Yes, in two distinct regimes, and the name is not a formality. Whoever appears as the responsible party under the Electrical Appliance and Material Safety Act (電気用品安全法) PSE marking becomes Japan's registered 届出事業者 (Notifying Supplier), and whoever appears in a food label's 輸入者 (importer) or 販売者 (seller) field becomes the party regulators and courts treat as liable for that product in Japan.
Does naming an importer on a Japan label create legal obligations, or is it just information?#
It creates obligations. In both the electrical-product and food regimes, the name printed on the label is the legal identity of a specific responsible party, not a courtesy disclosure to the consumer. Once a company's name is affixed to a PSE mark or entered in a food label's operator field, that company steps into a defined legal role with duties that continue after the shipment clears.
This distinguishes label naming from most other import paperwork. A customs declaration or a bill of lading is transactional and closes when the shipment is released. A label field tied to a Notifying Supplier or a food business operator role is structural: it attaches obligations that recur annually and liability that attaches to future events, such as a recall, years after the goods entered Japan. Anyone structuring a Japan import project should treat the question of whose name goes on the label as a deliberate scoping decision inside IOR / EOR service structuring, not an incidental detail settled at the printing stage.
What happens when your company's name appears on a PSE label?#
The named party becomes the METI-registered 届出事業者 (Notifying Supplier) and takes on ongoing compliance duties, not a one-time filing. Article 3 of the Electrical Appliance and Material Safety Act (電気用品安全法) requires anyone manufacturing or importing a designated electrical appliance to notify Japan's Ministry of Economy, Trade and Industry (METI) within 30 days of starting that business. The name that goes on the PSE mark is the name METI holds as the notifying party.
Two obligations follow directly. Article 9 of the same Act requires the Notifying Supplier to retain the conformity test certificate for the product. Separately, the Act's enforcement regulations set a statutory minimum retention period of three years for self-inspection records; treat that three-year figure as the verified floor, and do not rely on any longer period without confirming it against the current enforcement regulations, since practices beyond the statutory minimum vary by product category and have not been independently verified here.
Beyond retention, the Notifying Supplier role carries recurring exposure: METI can request records or conduct an audit against a registered notifying party at any point the product remains on the market, and a design or category change can trigger renewal obligations. This overlaps with, but is legally separate from, wireless certification questions that come up on the same product line; see the PSE and 技適 (Giteki) dual-certification post for how the two regimes interact when a device also carries wireless capability.
What happens when your company's name appears in the food label's 輸入者/販売者 field?#
The named party is treated as the responsible party for recall and product-liability purposes, and it must be a Japan-resident entity. Before that label question even arises, the Food Sanitation Act (食品衛生法) Article 27 requires an import notification to the quarantine station covering the point of customs clearance, filed before the goods clear. That filing obligation and the labeling obligation sit on the same party, which is why the two cannot be structured separately; the food import business notification post covers the notification mechanics in full.
The Food Labeling Standards (食品表示基準) require imported processed food to carry, among other mandatory items, a 食品関連事業者 (food business operator) shown in the label as 輸入者 (importer) or, by agreement, as 販売者 (seller). That field must carry a Japan address. This is not a gap a non-resident company can structure around: a non-resident cannot be named in that field and cannot act as the food import declarant at all, confirmed by quarantine and Customs guidance rather than left as an open drafting question. Full mandatory-item detail is covered in the food labeling standards post.
The exposure this creates is not administrative. A named operator faces disposal-order exposure under Food Sanitation Act Article 54 (廃棄命令), and separately, the named party is treated as the responsible party under the Product Liability Act (製造物責任法) for recall and liability purposes. Both of those consequences outlive the individual shipment; when a defect surfaces in product already sold, the label's named party, not the exporter or brand owner behind it, is the entity regulators and claimants engage first. The product recall coordination post covers how that engagement runs in practice.
Can an ACP appointment substitute for a PSE Notifying Supplier or a food label operator?#
No. An Attorney for Customs Procedures (税関事務管理人) appointment under Customs Act (関税法) Article 95 authorizes a Japan-resident agent to handle customs procedures on behalf of a non-resident importer; it does not create a Notifying Supplier and does not create a Japan-resident food operator. These are separate legal roles governed by separate statutes, and a customs procedural appointment satisfies none of them.
For a PSE-regulated item, the DENAN notification obligation under Article 3 stays with the non-resident manufacturer or importer, which by definition has no Japan establishment from which to file or to retain records. For food, the outcome is stricter still: a non-resident cannot be the food import declarant under any procedural appointment, ACP included, because quarantine guidance bars it outright to preserve enforceability of a disposal order. In both cases, the company still needs a Japan-resident party willing to take on the ongoing duties described above, priced and scoped on its own terms rather than assumed as a byproduct of an import engagement.
Key points:
(a) A label naming a party as PSE Notifying Supplier or as a food label's 輸入者/販売者 creates recurring legal duties (record retention, audit cooperation, renewal), separate from and outlasting the individual import transaction.
(b) The food label's operator field legally requires a Japan-resident party; a non-resident cannot be named in that field and cannot be the food import declarant under any structure, including an ACP appointment.
(c) Naming a party on a PSE or food label assigns product-liability and recall exposure to that party specifically, under the Product Liability Act and, for food, under the Food Sanitation Act's disposal-order provision, so the decision should be scoped and priced separately from the underlying import service.
Frequently Asked Questions#
Does putting my company's name on a Japan product label cost anything beyond the one-time import fee?
Yes, if the label field triggers a Notifying Supplier or food operator role. Both roles carry recurring compliance work, such as record retention, audit cooperation, and periodic renewal, that continues as long as the product remains on the Japan market, separate from the fee for the shipment itself.
Can a non-resident company be named as the importer on a Japan food label?
No. The Food Labeling Standards require the 輸入者 or 販売者 field to carry a Japan address, and quarantine and Customs guidance bars a non-resident, or that non-resident's customs procedural agent, from acting as the food import declarant. A Japan-resident party must hold that role.
If I use an ACP structure for customs clearance, does that also cover my PSE or food labeling obligations?
No. An ACP appointment under Customs Act Article 95 covers customs procedures only. It creates no PSE Notifying Supplier registration and no Japan-resident food operator status; those are separate legal roles under separate statutes and need their own party and their own scoping.
Conclusion#
Naming a party on a Japan product label is a legal structuring decision with consequences that run well past the shipment it accompanies. Whether the field is a PSE mark or a food label's 輸入者/販売者 line, the named party takes on recurring compliance duties and product-liability exposure that should be identified, scoped, and priced before the label is printed, not discovered afterward.
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: September 2026.