Yes. Any dog or cat product sold to supply nutrition, including marine-oil softgels and joint chews, falls under the Pet Food Safety Act (愛がん動物用飼料の安全性の確保に関する法律), which requires a business notification filed before sales start, a five-item Japanese label naming an importer, binding composition limits, and a near-total ban on the joint, coat, and anti-aging claims that fill most Western pet supplement copy.
What Law Governs Pet Food and Pet Supplements in Japan?#
The Pet Food Safety Act, not the Food Sanitation Act (食品衛生法), governs anything marketed to provide nutrition to a dog or a cat. That includes complete foods, treats, dental chews, gum, mineral water, and supplements; toys and containers fall outside the Act because they serve no nutritional purpose, and species other than dogs and cats are excluded entirely. Because the Food Sanitation Act does not apply, the import notification and reduced-tax reasoning built for human food does not carry over to a pet product, a gap Japan IOR for Pet Products, Pet Food, and Animal-Derived Goods covers at the structural level. The Act sits jointly under the Ministry of Agriculture, Forestry and Fisheries (MAFF) and the Ministry of the Environment, separate from the Customs Act (関税法) processes that move the shipment itself.
Do You Need a Business Notification Before You Can Sell?#
Yes, and it must be filed before the business starts, not after the first sale. Article 9, Paragraph 1 of the Act requires a business notification submitted in duplicate to the regional agricultural administration office (地方農政局) with jurisdiction over the notifier's principal office in Japan. A foreign brand with no Japan office cannot file this notification directly, since the office of jurisdiction is determined by the notifier's principal place of business inside Japan. The notification also establishes the record-keeping obligation the Act imposes on the notifier, along with responsibility for responding to any disposal or recall order MAFF issues against the product.
Who Can File the Notification: IOR or ACP?#
IOR. An Importer of Record (IOR) structure gives a non-resident brand both roles the Act requires: the notifier under Article 9, and the labelled importer (輸入業者) that the Act's labelling schedule (別表第3) requires the Japanese label to name with a Japan address. Under this structure the Japan-based entity is the party MAFF's notification and label rules are written around, holding the filing, the record-keeping duty, and the exposure if a recall or disposal order is issued. This is the structure a brand needs in place before the notification can be filed at all, and it is worth reviewing against the general importer-of-record question addressed for food shipments in Can a Non-Resident Be the Importer of Record for a Food Shipment Into Japan?, since the underlying non-resident problem is the same even though the governing Act differs.
ACP. An Attorney for Customs Procedures (ACP) appointment under Article 95 of the Customs Act supplies neither role. ACP is a customs-procedure agent that clears the shipment through Customs; it does not file the Article 9 business notification and it cannot appear on the label as the importer (輸入業者), because both requirements are written around the importer itself, not around whoever handles the customs entry. A brand that has only appointed an ACP still has no notifier and no labelled importer, and cannot lawfully sell. Structuring the IOR relationship correctly, before the first shipment, is what closes that gap.
What Must the Japan Label Say?#
The label needs five items in Japanese, and all five sit on the product itself, not in a separate compliance document. They are: the name (名称), showing whether the product is for dogs or for cats; the ingredient list (原材料名), including additives; the best-before date (賞味期限); the business name and address (事業者名及び住所), carrying the category label importer (輸入業者); and the country of origin (原産国名). Country of origin means the country of last substantial processing, so relabelling or repacking in a third country does not change the declared origin. A related certification question, whether a product also needs PSE, PSC, or a separate food-safety filing before it can be sold at all, is covered in Do You Need PSE, PSC, or Food Safety Certification to Import Into Japan? (2026 Guide).
What Composition Limits Apply to Marine-Oil Pet Supplements?#
The Act sets binding numeric limits, and for marine-oil products the ones most likely to be exceeded involve the antioxidant preservative rather than the fish oil itself. Ethoxyquin is capped at 75 mg/kg (75 g/t) for dog product, or 150 mg/kg (150 g/t) when combined with BHA and BHT. Cadmium is capped at 1 microgram per gram, lead at 3 micrograms per gram, and inorganic arsenic at 2 micrograms per gram. Ethoxyquin is the conventional fish-oil antioxidant and can be present in a supply chain without appearing anywhere on a US ingredient list, so it should be treated as a first-lot laboratory test item rather than accepted on a supplier's word.
Propylene glycol is barred outright in any product targeted at cats, and a single SKU labelled for both dogs and cats inherits the stricter cat-only restriction across the whole batch. A brand running one formulation across both species needs to check every excipient against the cat list, not just the dog list, before the first import.
Are Joint Health, Coat Health, and Anti-Aging Claims Legal in Japan?#
No, and this is the single biggest compliance risk in the category. A pet food or supplement becomes an unapproved, unlicensed veterinary drug under the Pharmaceutical and Medical Device Act (薬機法) if its ingredients, form, labelling, or dosage instructions read as drug-like, and body-structure or body-function claims sit squarely inside that prohibition. MAFF specifically names joint, coat and fur, bone, teeth, eye, stomach and abdomen, and leg and hip claims, along with joint function, digestion and absorption, growth and development, and anti-aging claims. This reach covers the physical package, any insert or leaflet, and internet or marketplace advertising and listing copy, so a compliant bottle label paired with a non-compliant Amazon or Rakuten listing is still a violation.
Most Western pet supplement marketing is built almost entirely from these prohibited claim categories, since joint health, coat health, digestive health, and anti-aging are the standard vocabulary of the US and EU category. That means a Japan SKU's copy needs a full rewrite grounded in the product's actual composition and feeding amount, never a translation of the US copy. There is a workable framing distinction: describing the recommended amount as a feeding amount (給与量) is ordinary pet food language, while the same instruction framed as a medical dosage (用量) crosses into the drug-like prohibition.
Key points:
(a) Any body-structure or body-function claim (joint, coat, bone, teeth, eye, stomach, leg and hip, digestion, growth, anti-aging) is treated as drug-like under the Pharmaceutical and Medical Device Act and is prohibited on pet food and pet supplements.
(b) The prohibition covers the package, any leaflet, and all online advertising and marketplace listing copy, so a clean physical label does not offset non-compliant listing text.
(c) Feeding instructions must be framed as a feeding amount (給与量), not a dosage (用量); the copy should be rewritten from the product's actual composition, not translated from the US label.
Does Fish Oil Trigger Japan's Animal Quarantine Rules?#
Generally no. Fish and fish oil are not on the designated quarantine list under Japan's Livestock Infectious Disease Control Act (家畜伝染病予防法), a list that runs to cloven-hoofed animals, horses, poultry, rabbits, bees, and products derived from them. A straight marine-oil supplement in a non-animal capsule shell sits outside that quarantine regime entirely.
The exception is the capsule itself. A gelatin capsule shell, or any other mammal- or poultry-derived carrier ingredient, brings the finished product back inside the quarantine list even though the active fish oil fill would not trigger it alone. A fish-oil softgel is not automatically clear of quarantine scope; the shell material has to be checked as its own input, separately from the oil.
What Duty and Tax Rate Applies to Pet Food Imports?#
Pet food classifies under HS heading 2309.10, feed for dogs or cats put up for retail sale, and that heading is duty-free at both the general and WTO tariff rates. The tax question is where brands most often assume the wrong number. Import consumption tax on pet food is the standard 10 percent rate, not the reduced 8 percent rate that applies to human food and drink, because Japan's National Tax Agency specifically excludes pet food from the reduced-rate category regardless of how food-like the packaging looks.
Frequently Asked Questions#
Can I sell my pet supplement in Japan if I already have a customs broker or ACP in place?
No. An ACP appointment under the Customs Act clears the shipment through Customs but does not file the Article 9 business notification and cannot appear on the label as the importer, both of which the Pet Food Safety Act requires from the importer itself. A brand needs an IOR structure to hold the notifier role and the labelled importer role before it can lawfully sell.
Do I need to translate my US label into Japanese, or rewrite it?
Rewrite it. A direct translation of typical US pet supplement copy, joint health, coat health, digestive health, anti-aging, will carry the exact body-structure and body-function claims Japan treats as drug-like under the Pharmaceutical and Medical Device Act. The label, any leaflet, and the marketplace listing all need copy built from the product's actual composition and feeding amount, not from the source-market marketing language.
Does a marine-oil supplement need any special testing before the first shipment?
Yes, at minimum for the antioxidant preservative. Ethoxyquin, the conventional fish-oil antioxidant, can be present in the supply chain without appearing on a US ingredient list, so the composition limits (ethoxyquin, cadmium, lead, inorganic arsenic) should be verified by laboratory test on the first lot rather than accepted on the supplier's declaration alone.
Conclusion#
The Pet Food Safety Act treats a marine-oil supplement or joint chew as a regulated product with its own notification, label, and composition regime, entirely separate from the Food Sanitation Act framework that governs human food imports. The notification and label requirements can only be satisfied through a Japan-based importer structure, and the claims restriction under the Pharmaceutical and Medical Device Act rules out most of the standard Western marketing vocabulary for this category. Getting the composition testing, label, and claims rewrite right before the first shipment avoids a recall or disposal order after the product is already on shelf.
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.