No. Importing a sealed, retail-packaged, ambient-stable food product and reselling it unopened does not require a business notification (営業届出) under the Food Sanitation Act (食品衛生法). The Act expressly lists "the business of importing food or additives" as exempt from the notification requirement. This is separate from the per-shipment import notification every food shipment must still clear at the border.
What Is the Business Notification (営業届出) Requirement Under the Food Sanitation Act?
The business notification (営業届出) is a filing under Article 57 of the Food Sanitation Act (食品衛生法) that a food business operator submits to the local health center (保健所) covering the location of its facility. It applies to any operator outside the smaller list of businesses that instead require a full business license (営業許可, Article 55). Article 57 also names specific categories that are exempt from filing anything at all, and the import business is one of them.
Sitting alongside Article 57 is a separate, narrower list under Article 55 covering 32 prefectural license categories, none of which covers the act of importing or the resale of an unopened retail package. The licence categories that do matter for a food business are activity-based: manufacturing the product, sealing or bottling it, or opening and repacking product that someone else manufactured. None of those activities describes an importer moving a sealed carton from the port to a warehouse to a buyer.
Why Is Importing Food Exempt From the Business Notification?
The exemption exists because the Food Sanitation Act treats notification and licensing as tied to what a business does to the product, not to the fact that it crossed a border. The business of importing food or additives (食品又は添加物の輸入業) is written into the Article 57 exempt list by name, alongside a second, product-characteristic exemption for shelf-stable sealed packages. The government's own published examples of exempt sealed products include instant cup noodles, bottled beverages, and packaged snacks, the same category most retail food imports fall into.
A pure import-and-resell operation that never opens, repacks, or subdivides the sealed package stays inside both exemptions. The activity that pulls a business out of the exemption and into licence territory is repacking: opening a sealed container made under a manufacturing license and redistributing it into smaller units is its own licensed subdividing business (小分け業) under Article 55. Applying a Japanese-language label to an already-sealed package, on the other hand, does not cross that line, because the seal itself is never broken.
Key points:
(a) A pure import-and-resell business handling sealed, ambient-stable retail packages needs no business licence (営業許可) and no business notification (営業届出). (b) The exemption sits outside the Food Sanitation Act's HACCP-based hygiene management duty as well; the import/additive business is listed among the operators that duty does not reach, though general hygiene management still applies. (c) The moment a business opens, subdivides, or repacks a sealed container, it exits the exemption and enters the licensed subdividing business category (小分け業) under Article 55, which brings facility standards and a mandatory food sanitation supervisor (食品衛生責任者) with it.
Business Notification (営業届出) vs. Import Notification (食品等輸入届出): What Is the Difference?
These are two separate filings under two different articles of the same law, and confusing them is the most common mistake in a food import plan. The business notification (営業届出, Article 57) is a one-time, business-level filing to the health center that a pure importer is exempt from. The import notification (食品等輸入届出) is a per-shipment filing to the quarantine station (検疫所) under Article 27 of the Food Sanitation Act, and it applies to every food shipment entering Japan regardless of the Article 57 exemption above.
The import notification has to be submitted before customs clearance, and the filing anchor moves with the port: it goes to the quarantine station covering wherever the shipment actually clears customs, not the importer's registered address. The business notification, where it applies to a different kind of operator, works the opposite way: it goes to the health center covering that operator's own facility address, and it never moves with the cargo. A business changing its entry port changes which quarantine station reviews the shipment; it never changes which health center, if any, applies to the business itself. Our companion piece on plant and animal quarantine permits covers the parallel MAFF-side filing that agricultural products face at the same border step.
Because these two filings sit at completely different points in the supply chain, being exempt from one says nothing about the other. A food importer that never files a single business notification in its operating life will still file an import notification on every shipment that crosses the border.
Where a Business Notification Does Apply Downstream
A business notification does attach further down the chain, typically to a domestic reseller such as a mail-order or e-commerce operator handling the product after import, and that filing brings obligations with it that a pure importer never takes on. Once a business notification is required, it carries a mandatory appointment of a food sanitation supervisor (食品衛生責任者) and pulls the operator into HACCP-based hygiene management, the general hygiene management duty the Food Sanitation Act imposes on notified businesses. The exemption on the import side is therefore worth more than the filing paperwork alone suggests, because it is also an exemption from that supervisor appointment and hygiene management scope.
Whether a particular downstream reseller of sealed product needs to file is a determination the local health center makes, and it can vary by jurisdiction. A business planning a domestic resale or mail-order layer on top of the import should confirm its own notification status with the relevant health center before assuming the import-side exemption extends to it, since the two are separate operators.
What Else Applies to a Food Import Regardless of Licensing Status
Two obligations apply to every food import into Japan and neither depends on whether a business notification or licence is required. The first is the per-shipment import notification (食品等輸入届出) discussed above, which brings its own exposure: a shipment can be subject to an order to discard or destroy product (廃棄命令) under Article 54 of the Food Sanitation Act if it fails inspection. The second is the retail label.
Japan's Food Labelling Standards (食品表示基準) require every retail food label to name a food business operator (食品関連事業者), shown as either the importer (輸入者) or the seller (販売者), and that party must carry a Japan address. A non-resident company cannot fill this role. This means the importer of record for a food shipment has to be Japan-resident from the outset, which is a structural question separate from the licensing question this article answers. Our guide on Japan IOR structures for food and beverage brands covers how that Japan-resident importer role gets established, and the same underlying issue shows up in a different product category in our Japan IOR guide for supplements and nutraceuticals. If you already know your business needs a Japan-resident importer of record in place, our importer of record and employer of record service covers how that structure gets built.
Before assuming a product is exempt from every food-safety filing, it is also worth checking whether the product category itself triggers a separate certification requirement; our overview of PSE, PSC, and food safety certification triggers walks through which product types carry that extra layer.
Frequently Asked Questions
If I import sealed snacks and beverages to resell in Japan, do I need to register with a health center at all?
No. Importing and reselling a sealed, ambient-stable retail package, without opening, repacking, or subdividing it, falls into the exempt category under Article 57 of the Food Sanitation Act and requires no filing with the local health center. You still need to file the separate, per-shipment import notification with the quarantine station before each shipment clears customs.
Does applying a Japanese label to my imported product count as repacking and trigger a licence requirement?
No. Affixing a label to a package that stays sealed does not break the seal and does not fall into the licensed subdividing category (小分け業) under Article 55 of the Food Sanitation Act. The line is the physical seal: opening the original container to repack or subdivide the contents is what triggers a licence, not the label itself.
Since I don't need a business notification, can I act as my own importer of record even though I'm based overseas?
No, and this is unrelated to the notification exemption. The Food Labelling Standards require the food business operator named on the retail label, whether shown as importer or seller, to carry a Japan address, so a non-resident cannot serve as the importer of record for a food shipment regardless of its licensing or notification status.
Conclusion
A pure import-and-resell business handling sealed, shelf-stable food faces no business licence and no business notification requirement under the Food Sanitation Act, and sits outside the HACCP-based hygiene management duty. That exemption never touches the per-shipment import notification at the quarantine station, which every food shipment must still clear, or the requirement for a Japan-resident party on the retail label.
This article is informational only and does not constitute legal, tax, or regulatory advice. Consult a qualified advisor before acting on the content. Last updated: August 2026.