A foreign manufacturer with no Japan entity gets the PSE mark by contracting a Japan-incorporated company to act as Notifying Supplier (届出事業者) under the Electrical Appliance and Materials Safety Act (電気用品安全法), known as DENAN. That entity registers with METI, puts its name on the PSE label, and carries the ongoing safety obligations, while the manufacturer keeps design control and supplies the goods.
Why Can't a Foreign Manufacturer Be the PSE Notifying Supplier?#
Because DENAN requires the Notifying Supplier to be a Japan-incorporated company or an individual with a Japan address, and a foreign manufacturer without a local entity cannot meet that test. The PSE mark identifies the party that takes legal responsibility for product safety in the Japanese market, so without a qualifying Notifying Supplier, the mark cannot legally be affixed and the product cannot legally be sold or imported for sale in Japan.
The Notifying Supplier model resolves this by letting a Japan-incorporated company take on the registration and label responsibility on the manufacturer's behalf, under contract, without requiring the manufacturer to incorporate locally.
What Is PSE?#
PSE certification is required under DENAN - the Electrical Appliance and Materials Safety Act (電気用品安全法). It applies to all electrical products sold or imported for sale in Japan that appear on METI's designated product lists.
DENAN applies only to products on one of two METI-designated lists: the 116-item Specified Electrical Appliances (特定電気用品) list and the approximately 341-item Non-Specified Electrical Appliances (非特定電気用品) list. Products that appear on neither list do not require PSE - but that determination must be documented.
Diamond PSE vs. Circle PSE: What Is the Difference?#
PSE has two tiers with fundamentally different certification paths, testing requirements, cost profiles, and timelines. The most expensive error in Japan PSE compliance is assigning the wrong tier. For the full breakdown of testing paths, certificate validity, and timelines by tier, see Diamond PSE vs Circle PSE: How Japan Classifies Your Electrical Product for Import.
| Attribute | Diamond PSE | Circle PSE |
|---|---|---|
| Official category | Specified (特定電気用品) | Non-Specified (非特定電気用品) |
| METI designated list | 116-item list | ~341-item list |
| Certification body | METI-designated RCAB | ISO/IEC 17025-accredited laboratory |
| Third-party certification | Mandatory | Not required (self-declaration) |
| Factory inspection at initial cert | Required | Not required |
| Annual surveillance audit | Yes - ¥100,000–¥250,000 | No |
| Certificate validity | 3, 5, or 7 years | No expiry (while design and applicable standards unchanged) |
| Renewal required | Yes - before each expiry | No (unless design or standards change) |
| Typical timeline | 6–10 weeks | 4–6 weeks |
The Single Most Common PSE Error
Do not default all products to Diamond PSE. Unless your product appears on the 116-item Specified Electrical Appliances list, it cannot be Diamond PSE. Blanket Diamond classification for a product portfolio creates unnecessary cost, longer timelines, and factory audit obligations that do not legally apply.
The check is straightforward: look up your product against the current METI 特定電気用品 list. If it is not there, it is Circle PSE (if on the 341-item list) or exempt (if on neither). Document the determination either way.
Product Classification Reference
| Product | Correct PSE Tier | Basis |
|---|---|---|
| AC/DC power adapters | Diamond | On Specified (116-item) list |
| Rechargeable lithium-ion batteries | Diamond | On Specified list; also triggers DG (UN 3480/3481) |
| Electric water heaters | Diamond | On Specified list |
| Air conditioners | Diamond | On Specified list |
| Microwave ovens | Circle | Not on Specified list (電子応用機械器具 - 341 list) |
| Hair dryers | Circle | Not on Specified list (電動力応用機械器具 - 341 list) |
| Electric kettles | Circle | Non-Specified |
| Television receivers | Circle | Non-Specified; check Radio Act (電波法) if wireless |
| LED lighting | Circle | Non-Specified |
| USB chargers | Circle | Non-Specified |
| Refrigerators (certain types) | Diamond | Confirm against Specified list by product type |
| Low-voltage DC signal switches (<50V DC) | Exempt | Not on either DENAN list - document |
Always verify each model individually against the current METI designated lists. The table above is a reference, not a substitute for a formal applicability assessment.
The Notifying Supplier Model: How Does It Work?#
The Notifying Supplier (届出事業者) is the Japan-registered entity whose name appears on the PSE label. When a foreign manufacturer engages a Japan entity to serve as Notifying Supplier, the structure has three layers:
Aplash provides this Notifying Supplier structure together with Attorney for Customs Procedures (ACP) services for the import leg, so certification, registration, and customs clearance run through a single Japan point of contact.
What the Notifying Supplier Does in Practice
| Obligation | Detail |
|---|---|
| METI registration | Files business notification (届出) with METI; one filing per product category |
| Label bearing | Notifying Supplier's name and address appear on every PSE-compliant product |
| Certification management | Coordinates test laboratory engagement and manages certification files |
| Record keeping | Retains technical documentation and inspection records for seven years (DENAN requirement) |
| Accident reporting | Reports product-related accidents to METI |
| Recall coordination | Coordinates with METI in the event of a product safety recall |
| ACP / import | Handles customs clearance as Attorney for Customs Procedures (税関事務管理人, 関税法第95条) or as IOR |
| Invoicing | Issues qualified invoices (適格請求書) to Japan end clients if the distribution structure requires it |
METI registration is filed once per product category rather than per individual model, though the underlying certification (Diamond or Circle) is still assessed model by model. For the exact rule on when one certificate covers multiple models and when each model needs its own, see Do You Need a Separate PSE Certificate for Every Product Model in Japan?
What Are Japan's Hardware Requirements for Electrical Products?#
Japan requires four physical compliance points before PSE testing can begin: 100V voltage compatibility, Type A (JIS C 8303) plugs, 50/60Hz dual-frequency support, and Japanese-language safety labelling. Verify these before any PSE classification or testing starts; a single mismatch can block market entry entirely.
| Requirement | Japan Standard | Common Issue from Foreign Markets |
|---|---|---|
| Voltage | 100V | US products rated 110V or 120V; European products rated 220–240V - require voltage conversion or dual-voltage design |
| Frequency | 50Hz (eastern Japan / Tokyo) and 60Hz (western Japan / Osaka) | Single-frequency rating limits distribution to one region; dual-frequency (50/60Hz) strongly preferred |
| Plug type | Type A, JIS C 8303 | Non-Type A plugs require adapter or physical plug replacement on the product |
| Safety labelling | Japanese language | All safety labels, warning marks, usage instructions, and age restrictions must be in Japanese |
Voltage is the most common market-entry blocker. A product rated at 110V, 120V, or 220V cannot be sold in Japan without modification or a confirmed dual-voltage rating. Identify this at the first stage of any PSE engagement - it may require hardware redesign before certification can proceed.
Does an Existing CB Report Satisfy Japan PSE Testing Requirements?#
Not on its own. A valid CB report reduces the scope of Japan testing but does not replace the Japan-specific delta testing DENAN requires for voltage, plug, and labelling differences.
| CB Report Status | Action Required for Japan |
|---|---|
| Valid CB report for exact Japan-bound model number | Delta testing for Japan-specific deviations (100V voltage, JIS C 8303 plug, Japanese labelling) |
| Valid CB report for similar model with different model number | Full new testing - CB scope must precisely match the model being certified |
| CB report expired, no design changes | Reassessment; in some cases, re-testing may not be required if standards are unchanged |
| CB report expired, design changes occurred | New testing required |
| No CB report | Full Japan testing from scratch against applicable JIS/IEC standards |
Delta testing cannot be skipped. Even with a valid CB report, Japan-specific deviations in the applicable standards - particularly for 100V operation and JIS C 8303 plug compliance - require additional testing. This is not a formality; it addresses genuine technical differences between Japan's electrical environment and other markets.
PSE Certification: Step-by-Step#
Step 1: PSE Applicability Assessment
Check each product model against the METI Specified (116-item) and
Non-Specified (~341-item) lists.
Output per model: Diamond / Circle / Exempt + documentation.
│
Step 2: Japan Hardware Gap Analysis
Verify voltage, frequency, plug type, and labelling compliance.
Output: Go / Requires modification - list all required changes.
│
Step 3: CB Report Review
Assess whether existing CB reports cover the Japan-bound models
and determine delta testing scope.
│
Step 4: Test Coordination
Diamond: engage METI-designated RCAB (Registered Conformity Assessment Body).
Circle: engage ISO/IEC 17025-accredited test laboratory.
Provide technical documentation and product samples.
│
Step 5: Lab Testing
Testing against applicable JIS/IEC standards with Japan-specific requirements.
Typical duration: 3–6 weeks depending on product complexity.
│
Step 6: METI Business Notification (届出)
Notifying Supplier files with METI.
One filing per product category - not per individual model.
│
Step 7: Label and Nameplate Application
Apply PSE mark (Diamond or Circle) and required nameplate information in Japanese:
mark, rated voltage, rated frequency, rated consumption, manufacturer/importer name,
country of manufacture.
│
Step 8: Import and Customs Clearance
Customs clearance via ACP (税関事務管理人, 関税法第95条) or IOR.
Goods released for distribution with PSE mark.
│
Step 9: Ongoing Compliance
Annual maintenance, record retention, regulatory monitoring, renewal.
What Ongoing Obligations Does a Notifying Supplier Have After PSE Certification?#
DENAN compliance does not end at certification. The Notifying Supplier carries permanent obligations for as long as products bearing the PSE mark remain in the Japan market, including seven-year record retention, annual registration maintenance, and accident reporting.
| Obligation | Frequency | Detail |
|---|---|---|
| Technical record retention | 7 years | Technical documents, test reports, inspection records per DENAN |
| METI registration maintenance | Annual | Keep notification current; update on product or company changes |
| Accident reporting | As incidents occur | Report product-related accidents to METI within statutory timeframe |
| Recall coordination | As required | Coordinate with METI; logistics/refund costs are manufacturer's liability |
| Annual surveillance audit (Diamond only) | Annual | Factory inspection; cost ¥100,000–¥250,000 passed through at cost |
| Diamond PSE renewal | Every 3, 5, or 7 years | Recertification before certificate expiry; cannot be allowed to lapse |
Post-termination obligation: When a Notifying Supplier arrangement ends, the supplier's name remains on products already sold and in the Japan market. The former supplier must either (a) arrange transfer of METI registration to a new Notifying Supplier, or (b) coordinate product recall. Termination notice periods of at least 90 days exist precisely because of this obligation. Plan transitions carefully.
What Changed for Foreign Sellers Under the December 2025 Product Safety Reform?#
A December 2025 amendment to Japan's Product Safety Acts extended compliance obligations directly to foreign sellers who sell PSE or PSC-regulated products to Japanese consumers via cross-border channels (including cross-border e-commerce platforms).
| Obligation | Before December 2025 | After December 2025 |
|---|---|---|
| Business notification to METI | Japan importer only | Foreign seller also required |
| Domestic Representative (国内管理人) | Not required for foreign sellers | Mandatory |
| PSE mark display responsibility | Japan importer's obligation | Foreign seller's responsibility |
| Accident reporting | Japan importer only | Foreign seller also required |
| Product recall coordination | Japan importer only | Foreign seller also required |
What the Domestic Representative Does
Foreign sellers of PSE-regulated products must now appoint a Japan-resident Domestic Representative (国内管理人) who:
A Notifying Supplier and a Domestic Representative serve related but legally distinct functions. For foreign manufacturers distributing through a Japan entity that also acts as Notifying Supplier, that same entity can often fulfil the Domestic Representative role, simplifying the compliance structure.
Does a Wireless Product Need Radio Act (電波法) Certification in Addition to PSE?#
Yes. Any product with wireless capability, such as Wi-Fi, Bluetooth, NFC, cellular, ZigBee, or proprietary RF, requires a separate Radio Act (電波法) assessment in addition to PSE, regardless of PSE tier. TELEC certification (技術基準適合証明) from a MIC-designated body is mandatory for all radio-transmitting devices.
PSE and TELEC are distinct certifications. A product can be Circle PSE and simultaneously require TELEC. Neither certification substitutes for the other. For the full certification path, MIC-designated test bodies, and typical timeline, see Japan Radio Act Certification (技適): Import Compliance for Wireless Devices and IoT.
Example: A smart home appliance with Wi-Fi requires Circle PSE certification (as a non-specified electrical appliance) AND TELEC certification for its radio function. Both must be completed before customs clearance.
Why Work Through a Notifying Supplier Instead of a Japan Entity?#
For foreign manufacturers with recurring Japan sales, the Notifying Supplier structure creates a legally compliant, commercially structured, ongoing access mechanism without the manufacturer standing up a Japan subsidiary of its own.
Illustrative Annual Revenue Structure per Client
| Revenue Line | Initial Year | Year 2+ |
|---|---|---|
| PSE applicability assessment | $500–$1,000 per model | - |
| Circle PSE certification | $2,200–$5,500 per model | - |
| Diamond PSE certification | $5,000–$10,000 per model | - |
| METI registration (届出) | $800–$1,200 per category | - |
| Annual Notifying Supplier maintenance | $1,800–$2,400 per category | $1,800–$2,400 per category |
| Diamond annual surveillance support | $1,500–$2,500 per audit | $1,500–$2,500 per audit |
| Invoicing margin on Japan sales | 7–10% of CIF | 7–10% of CIF |
The invoicing margin scales with Japan sales volume. For a manufacturer shipping ¥50M JPY (~$325K USD) annually into Japan, an 8% invoicing margin represents approximately $26,000/year in ongoing revenue to the Notifying Supplier - in addition to the annual maintenance fee - with no additional certification cost in Year 2 or beyond.
PSE Compliance Checklist for Foreign Manufacturers#
- Check each product model individually against METI's Specified (116-item) and Non-Specified lists - do not apply blanket Diamond or Circle classification
- Verify Japan hardware requirements: voltage (100V), plug type (Type A / JIS C 8303), frequency (50/60Hz)
- Confirm all safety labels, warnings, and usage instructions are in Japanese
- Assess existing CB reports: do they cover the exact Japan-bound model number?
- Identify wireless capability in any product: if yes, engage Radio Act (電波法) / TELEC assessment separately
- Engage METI-designated RCAB (Diamond) or ISO/IEC 17025-accredited lab (Circle)
- File METI business notification (届出) under Notifying Supplier name
- Disclose and budget for annual maintenance, surveillance audit (Diamond), and renewal obligations
- For cross-border e-commerce sales to Japan: appoint Domestic Representative (国内管理人) per December 2025 reform
- Confirm product liability insurance covers Japan market distribution
Frequently Asked Questions#
Do I need a Japan entity to sell PSE-regulated electrical products in Japan?
No. A foreign manufacturer can reach the Japan market by contracting a Japan-incorporated company to act as Notifying Supplier (届出事業者) under DENAN. The manufacturer keeps design control and continues producing the goods; the Notifying Supplier registers with METI, holds the PSE label obligation, and manages the ongoing compliance record.
How is Diamond PSE different from Circle PSE in cost and timeline?
Diamond PSE applies only to the 116-item Specified Electrical Appliances (特定電気用品) list and requires third-party certification through a METI-designated conformity assessment body, a factory inspection, and periodic renewal every 3, 5, or 7 years, typically taking 6 to 10 weeks. Circle PSE applies to the roughly 341-item Non-Specified list, is a self-declaration against ISO/IEC 17025-accredited lab testing with no factory inspection or expiry, and typically takes 4 to 6 weeks. Defaulting every product to Diamond when it belongs on the Circle path is the single most common and most expensive classification error.
What is the Domestic Representative requirement introduced in December 2025?
Since the December 2025 amendment to Japan's Product Safety Acts, foreign sellers of PSE or PSC-regulated products sold to Japanese consumers through cross-border channels must appoint a Japan-resident Domestic Representative (国内管理人) named in the METI business notification. The Domestic Representative relays METI communications, assists with accident reporting, and coordinates recalls. A Japan entity already serving as Notifying Supplier can often take on this role as well, keeping the compliance structure to a single point of contact.
Official References#
| Source | Link |
|---|---|
| METI - PSE / DENAN | meti.go.jp/english (PSE) |
| METI - Specified Electrical Appliances List | meti.go.jp |
| MIC - Radio Act / TELEC Certification | soumu.go.jp/english |
| JIS C 8303 - Japan Plug Standard | jisc.go.jp |
| Consumer Affairs Agency - Product Safety | consumer.go.jp/english |
| IEC CB Scheme | iecee.org |
This article is for informational purposes only and does not constitute legal, regulatory, or product safety advice. Consult a METI-registered product safety consultant, certified customs specialist (通関士), or licensed attorney (弁護士) for your specific PSE certification, DENAN compliance, and Notifying Supplier structure needs. Last updated: September 2026.