Chemical Substances Importer of Record in Japan (化審法 / 毒劇法)
Want to bring industrial chemicals into Japan but have no company there to import them? Aplash becomes your Importer of Record (IOR): the legal importer on record for your shipment. We check whether your substance is already registered in Japan, handle the new-substance notification if it is not, prepare a Japan-format safety data sheet, and file the customs entry in our own name under the Customs Act (関税法).
How it works
An Importer of Record (IOR) is the company legally responsible for bringing goods through customs. Aplash takes that role so you can sell into Japan without a local entity.
- 1Free commodity assessmentSend your product details. We confirm whether Aplash can be your importer and give you a quote, at no cost.
- 2We import as your Importer of RecordAplash clears customs in its own name under the Customs Act (関税法) and arranges any permits or certifications your goods need.
- 3Delivered to your Japan buyerWe hand the goods to your Japan-side buyer and invoice transparently, so you sell in Japan with no company of your own there.
What Aplash handles
- Check whether your substance is already on Japan's Existing Chemical Substances inventory, or whether it needs new-substance notice (PMN, Pre-Manufacture Notification) before import.
- Coordinate the handler permit and import permit required under the Poisonous and Deleterious Substances Control Law (毒劇法) through a licensed partner.
- Review your existing GHS-aligned safety data sheet (SDS) and prepare a bilingual English-Japanese version in Japan's required format (JIS Z 7253:2019) where needed.
- Act as Importer of Record for: (a) chemicals already on the Existing Chemicals inventory, (b) new chemicals that qualify for the small-volume R&D exemption (up to 1 ton per year per importer), and (c) Class 1 Specified Chemical Substances once the required assessment is cleared.
- Coordinate name-disclosure compliance under the Industrial Safety and Health Act (安衛法) for chemicals that require it.
What we do not handle
- Build a new-substance notification from raw lab data on your behalf. The manufacturer owns the toxicology data and must submit the notification as the data owner; we coordinate, we do not originate it without their cooperation.
- Handle narcotics or narcotics precursors under the Narcotics and Psychotropics Control Law (麻薬及び向精神薬取締法). We decline these and refer you to a specialist.
- Import Class 1 Specified Chemical Substances flagged for restricted use under Article 17 of the Chemical Substances Control Law (化審法第17条). These sit outside our standard scope by default.
- Import poisons (毒物) without a registered handler. Aplash does not currently hold the Poisonous and Deleterious Substances Business Operator (毒物劇物営業者) registration, so we coordinate this through a licensed partner.
- Handle radioactive isotopes. We decline these.
- Work with shipments routed to a sanctioned party or sanctioned country. We decline these.
How we classify your substance
- (a) Already on the inventory: standard customs filing, no extra notification needed.
- (b) New substance, notification required: we open a pre-import notification window before the shipment moves.
- (c) Class 1 Specified, priority assessment needed: restricted scope, requires a pre-engagement assessment first.
- (d) Listed as a poison (毒物) under the 毒劇法: we coordinate the import through a licensed partner.
- (e) Listed as a deleterious substance (劇物) under the 毒劇法: we coordinate the import through a licensed partner.
What we need before we start
- CAS number.
- A GHS-aligned safety data sheet (SDS).
- A summary of the toxicology data.
- A description of the intended use.
- Your expected annual import volume.
How long each path takes
| Path | Time before import |
|---|---|
| Already on the inventory | No extra wait, filed with the shipment |
| Small-volume R&D exemption | 1 to 2 months |
| Full new-substance notification (PMN) | 3 to 12 months |
Pricing band
Standard chemicals (already on the inventory, small volume, no permit needed): from $4,800 per shipment. Imports that need a permit, or Specified Chemical handling: from $7,500 per shipment, plus a permit coordination fee. New-substance notification coordination is scoped per engagement.
Customs duty and Japanese consumption tax (JCT) are passed on at cost. Aplash earns no margin on the goods, only on the service.
Not sure if your goods qualify?
Send the product details. We confirm whether Aplash can import it and quote against the public pricing band before you commit.
Frequently asked questions
What is the Chemical Substances Control Law (化審法)?
It is Japan's primary law governing the manufacture, import, and use of industrial chemicals. It sorts substances into four groups, Existing, New, Class 1 Specified, and Class 2 Specified, each with its own notification and assessment requirements.
Do I need to notify the government before importing every new chemical?
Yes, unless an exemption applies, you need a Pre-Manufacture Notification (PMN) for any new chemical not already on the Existing inventory. The most common route Aplash coordinates is the small-volume R&D exemption, which applies up to 1 ton per year per importer.
Can Aplash act as importer for substances on the poison (毒物) list?
Aplash does not currently hold the registration required to handle these directly (毒物劇物営業者, Poisonous and Deleterious Substances Business Operator). We coordinate the import through a licensed partner who holds that registration.
How long does new chemical notification take?
A full PMN review typically takes 3 to 12 months, depending on how complex the substance is and current workload at METI and MHLW (the relevant ministries). The small-volume R&D exemption is faster, at 1 to 2 months. We only start the customs filing once the correct path is confirmed.
Does Aplash handle narcotics precursors?
No. Substances on the precursor list under the Narcotics and Psychotropics Control Law (麻薬及び向精神薬取締法) fall outside our scope. We refer these to a specialist holding the relevant narcotics importer (麻薬輸入業者) license.
Applicable law and standards
- Customs Act (関税法)
- Chemical Substances Control Law (化審法)
- Poisonous and Deleterious Substances Control Law (毒劇法)
- Industrial Safety and Health Act (安衛法)
Related pages
We only file your customs entry once your substance's classification is confirmed and any required permits are in hand. Every engagement starts with a pre-engagement document review.