A foreign manufacturer of drones, networked robots, or factory automation hardware typically starts with a customs question: who imports the equipment into Japan, and who is named on the import declaration. That question has a clean answer through Importer of Record (IOR) structuring. What trips up this product category specifically is the assumption that solving the import question also solves the "can we use this device in Japan" question. It does not. Depending on what the equipment actually does, at least one additional regulatory layer sits on top of the import structure, and the layer differs by device type. This post walks through which layer applies to which category, and why the IOR structure and the use-clearance question have to be tracked separately.
The IOR Layer: What It Actually Solves
Under the standard IOR structure, Aplash becomes the legal importer of the equipment, not an agent acting on the client's behalf. Aplash purchases the goods from the overseas seller, takes title before the goods reach customs, files the import declaration (輸入申告) in its own name under the Customs Act (関税法), pays the applicable customs duties and import consumption tax, and then re-sells the equipment to the Japan-based buyer. Aplash issues a qualified invoice (適格請求書) on the re-sale, which allows the Japan buyer to recover the import consumption tax as input credit.
This structure answers exactly one question: who has legal title and customs liability at the moment the goods cross the border. It says nothing about whether the device, once landed, is legal to switch on, connect to a network, or fly. That is the gap this post addresses, and it is the gap that makes drones and robotics a distinct vertical from the aerospace parts and industrial machinery categories already covered on this blog.
Why This Category Is Different From Aerospace Parts and Industrial Machinery
Aerospace components and heavy industrial machinery are, in the overwhelming majority of cases, physical goods that clear customs and then go straight into installation or maintenance. The compliance work is concentrated at the border: correct HS classification, valuation, and in the aerospace case, screening for aviation-parts traceability and airworthiness documentation.
Drones, networked robots, and automation equipment behave differently after they clear customs, because a meaningful share of this category does one or both of two things that a stationary machine tool does not: it transmits over radio, and in the case of drones, it flies as an aircraft under Japanese civil aviation rules. Neither of those two facts is a customs question. Both are use-of-device questions that arise only after the IOR transaction is complete, and both are regulated by different authorities than the one that governs the import declaration.
Layer 1: Radio Certification for Any Device With a Wireless Module
Any drone, mobile robot, or automation unit with a built-in radio transmitter (Wi-Fi, Bluetooth, proprietary RF control link, cellular modem, or similar) falls within the scope of the Radio Act (電波法). Under this law, a radio-transmitting device generally cannot be legally operated in Japan unless the transmitter has passed Technical Conformity Certification, commonly referred to in Japan as TELEC certification (技適). This is a certification of the device's radio module against Japanese technical standards, administered under the Ministry of Internal Affairs and Communications (MIC) framework, and it is separate from, and unrelated to, the customs clearance of the physical unit.
The practical consequence for an IOR client: Aplash importing the drone or robot resolves customs title and declaration. It does not certify the radio module. A unit that cleared customs cleanly can still be non-compliant to operate if it transmits on frequencies or at power levels not covered by an existing certification, or if it has never been certified for the Japanese market at all. Radio Act exposure applies to consumer drones, warehouse AMRs and AGVs with wireless coordination links, remote-monitored industrial robots, and any automation equipment that reports telemetry over a wireless connection. This is covered in depth in our dedicated post on Radio Act and TELEC certification, and it should be scoped as a parallel workstream to the IOR engagement, not an afterthought once the equipment has already landed.
Layer 2: Civil Aviation Rules for Drones Specifically
Drones carry a second layer that ordinary robotics and automation equipment does not: they are aircraft under Japanese civil aviation regulation, administered by the Ministry of Land, Infrastructure, Transport and Tourism (MLIT). This layer governs registration of the airframe, remote identification broadcast, and the operating rules that apply once the drone is actually flown, such as altitude limits, distance from people and property, restrictions near airports and event sites, and licensing requirements for the pilot depending on the type of operation. This entire framework sits on top of both the IOR import question and the Radio Act certification question. A drone can be correctly imported under IOR and have a fully certified radio module, and still be unable to fly legally in Japan until it is registered with MLIT and operated under the applicable flight rules.
Aplash's IOR service does not extend to MLIT drone registration or flight authorization; that is a distinct regulatory process the end operator in Japan generally handles directly, and it should be scoped separately from the import engagement so the client understands the full sequence: customs clearance, then radio certification, then aviation registration and flight compliance, each governed by a different authority.
One additional point on drones specifically: because certain drone platforms and components can raise export control considerations, any dual-use or export-control screening question is a separate analysis handled case by case against the specific technical specification and end-use, and is not something this post, or the IOR structure itself, resolves. Where that question arises, it needs to be scoped on its own before, not after, the import transaction proceeds.
Layer 3: Machinery Safety for General Industrial Robotics and Automation
Manufacturing line robots, robotic arms, and most AGV/AMR deployments that stay within a factory network typically do not carry the aviation layer at all, since they are not aircraft. Where they do carry wireless coordination or remote control, the Radio Act layer above still applies. Beyond that, the compliance question for this sub-category shifts toward machinery and workplace safety standards: guarding, emergency stop design, collaborative-robot safety zones, and the general product safety expectations that apply to industrial equipment installed in a Japanese facility. This is a narrower and more procedural layer than the radio or aviation questions, but it is still a distinct workstream from the IOR transaction, and it is worth confirming early which of the three layers, radio, aviation, or machinery safety, actually applies to the specific unit being imported, since not every device in this vertical carries all three.
How the Layers Stack, By Device Type
The reader's own device determines which of the following applies, and more than one layer can stack on a single unit:
(a) A drone with a wireless control link carries all three: IOR resolves customs and title; Radio Act certification is required before the radio module can be legally operated; MLIT registration and flight rules apply before the airframe can be flown.
(b) A wirelessly networked factory robot or AMR carries two: IOR resolves customs and title; Radio Act certification is required for the wireless module. No aviation layer applies, since the unit does not fly. Machinery safety standards apply to the physical installation.
(c) A wired, non-networked industrial machine (a stationary robotic arm on a hard-wired control system, for example) carries one: IOR resolves customs and title. No Radio Act exposure, since there is no transmitter. Machinery safety standards still apply to installation, as with any industrial equipment.
Scoping the Engagement Correctly
The single most common structuring error in this vertical is treating the IOR engagement as the entire compliance answer. It is the customs and title answer only. Before scheduling an import, confirm (a) whether the device has a wireless transmitter of any kind, which determines whether Radio Act certification needs to be scoped as a parallel workstream, and (b) whether the device is a drone intended to be flown in Japan, which determines whether MLIT registration and flight-rule compliance needs to be scoped as a separate, sequential workstream after import and radio certification are both resolved. Getting this sequencing right at the outset avoids a scenario where equipment lands in Japan, clears customs cleanly, and then sits unused because the radio module was never certified or the airframe was never registered.
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: 2026-07.