A bicycle-use battery pack gets no PSE exemption. The Electrical Appliance and Material Safety Act (電気用品安全法, DENAN) excludes lithium-ion battery packs used in automobiles, mopeds, medical equipment, and industrial machinery from PSE scope, but bicycle-use packs are not on that closed list. A compliant power-assisted bicycle (電動アシスト自転車) is legally a bicycle, not a moped, so its battery pack falls inside PSE scope.
Does Japan's PSE Law Exempt Bicycle-Use Lithium-Ion Batteries?#
It does not, and the claim that it does is the most common vendor error on an e-bike sourcing file. Some overseas component suppliers describe lithium-ion packs as "自転車用" (bicycle-use) and market that label as if it removes the product from Japan's Product Safety Electrical Appliance and Material (PSE) certification requirement. That claim is a vendor assertion, not a verified regulatory position, and it does not survive a reading of the cabinet order text.
The cabinet order under the DENAN Act (電気用品安全法施行令) sets out the actual PSE product list, and the lithium-ion rechargeable battery entry names four specific uses that fall outside scope. Bicycle-use is absent from that list by design. Anyone quoting a sourcing deal on the assumption that a bicycle-labeled pack is PSE-free is quoting against a document they have not read, and an importer who sells on that assumption carries registration and recall exposure.
What Does the Cabinet Order Actually Exclude From PSE?#
The exclusions are a closed list of four uses, and none of them is bicycles. Item 12 of the non-specified electrical appliance schedule (別表第二) under the DENAN Act enforcement order defines the lithium-ion rechargeable battery entry, then carves out automotive-use, moped-use, medical-equipment-use, and industrial-machinery-use packs from that entry. A power-assisted bicycle battery matches none of the four carve-outs, so it stays inside the regulated entry.
A bicycle-use pack is screened against the cabinet order on the exclusion list, the vehicle classification, and the cell-level threshold:
(a) The closed exclusion list under the cabinet order covers only automotive-use (自動車用), moped-use (原動機付自転車用), medical-equipment-use (医療用機械器具用), and industrial-machinery-use (産業用機械器具用) lithium-ion packs. (b) A legally compliant power-assisted bicycle (電動アシスト自転車) is a bicycle (自転車), not a moped (原動機付自転車), under the Road Traffic Act's assist-ratio criteria, so its battery does not reach the moped exclusion. (c) The regulated threshold is measured at 400 Wh/L volumetric energy density per single cell, not per finished pack, so pack-level marketing claims about density are the wrong unit to screen against.
What Energy-Density Threshold Triggers PSE Scope?#
The trigger is a volumetric energy density of 400 Wh/L or higher, measured at the individual cell. That matters because a supplier can quote a pack-level energy figure that looks reassuring while every individual cell inside it clears the 400 Wh/L line on its own.
Any screening question to a supplier about PSE applicability has to specify cell-level data, and a pack datasheet alone does not answer it. Most e-bike lithium-ion cells on the market today are well above 400 Wh/L, which is why the regulation is written at the cell level: it is targeting the chemistry.
Is an E-Bike Battery Circle PSE or Diamond PSE?#
An in-scope e-bike lithium-ion battery falls under Circle PSE (丸PSE), the self-declaration and accredited-lab-testing track, not Diamond PSE (菱型PSE), which requires third-party Registered Conformity Assessment Body (RCAB) certification and factory inspection. This distinction changes both the compliance workload and the cost, and getting it backwards inflates a quote for no regulatory reason.
Circle PSE certification for a non-specified electrical appliance runs on self-declaration (自主検査) backed by accredited-lab test data, with no factory audit requirement. The mechanics of that split, including how a Circle PSE self-declaration compares to a Diamond PSE certificate's fixed renewal cycle, are covered in Diamond PSE vs Circle PSE: How Japan Classifies Your Electrical Product for Import. An e-bike battery is Circle PSE, so there is no factory inspection to schedule.
What Technical Standard Applies, and Did the Deadline Already Pass?#
The transition deadline has already passed. Lithium-ion batteries had a grandfather period under an older technical standard (別表第九) that ended on December 27, 2024. Any battery placed on the Japanese market after that date must conform to the current standard (別表第十二) instead, and a certificate issued under the old standard is not sufficient for a new market placement.
An importer relying on an older test report or an existing overseas certification needs to confirm which standard it was tested against before assuming it still clears the Japanese requirement. The mechanics of how a PSE certificate ages, and when a design or standard change forces new testing rather than a simple renewal, are covered in Does a PSE Certificate Expire in Japan? Diamond vs Circle Renewal Rules.
What Are the Notifying Supplier Obligations for E-Bike Battery Importers?#
Anyone carrying on the business of manufacturing or importing an in-scope electrical appliance must file a Notifying Supplier registration (届出) with Japan's Ministry of Economy, Trade and Industry (METI) within 30 days of starting that business, under Article 3 of the DENAN Act. This obligation runs separately from the certification testing itself: certification proves the product meets the standard, while the Notifying Supplier filing establishes who is legally answerable for it in Japan.
An importer with no physical presence in Japan is treated as a specified importing business operator (特定輸入事業者) and must designate a Japan-resident administrator (国内管理人) as part of that filing. This is a standing legal position, not a one-time paperwork step, and it carries ongoing recordkeeping duties for as long as the product remains on the market. Battery packs also travel under dangerous-goods rules separate from PSE, and the transport-side compliance structure for lithium-ion shipments is covered in Japan IOR for Lithium Battery Imports: The DG Compliance and Customs Structure Every Battery Shipper Must Get Right.
Does the Motor-Assist Ratio Change Whether PSE Applies?#
The assist ratio changes the PSE answer, but not in the client's favor. The more a drive unit's motor assist exceeds Japan's legal power-assisted-bicycle criteria, the more likely the finished vehicle is reclassified as a moped (原動機付自転車) rather than a bicycle, and a moped-use battery is the one configuration the cabinet order actually excludes from PSE.
That sounds like an escape route until the rest of the reclassification lands: a moped requires a license plate, compulsory insurance (自賠責保険), a driving license, a helmet, and it loses cycle-path access. Trading a PSE obligation on the battery for full vehicle-regulation exposure on the whole product is not a net gain under any reading, so the vehicle classification has to be settled correctly before anyone reasons about the battery's PSE status at all. Some e-bike drive systems also ship with Bluetooth-enabled displays, GPS trackers, or app-connected head units, which raise a separate certification question under Japan's Radio Act; that overlap is covered in PSE and Giteki in Japan: Do Wireless Devices Need Both?.
Is There a Separate Recycling Duty for E-Bike Batteries?#
A separate recycling duty applies, independent of the PSE question. Sealed rechargeable batteries, including the lithium-ion packs used in power-assisted bicycles, are designated products under the Act on Promotion of Effective Utilization of Resources (資源有効利用促進法), which places a collection and recycling duty on manufacturers and importers of the batteries and of the equipment that uses them.
Complete e-bikes are treated as equipment using a small rechargeable battery for this purpose, so importing assembled bicycles triggers the duty just as importing bare packs does. The practical discharge route for this obligation in Japan runs through membership in the industry collection scheme (JBRC), and it should be raised with a client at onboarding.
Aplash's PSE certification and Notifying Supplier filing work, alongside broader customs and trade-compliance structuring through Aplash's ACP and trade-compliance service, covers the certification and registration side of an e-bike battery import. The recycling duty, the vehicle-classification question, and the DG transport rules are separate, independently-triggered obligations, and a sourcing plan that only checks the battery's PSE status has checked one of at least four regimes.
Frequently Asked Questions#
If my e-bike battery is labeled 自転車用 by the supplier, is that a certification exemption?
The supplier's 自転車用 label creates no exemption: it is a marketing description, not a regulatory determination, and it should be treated as an unverified claim until checked against the cabinet order text. The DENAN Act's exclusion list for lithium-ion batteries names automotive-use, moped-use, medical-equipment-use, and industrial-machinery-use only, so a bicycle-use label does not place the product outside PSE scope.
Does a pre-2024 PSE test report still work for a new e-bike battery import?
Not on its own. The technical standard's grandfather period ended on December 27, 2024, and any battery placed on the market afterward must conform to the current standard. Confirm which standard the existing test data was generated against before relying on it for a new import.
Do I need to register as a Notifying Supplier even if I only import the battery, not the whole bicycle?
The Notifying Supplier filing applies to a battery-only importer as well. If the battery is an in-scope electrical appliance and the importer is carrying on the business of importing it, the Article 3 Notifying Supplier filing obligation applies regardless of whether the battery ships alone or installed in a finished bicycle. An importer located outside Japan additionally needs a Japan-resident administrator named in that filing.
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.