PSE & Radio Act Importer of Record Japan (電安法 / 電波法)

Regulated electronics imports into Japan require three stacked roles: Importer of Record (関税法), Notifying Supplier (電安法 / Electrical Appliance Safety Act), and Radio Act type certification (電波法 / 技適) for wireless devices. Aplash provides all three in one engagement — the configuration COVUE and generic IOR brokers cannot match for IT equipment, wireless gear, and AC-powered consumer electronics.

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Engagement scope

  • Importer of Record for PSE-regulated electronics (Diamond PSE and Circle PSE per 電気用品安全法 / Electrical Appliance Safety Act).
  • Notifying Supplier (届出事業者) role: Aplash registered with METI (経済産業省) as the responsible entity on the PSE label, with ongoing record-keeping and audit-readiness obligations.
  • 技適 (Giteki, Radio Act type certification) coordination via TELEC (Telecom Engineering Center) or other 登録証明機関 (Registered Certification Body under 電波法).
  • Bluetooth, Wi-Fi, cellular, NFC, and RF device 工事設計認証 (construction-design certification) coordination.
  • Three-layer revenue stack: IOR + Notifying Supplier + distribution-coordination layer.
  • Annual PSE maintenance and audit-readiness record-keeping for the device category Aplash is notified on.

Outside scope

  • Perform actual 技適 testing — TELEC and other Registered Certification Bodies perform the test; Aplash coordinates the submission.
  • Issue PSE marks on goods Aplash has not been notified on; cannot retroactively label goods imported before notification.
  • Hardware design changes or firmware modifications to bring a product into compliance — refer to OEM.
  • Items outside the 116 Diamond-PSE list and the 341 Circle-PSE list — the item must be in scope.
  • Industrial / commercial high-voltage equipment outside 電安法 scope — routed to industrial-equipment subpage.

Three-layer synergy

LayerAplash roleFee structure
1. Importer of RecordNamed importer; buy-and-sell contract chain; 適格請求書 issued to Japan-side buyerPer-shipment fee, CIF-banded
2. Notifying Supplier (PSE / Radio Act)METI-registered responsible party on the PSE label; ongoing record-keepingInitial certification + annual maintenance
3. Distribution CoordinationInvoices Japan-side buyer; transparent service-fee disclosureDistribution coordination fee, percentage of CIF

Diamond PSE vs Circle PSE

Diamond PSE applies to 116 specified electrical appliances (specified electrical products with higher hazard, such as AC adapters and water heaters) requiring third-party certification. Circle PSE applies to 341 non-specified items requiring manufacturer self-declaration. Aplash holds the Notifying Supplier role for both categories on engaged products.

技適 (Giteki) trigger

Any product with Wi-Fi, Bluetooth, cellular, NFC, or RF transmission requires 技適 (Radio Act type certification) before commercial use in Japan. Aplash coordinates the certification via TELEC or another 登録証明機関 (Registered Certification Body) and confirms mark-display requirements (visible label or in-software display).

Combined IOR + PSE + 技適 timeline

Typical 6 to 10 weeks from engagement start to first commercial shipment cleared, depending on whether 技適 testing is needed in addition to PSE notification.

Pricing band

IOR only (no PSE notification needed): from $2,800 per shipment. IOR + PSE Notifying Supplier coordination: from $4,800 per shipment + annual PSE maintenance $1,800 to $2,400 per category. IOR + 技適 + PSE bundle: quoted on inquiry. Distribution coordination fee on the distribution layer: percentage of CIF, disclosed transparently in the engagement letter.

Customs duties and Japanese consumption tax (JCT) pass through at cost. Aplash earns no margin on the goods, only on the service.

Frequently asked questions

Does IOR include PSE certification?

No. PSE certification and Importer of Record are separate functions. Aplash provides both stacked: Aplash imports as named IOR, and Aplash registers with METI as Notifying Supplier so its name appears on the PSE label.

What is a Notifying Supplier (届出事業者)?

The 届出事業者 is the METI-registered entity that places a PSE-marked product on the Japanese market. The Notifying Supplier carries ongoing record-keeping, audit-readiness, and product-safety obligations. Aplash can act as Notifying Supplier on the client's behalf.

Is 技適 required for Bluetooth headphones?

Yes. Any product with Wi-Fi, Bluetooth, cellular, NFC, or RF transmission requires 技適 (Giteki, Radio Act type certification) before commercial use in Japan. Aplash coordinates the certification via TELEC or another 登録証明機関.

Can Aplash maintain PSE after the initial import?

Yes. Annual PSE maintenance covers record-keeping, label-version updates, and audit-readiness. This is the recurring layer of the three-layer offer.

Diamond PSE vs Circle PSE?

Diamond PSE applies to 116 specified electrical appliances with higher hazard (AC adapters, water heaters) requiring third-party certification. Circle PSE applies to 341 non-specified items requiring manufacturer self-declaration.

What is the distribution coordination fee?

A separately disclosed service fee for invoicing the Japan-side buyer and coordinating collection. It is the distribution-layer compensation, not a markup on goods, and is itemized transparently in the engagement letter.

Applicable law and standards

  • 関税法 (Customs Act) [R1]
  • 電気用品安全法 (Electrical Appliance Safety Act) [R1]
  • 電波法 (Radio Act) [R1]

Engagement begins with a free product-classification review: we confirm PSE scope, 技適 trigger, and IOR feasibility before quoting.

Request a no-cost commodity assessment. We confirm IOR feasibility and quote against the public pricing band before any commitment.

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