No. Appointing an Attorney for Customs Procedures (ACP, 税関事務管理人) under Article 95 of the Customs Act (関税法) has no bearing on the Domestic Administrator (国内管理人) requirement under the Consumer Product Safety Act (消費生活用製品安全法). The two are separate legal appointments under separate Acts, created for separate purposes, and neither substitutes for the other. A marketplace seller of a specified product typically needs both, running in parallel.
Does Appointing an ACP Satisfy the Domestic Administrator Requirement?#
No, and the reason is structural, not a matter of degree. ACP under Article 95 of the Customs Act governs who may lawfully handle customs clearance procedures on behalf of a non-resident importer; it says nothing about, and creates no obligation under, the Consumer Product Safety Act. The Domestic Administrator requirement arises from a completely different statute aimed at consumer safety, not customs procedure. An ACP appointment being on file with Japan Customs does not appear anywhere in a Consumer Product Safety Act filing, and a Domestic Administrator appointment does not appear anywhere in a customs declaration. This question was left open in Does a Baby Bed Rail Need a Japan Safety Mark in 2026?, which flagged it without resolving it; the answer is that the two instruments simply do not intersect.
What Is a Domestic Administrator Under the Consumer Product Safety Act?#
The Domestic Administrator (国内管理人) is a Japan-resident contact a foreign business must appoint before it can lawfully apply the PSC safety mark and sell certain products in Japan. the Consumer Product Safety Act's Article 6, Item 2 specified-importer provision (第6条第2号), effective from December 25, 2025, defines a specified importer (特定輸入事業者) as a foreign business that imports a specified product (特定製品) and sells it directly to Japanese consumers, typically through a marketplace listing rather than through a Japan-resident distributor. A specified importer must appoint the Domestic Administrator before it can apply the mark; filing without one means the product cannot carry the mark and cannot lawfully go on the market. Infant bed guards (乳幼児用ベッドガード) and strollers (ベビーカー) were designated specified "Child PSC Mark" products effective July 8, 2026, which is why marketplace sellers of infant and juvenile products are running into this question now.
What Does an ACP Appointment Actually Cover Under the Customs Act?#
Attorney for Customs Procedures (ACP) An ACP appointment under Article 95 of the Customs Act creates a Japan-resident procedural agent for a non-resident importer, so that entity can be named as the importer of record on the import declaration while a Japan-resident handles the customs-facing steps. The non-resident remains the legal importer on the declaration; the ACP agent's role is limited to customs clearance procedure and correspondence with Japan Customs. It carries no role in, and creates no obligation under, the Consumer Product Safety Act, DENAN, or any other product-regulation framework. The mechanics of when this structure fits, and how it differs from an importer-of-record arrangement, are covered in ACP - Attorney for Customs Procedures in Japan: When You Need One Instead of a Full Entity (2026) and in IOR vs ACP for Japan Imports - Which Structure Do You Need in 2026?.
How Do ACP and the Domestic Administrator Fit Together for a Marketplace Seller?#
They run side by side, each handling its own half of the transaction, because the Consumer Product Safety Act deliberately keeps the non-resident sales route open rather than closing it off the way food-safety rules do. A non-resident brand selling a specified product through a marketplace can hold an ACP appointment for the customs and import declaration side, and separately register as a specified importer with a Domestic Administrator appointment for the consumer-safety side. Neither filing does the other's job, and neither can be dropped in favor of the other. A brand that has an ACP agent in place and assumes that resident presence covers the safety-mark filing as well will find the product cannot lawfully carry the PSC mark until the separate Domestic Administrator appointment is made.
Key points:
(a) ACP under Article 95 of the Customs Act and the Domestic Administrator under Article 6, Item 2 of the Consumer Product Safety Act are separate instruments, filed separately, under separate Acts, and one is never a substitute for the other.
(b) A non-resident brand selling a specified product direct to Japanese consumers through a marketplace can generally keep both appointments running in parallel: ACP for the customs and import declaration side, plus specified-importer registration and a Domestic Administrator for the consumer-safety side.
(c) An Importer of Record structure is a different route entirely that removes the specified-importer question by putting a Japan-resident party in the chain as the actual importer, at the cost of shifting product-liability exposure under the Product Liability Act (製造物責任法) onto that provider.
Does DENAN Have Its Own, Different Domestic Administrator Concept?#
Yes, and the two must not be conflated even though the terminology looks similar. The Electrical Appliance and Material Safety Act (電気用品安全法), commonly called DENAN, has its own Domestic Administrator concept tied to its own notifying-supplier (届出事業者) registration framework for electrical products, entirely separate from the Consumer Product Safety Act's version. A product that is both electrical and a designated child-safety specified product, a nightlight built into a bed guard is one example, needs both frameworks satisfied independently: a Domestic Administrator appointment plus notifying-supplier registration under DENAN for the electrical component, and a separate specified-importer registration plus Domestic Administrator appointment under the Consumer Product Safety Act for the child-product designation. The DENAN notifying-supplier mechanics are covered in PSE Certification for Foreign Manufacturers - DENAN and the Notifying Supplier Model.
Does an Importer of Record Structure Remove the Domestic Administrator Requirement?#
Importer of Record (IOR) An Importer of Record arrangement dissolves the specified-importer question rather than answering it within the existing structure. Putting a Japan-resident IOR provider in the chain as the actual importer removes the "foreign business selling direct to consumers" fact pattern that the Domestic Administrator rule is aimed at in the first place, because the seller of record is no longer a non-resident. This is a genuinely different structure from ACP, not an alternative version of it: under ACP the non-resident stays the named importer and files through a resident agent, while under IOR a Japan-resident party takes over the importer role itself. The trade-off is that the notifying and registered-party role, and general product-liability exposure under the Product Liability Act, moves onto the IOR provider rather than staying with the brand, which is a commercial decision worth weighing against keeping the non-resident specified-importer route with its own ACP appointment and Domestic Administrator filing.
Frequently Asked Questions#
If we already have an ACP agent in Japan, do we still need a separate Domestic Administrator?
Yes. The ACP appointment covers customs clearance procedure under the Customs Act and has no standing under the Consumer Product Safety Act. A specified importer selling a specified product direct to Japanese consumers needs a separate Domestic Administrator appointment, and the product cannot carry the PSC mark until that appointment is in place.
Can one Japan-resident person or entity hold both the ACP appointment and the Domestic Administrator role?
The two are separate legal instruments filed under separate Acts, so the same Japan-resident party can be named in both, but each filing is made and recorded independently. Holding both roles does not merge the appointments into one filing or remove the requirement to make each one on its own terms.
Does using an Importer of Record instead of ACP make the Domestic Administrator requirement go away?
Yes, because an IOR structure puts a Japan-resident party in as the actual importer, which removes the non-resident direct-to-consumer fact pattern the specified-importer rule targets. That comes with a trade-off: the notifying-party role and product-liability exposure under the Product Liability Act shift to the IOR provider instead of staying with the brand.
Conclusion#
ACP and the Domestic Administrator are answers to different questions asked by different Acts: one is about who may file customs procedures, the other is about who is the Japan-resident consumer-safety contact before a mark can be applied. A marketplace seller of a specified product generally needs both running in parallel rather than treating one as covering the other, unless the seller restructures around an Importer of Record, which removes the question rather than answering it.
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.