are indicative ranges.
What went into this one report
One product. Five working days. This is why the findings below are redacted.
Your ticks save in this browser, on this device. Open the file somewhere else and the boxes start empty. If this report is revised, ticks stay with the items they were put against.
What this report does not cover: your own UK-side export paperwork (EORI, export declarations, outbound customs); opening or operating your Amazon seller account; FBA setup; acting as your importer of record; appointing or instructing any specialist on your behalf; and legal advice of any kind. Where a specialist is needed the category is named, not a firm.
This report is advisory. GenkanCo is not a law firm, a certification body, or a registered Japan compliance agent, and nothing here is legal advice or a certification opinion. It identifies where Japanese regulation is likely to apply to this product and what would need resolving, so that you can take those questions to the right specialist. Decisions about compliance, registration and importation remain yours, taken on your own professional advice.
Step 1 of 5 · 2 items
Do these first. Nothing else moves until they are done.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
An indicative cost is given as a range, with the basis stated and the date it was checked, so it can be challenged rather than taken on trust.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
An indicative cost is given as a range, with the basis stated and the date it was checked, so it can be challenged rather than taken on trust.
A timeline is given for the step, separated into what is under your control and what is queue time at the authority.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
An indicative cost is given as a range, with the basis stated and the date it was checked, so it can be challenged rather than taken on trust.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
An indicative cost is given as a range, with the basis stated and the date it was checked, so it can be challenged rather than taken on trust.
A timeline is given for the step, separated into what is under your control and what is queue time at the authority.
The category of specialist to take it to is named, together with the one narrow question to ask them.
Where the source was ambiguous or the record incomplete, that is stated plainly instead of being smoothed over.
What this depends on, and what has to happen before it, is set out so the eleven findings can be worked in order.
Step 2 of 5 · 1 item
These cannot be answered from outside. They cost you nothing but an answer, and they usually decide the work below.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
An indicative cost is given as a range, with the basis stated and the date it was checked, so it can be challenged rather than taken on trust.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
An indicative cost is given as a range, with the basis stated and the date it was checked, so it can be challenged rather than taken on trust.
A timeline is given for the step, separated into what is under your control and what is queue time at the authority.
Step 3 of 5 · 5 items
Required by Japanese law.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
An indicative cost is given as a range, with the basis stated and the date it was checked, so it can be challenged rather than taken on trust.
A timeline is given for the step, separated into what is under your control and what is queue time at the authority.
The category of specialist to take it to is named, together with the one narrow question to ask them.
Where the source was ambiguous or the record incomplete, that is stated plainly instead of being smoothed over.
What this depends on, and what has to happen before it, is set out so the eleven findings can be worked in order.
An absolute performance claim, and 景品表示法 (Act against Unjustifiable Premiums and Misleading Representations) applies to every word of the Japanese listing. The 消費者庁 (Consumer Affairs Agency) can demand objective substantiation; if it is not accepted, the claim is deemed misleading (優良誤認表示) by law.
景品表示法 (the Act against Unjustifiable Premiums and Misleading Representations), Article 5(1) — 優良誤認表示 (misleading representation of superior quality); and 消費者庁 (Consumer Affairs Agency) guidance on 打消し表示 (qualifying statements)
What makes it concrete here is the source listing's own reviews. Buyers report the pad "constantly falls off during use" and that the product "gets paint everywhere", against a 3.2-star average over 578 reviews. A claim the brand cannot support, sitting above reviews that contradict it, is the standard shape of a 優良誤認 (misleading representation) case.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
An indicative cost is given as a range, with the basis stated and the date it was checked, so it can be challenged rather than taken on trust.
A timeline is given for the step, separated into what is under your control and what is queue time at the authority.
The category of specialist to take it to is named, together with the one narrow question to ask them.
Where the source was ambiguous or the record incomplete, that is stated plainly instead of being smoothed over.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
An indicative cost is given as a range, with the basis stated and the date it was checked, so it can be challenged rather than taken on trust.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
An indicative cost is given as a range, with the basis stated and the date it was checked, so it can be challenged rather than taken on trust.
A timeline is given for the step, separated into what is under your control and what is queue time at the authority.
The category of specialist to take it to is named, together with the one narrow question to ask them.
Step 4 of 5 · 3 items
Not the law. Worth doing anyway, and the reason is given.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
An indicative cost is given as a range, with the basis stated and the date it was checked, so it can be challenged rather than taken on trust.
A timeline is given for the step, separated into what is under your control and what is queue time at the authority.
The category of specialist to take it to is named, together with the one narrow question to ask them.
Where the source was ambiguous or the record incomplete, that is stated plainly instead of being smoothed over.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
Step 5 of 5 · 3 items
Checked, and there is nothing for you to do.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
An indicative cost is given as a range, with the basis stated and the date it was checked, so it can be challenged rather than taken on trust.
A timeline is given for the step, separated into what is under your control and what is queue time at the authority.
The category of specialist to take it to is named, together with the one narrow question to ask them.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
An indicative cost is given as a range, with the basis stated and the date it was checked, so it can be challenged rather than taken on trust.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
An indicative cost is given as a range, with the basis stated and the date it was checked, so it can be challenged rather than taken on trust.
Including the ones that came back not applicable. A check that does not apply is still a result.
製造物責任法 (Product Liability Act), Article 2(3)
Applies to you the moment you import. Under Article 2(3) the importer of a product is treated as its manufacturer for liability purposes, so importing this tool into Japan puts [BRAND REDACTED] in the position the factory occupies, not the position a reseller occupies. Nothing to file; it is an exposure to insure and to price. See Tab 1.
消費生活用製品安全法 (Consumer Product Safety Act)
Applies to importers of ALL consumer products, not only specified products. Death, injury requiring 30 or more days of treatment, permanent disability, carbon monoxide poisoning or fire must be reported to the Consumer Affairs Agency within 10 days of becoming aware. Most UK sellers have never heard of this duty. See Tab 1.
景品表示法 (Act against Unjustifiable Premiums and Misleading Representations) (不当景品類及び不当表示防止法)
Applies to every word of the Japanese listing. "Eliminates the need for masking tape" is an absolute performance claim; 優良誤認 (misleading representation of superior quality) exposure runs on whether you can substantiate it, and the 消費者庁 (Consumer Affairs Agency) can require substantiation within a fixed period. The listing's own reviews record buyers saying the pad "constantly falls off" and the product "gets paint everywhere", against 3.2 stars over 578 reviews. See Tab 1.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
関税法 (Customs Act) — reform in force 1 October 2023
Amazon will not act as importer of record in Japan and states so itself; Japanese customs will not accept the marketplace in that role. Since 1 October 2023 a non-resident company can no longer simply nominate an unrelated third party either. You are the importer of record and must appoint an ACP (税関事務管理人). This is the item most likely to be a genuine surprise, and on this product it is the whole administrative burden. See Tab 1.
消費税法 (Consumption Tax Act); FY2026 tax reform
The ¥10 million threshold does not apply to a non-resident holding stock in Japan — FBA storage obliges registration from the first sale. Two FY2026 changes to keep on the radar: platform operators with intermediary sales above ¥5 billion become liable for filing and paying JCT on sellers' behalf; and cross-border mail-order goods at ¥10,000 or under, previously exempt, become subject to JCT. At £13.99 the second touches this product directly if you ship direct. See Tab 1.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
商標法 (Trademark Act)
Ambiguous — refer. Full search below.
関税定率法 (Customs Tariff Act) — tariff schedule
Likely heading HS 9603.40, which covers paint, distemper and varnish brushes together with paint pads and rollers. The exact classification and the applied duty rate are the customs broker's call and no rate has been asserted. Japan's applied tariff schedule should be checked against the finished declaration rather than against a category name.
医薬品、医療機器等の品質、有効性及び安全性の確保等に関する法律 (Act on Securing the Quality, Efficacy and Safety of Pharmaceuticals and Medical Devices) — commonly 薬機法 (the Pharmaceuticals and Medical Devices Act)
Not applicable. The product makes no claim to act on the human body and has no skin contact in normal use. No efficacy language anywhere in the source copy touches 薬機法 (the Pharmaceuticals and Medical Devices Act) territory.
電気用品安全法 (Electrical Appliance and Material Safety Act)
Not applicable. No mains lead, no plug, no battery, no charger, no motor. Confirmed against the listing's structured attribute fields ("Batteries included? No / Batteries Required? No"), not inferred from photographs.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
An indicative cost is given as a range, with the basis stated and the date it was checked, so it can be challenged rather than taken on trust.
電波法 (Radio Act)
Not applicable. No radio transmitter, no Bluetooth, no wireless component of any kind.
食品表示法 (Food Labelling Act)
Not applicable. Not a food and not sold as one.
食品衛生法 (Food Sanitation Act)
Not applicable — and this matters more than it looks. The Act reaches any article intended to come into contact with food, which catches a great many plastic household items that are not themselves food. A paint applicator for walls and ceilings is not one of them, and no part of the source copy positions it near food or drink.
医薬品医療機器等法 (Pharmaceuticals and Medical Devices Act) — 医療機器 (medical devices)
Not applicable. No therapeutic or diagnostic function, and no CE, IVD or medical symbology on the artwork reviewed — which matters, because Amazon Japan detects and suspends on those marks even where the product is plainly not a device.
食品衛生法 (Food Sanitation Act) (おもちゃ規制) / 玩具安全基準 (ST)
Not applicable. Not marketed to children and not a toy. No small-parts or age-marking obligation arises.
植物防疫法 (Plant Protection Act)
Not applicable. Contains no plant material, seeds, soil or wood.
農薬取締法 (Agricultural Chemicals Regulation Act)
Not applicable. Contains and dispenses no chemical of any kind. It applies paint the buyer already owns.
液化石油ガスの保安の確保及び取引の適正化に関する法律 (PSLPG)
Not applicable. No gas component.
家庭用品品質表示法 (Household Goods Quality Labelling Act)
Not applicable, verified against the Consumer Affairs Agency's own schedule rather than assumed. A paint edger is not on the closed list of eight 合成樹脂加工品 (moulded plastic goods), and nothing in the 雑貨工業品 (miscellaneous manufactured goods) group of 30 reaches it. BUT THE SAME SCHEDULE COVERS 塗料 (paint), 接着剤 (adhesives), ワックス (wax), 洗浄剤 (cleaning agents) and 磨き剤 (polishes) — the whole decorating-adjacent range. Sell any of those into Japan and it carries a labelling obligation this one does not.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
有害物質を含有する家庭用品の規制に関する法律 (Act on Control of Household Products Containing Harmful Substances)
The Act sets content limits for named substances in specified household products — principally textiles worn against the skin, aerosols, adhesives, cleaning agents and paints. A plastic hand tool with a fabric applicator pad is not within the specified categories. STATED WITH A CAVEAT: no information was supplied on the pad's fibre composition or whether it carries any finish, and that is the one input that could in principle bring it into scope. See Tab 1.
酒税法 (Liquor Tax Act) / たばこ事業法 (Tobacco Business Act)
Not applicable. Neither an alcoholic beverage nor a tobacco product, and nothing in the range as listed would trigger the retail licence regime.
健康増進法 (Health Promotion Act) — 特別用途食品 (foods for special dietary uses)
Not applicable. Not a food, and the product carries no health or nutrition claim of any kind.
— (comparison, not a gate)
There is no gap, because there is nothing to gap-analyse. A UK brand entering Japan usually arrives holding CE or UKCA marking and assumes it covers most of the distance. Here the opposite is true: this product sits outside the scope of every UK and EU product-safety regime as well. Nothing to obtain, nothing to fund, no lead time.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
An indicative cost is given as a range, with the basis stated and the date it was checked, so it can be challenged rather than taken on trust.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
An indicative cost is given as a range, with the basis stated and the date it was checked, so it can be challenged rather than taken on trust.
A timeline is given for the step, separated into what is under your control and what is queue time at the authority.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
An indicative cost is given as a range, with the basis stated and the date it was checked, so it can be challenged rather than taken on trust.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
An indicative cost is given as a range, with the basis stated and the date it was checked, so it can be challenged rather than taken on trust.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
An indicative cost is given as a range, with the basis stated and the date it was checked, so it can be challenged rather than taken on trust.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
An indicative cost is given as a range, with the basis stated and the date it was checked, so it can be challenged rather than taken on trust.
A timeline is given for the step, separated into what is under your control and what is queue time at the authority.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
An indicative cost is given as a range, with the basis stated and the date it was checked, so it can be challenged rather than taken on trust.
This section names the statute that applies, the specific requirement it creates, and the wording in the source listing that triggers it.
An indicative cost is given as a range, with the basis stated and the date it was checked, so it can be challenged rather than taken on trust.
A timeline is given for the step, separated into what is under your control and what is queue time at the authority.
Listed so nothing above is read as more certain than it is.