PSE and PSC Certification for Electronics and Household Goods Sold Into Japan

Most compliance surprises in Japan are timing surprises. A brand picks its launch range, books production, arranges freight, and only then discovers that one item needs a certificate from a designated body — with a factory audit attached — that nobody has started. The launch does not fail; it slips a quarter, and the marketing calendar slips with it.

PSE and PSC are the two regimes where this happens most, because neither is a general safety principle you can reason about. Both are lists of named products, and your product is either on a list or it is not. What follows is how to find out which, what each answer costs in time and money, who is allowed to be the responsible party, and what the obligation looks like after launch — which is where most budgets are wrong.

One boundary first: LAUNOVA is an ecommerce operations firm running Japanese storefronts for overseas brands. We do not perform certification, act as a registered inspection body, or file safety notifications, and nothing here is legal advice. Conformity work belongs with a registered inspection body or a technical consultant; what we can do is make sure the certification path is known before it becomes the reason a launch date moves.

Two Acts, Two Marks, and One Question That Comes First

PSE comes from the Electrical Appliance and Material Safety Act (電気用品安全法, Act No. 234 of 1961); PSC from the Consumer Product Safety Act (消費生活用製品安全法, Act No. 31 of 1973). They cover different goods but share an architecture: a Cabinet Order lists specific products with quantitative boundaries, and being on that list triggers duties on whoever manufactures or imports.

So the first question is never "is my product safe" or "does it use electricity". It is: does my product match a named entry, within its stated rating limits? METI publishes the two PSE lists in full — 116 items classed as Specified Electrical Appliances and 341 items classed as non-specified, 457 in total — and each entry carries its own boundary. Electric fans are in scope at 300W or less, vacuum cleaners at 1.5kW or less; lithium-ion cells only at 400Wh/L volumetric energy density or above, with automotive, moped, medical and industrial cells carved out. A product above the stated rating falls outside that item as written.

METI is unambiguous about who makes this determination: it is the business operator's own responsibility. And you cannot outsource the judgement to the body that will certify you — registered inspection bodies operate under ISO/IEC 17065 and are barred from advising applicants, so the assessment stays independent. There is no counter where you present a product and are told what it needs.

Diamond or Circle: The Split That Sets Your Timeline

Within PSE, the 457 items split into two routes, and the mark shape tells you which one applied.

• Non-specified electrical appliances — 341 items, round PSE mark. Self-declaration: you confirm conformity with the technical standards yourself, inspect, label and sell. No outside body required.
• Specified Electrical Appliances — 116 items, diamond PSE mark. All of the above, plus an Article 9 conformity assessment by a registered inspection body, certificate in hand before the product is sold. The assessment has two parts: a test of product samples against the technical standards, and an audit confirming the plant holds the required inspection equipment, properly calibrated.

The labelling differs too: a diamond product must display the mark, the notifying operator's name and the registered inspection body's name; a round product shows the first two only. And diamond certificates expire, with the validity period fixed item by item in the Enforcement Order — three years for a magnetic therapy device, five for an electric toilet seat or aquarium heater, seven for cable and wiring devices — and renewal means the assessment again, not a form.

Here is where intuition misleads people. The heavy, obviously dangerous-looking appliances are mostly non-specified: refrigerators, washing machines, televisions, vacuum cleaners, electric fans and lithium-ion batteries all sit in the 341. The specified list is dominated by what sits between the wall and the appliance — plugs, sockets, multi-taps, adapters, cord reels, extension cord sets, DC power supply units — plus items where failure puts the user in direct contact with water, heat or their own body: electric toilet seats, aquarium heaters, water heaters, electric massagers, portable generators.

The practical consequence catches brands importing consumer electronics. Your device may be self-declared or not a listed item at all — but the AC adapter and the power cord set in the same carton are separate electrical appliances, and METI's guidance is explicit that each bundled item carries its own obligations. Two narrow exceptions: a cord set usable only with that specific device, or a cord or plug built integrally into it, is treated as part of the device; and a lithium-ion battery installed in the product is part of the product, while one packed alongside as a spare is a separate electrical appliance. A "not an electrical product" conclusion drawn from the main unit alone is how a shipment ends up non-compliant on the accessory.

PSC: Fifteen Products, and a Children's Category That Just Expanded

PSC works on the same list logic but covers non-electrical consumer goods where failure is acutely dangerous. The Enforcement Order names 15 specified products: household pressure cookers and pots at 10 litres or less designed for gauge pressure of 9.8kPa or more; motorcycle and moped helmets; infant beds; mountaineering rope for body belay; portable laser applied devices; bathtub water circulators; kerosene water heaters, bath boilers and stoves within stated consumption limits; lighters with a plastic fuel container; magnetic recreational products and water-absorbing resin toys below sizes set by ministerial ordinance; infant toys for children under 36 months; infant bed guards for children up to 60 months; and pushchairs for children up to 36 months.

Four of those are Special Specified Products, requiring third-party conformity assessment rather than self-declaration — the PSC analogue of the diamond mark: infant beds, portable laser applied devices, bathtub water circulators, and lighters. Certificate retention periods are set per item, at ten years for infant beds and three for the other three.

The live part is the children's category. The December 2025 amendment created a separate class of Children's Specified Products with their own Children's PSC mark, and the list has filled in on a staggered schedule: infant toys with the amendment on 25 December 2025, then infant bed guards and pushchairs from 8 July 2026, with transition periods letting unmarked stock sell for one year and two years respectively — so bed guards must be marked from July 2027, pushchairs from July 2028. If you sell baby gear into Japan, those are the last dates existing inventory can clear.

Who Is Legally on the Hook — and What Changed in December 2025

The most important structural fact about PSE is one line in METI's own explanation: this is not a national certification scheme. The state does not approve your product. A business operator files a notification, judges conformity on its own responsibility, and labels the goods. A registered inspection body's certificate, where required, is an input to that judgement, not a government approval you can point to.

That has always meant the duties land on the importer. Article 3 requires anyone who begins manufacturing or importing a listed electrical appliance to notify METI within 30 days of starting the business, giving the company name, head office address and representative, the type classification, and — for imports — the overseas manufacturer's name and address. Filing goes to the METI regional bureau covering the office, warehouse or store involved. Keep the filed copy: it gets requested at on-site inspections and at marketplace listing review.

Until recently, an overseas company selling directly to Japanese consumers with no Japanese importer in the chain fell into a gap — nobody in Japan carried the legal responsibility. The amendment to Japan's four product safety acts, in force from 25 December 2025, closed it:

• Specified Import Business Operator. An overseas business selling directly to Japanese consumers through a marketplace can now file the notification itself, and carries the full set of duties: notification, conformity confirmation, per-unit inspection and labelling.
• Domestic Administrator, mandatory. That operator must appoint someone in Japan responsible for product safety measures — individual or corporate, but with an address in Japan and the ability to hold a conversation in Japanese. Without one, the operator cannot affix the PS mark and cannot sell. METI also warns that administrators have been filing without the operator's consent, and that failure by the administrator can trigger a labelling prohibition against the operator. How this role compares with the tax, customs and company-law appointments is set out in our local agent representation guide.
• Takedowns and publication. Where a product on a platform poses a risk and the seller cannot be expected to act, METI can require the platform to remove the listing. Notification details, including the administrator's name, can be published so platforms can screen out unnotified overseas sellers — as can the names of those who breach the law or an order under it.

The filing mechanics contain a trap worth planning around. METI's electronic filing system requires a gBizID Prime account, which requires a Japanese corporate number — so an overseas business without one cannot use the online route and must contact METI directly or file through a Japanese agent with a power of attorney. Beyond the notification form, the package includes the administrator's certificate of registered matters or residence record issued within the last three months, a certificate of authority, a copy of the delegation contract in Japanese or English, and a written pledge. The contract must cover the communication channel with METI, recall and harm-prevention measures, the administrator's authority to receive dispositions and notices, retention and provision of inspection records and conformity certificates, and cooperation with reporting and on-site inspection. That is a real contract with a real counterparty, not a mail-forwarding address — a decision with the same weight as choosing your importer of record and market entry sequence, and one that sits alongside the rest of a cross-border selling structure for Japan.

What It Costs, With Real Numbers

Fees for the diamond route are published, and an actual schedule beats a range. JET, the largest domestic registered inspection body, sets the fee as a testing charge (a standard charge for the item type, plus component testing) plus an equipment confirmation charge per factory. Its worked examples, effective 1 April 2024, excluding consumption tax:

• A moulded plug (125V, 15A, vinyl cord): standard item testing ¥95,900; component testing ¥192,800 where the cord is unmarked, or nil where the cord already carries a diamond PSE mark. Factory confirmation is ¥85,700 plus travel expenses on site, or ¥14,300 on documents. Total across the four combinations: ¥110,200 to ¥374,400 plus travel.
• An aquarium heater (single phase, 100V, 20W, with thermostat): standard item testing ¥133,600; component testing ¥25,500 where the thermostat is a registered part, ¥109,100 where it is not. Totals: ¥173,400 to ¥328,400 plus travel.

Three planning points fall out of those numbers. The biggest single swing is not the test — it is whether the factory audit is done on documents (¥14,300) or on site (¥85,700 plus travel to your factory, wherever it is). Component choice moves the bill materially: specifying a cord or thermostat that already carries certification cut the plug example by ¥192,800 and the heater example by ¥83,600. And these are one product, one factory — a range of five variants built at two plants multiplies both halves.

Published fees are not published lead times. Industry guides aimed at importers put the self-declaration route at roughly two to three months end to end and the specified route at three to six, with the testing queue alone running one to three months — an industry estimate, not a primary source, because no official body publishes a turnaround commitment. Confirm lead time in writing with the body you approach, and check the scope constraint below before you choose which one.

Not every body can certify your category

Registration is granted per product division, not in general. METI's current list shows nine domestic registered bodies and seven foreign ones, with sharply varying scopes: JET across all ten divisions, TÜV Rheinland Japan across nine, JQA across five, while UL Japan, Intertek Japan and SGS Japan each hold a single division — AC electrical machinery and apparatus. Foreign registered bodies sit in Taiwan, mainland China, Hong Kong, the United States and Singapore, which matters for sample logistics: you need not ship samples to Japan if a body registered for your division is closer to your factory. Check the division before requesting a quotation, or what comes back will be a decline.

The Obligation That Does Not End at Launch

The single most commonly mis-budgeted part of PSE is what happens after certification, because it is not a project cost — it is a per-unit operating cost that runs for as long as you import.

Article 8(2) requires the notifying business operator to inspect every unit manufactured or imported, not a sample, and to create and retain a record — for three years under the implementing ordinance. METI describes the completed-product inspection as three checks: a visual inspection covering labelling legibility, cracks, deformation and correct assembly; a dielectric strength test between supply and enclosure; and an energisation test confirming no abnormal heat, smell, noise or smoke. Lithium-ion batteries are checked visually and for output voltage. Each record must carry six fields: product name and type classification with a summary of construction, materials and performance; date and place of inspection; the name of the person who performed it; quantity; method; and result. Specified appliances add continuous in-process inspection and sample testing whenever design, method or equipment changes.

You may delegate the inspection to the overseas manufacturer. You may not delegate the responsibility. METI's guidance says it directly: holding a test report is not the same as having discharged the obligation. In practice this means a line in your landed cost, a document flow with your factory that has to survive staff changes on both sides, and a retention system that can produce three years of records on request — the same operational-continuity problem as holding personal data as an overseas seller, in a different register.

How This Gets Found Out

METI runs test purchases, on-site inspections (by METI or NITE for manufacturers and importers, by local government for sellers) and internet patrols of listings — and has formally requested that marketplace operators screen listings before they go live. That last channel is where most overseas sellers meet the regime. Rakuten requires an image of the mark on the product body to appear on the product page, plus the mark type, notifying operator's name and, where applicable, registered inspection body name in the description, applying sales suspension and then store suspension for non-compliance. LINE Yahoo requires a clear image of the mark and patrols listings against defined search conditions. Platforms request a copy of the notification form, and METI states plainly that submitting an unrelated Japanese company's notification is not merely invalid but potentially a document forgery offence.

Where compliance cannot be verified, listings are refused or deleted, and existing listings are removed on patrol. If you cannot account for conformity when challenged, METI may direct a recall of stock already sold. This is the same pattern seen in Rakuten's category compliance requirements and in how marketplaces handle regulated claims under the Pharmaceutical and Medical Device Act: the platform is the enforcement surface, and it acts faster than any regulator.

The statutory penalties sit behind all of it: up to one year's imprisonment or a ¥1 million fine, or both, for selling or displaying without the required label; up to ¥300,000 for failing to file the Article 3 notification or to inspect and keep records; and, under the dual liability provision, up to ¥100 million on a corporation whose officer or employee breaches a labelling prohibition or a recall order.

How to Decide, in Order

Five steps, in sequence, resolve this before it becomes a launch-date problem:

1. Check every item in the carton against the named lists, not just the main unit. Read the METI lists with their rating limits — for the adapter, the cord set and any spare battery as well as the product — at range selection, not after the purchase order.
2. Determine which route each item is on. Non-specified means self-declaration and a round mark. Specified means a registered body, a factory audit, a diamond mark and a certificate with an expiry date. If anything in the range is specified, that item sets the critical path for the whole launch.
3. Decide who the notifying business operator will be, before you file anything. A Japanese importer of record, or your own company as a Specified Import Business Operator with a Domestic Administrator appointed under a contract covering the five required subjects. This determines who carries the liability — a commercial decision, not a formality.
4. Price the whole obligation, not the certificate. Fees per product per factory, on-site versus documentary audit, component choices that avoid re-testing, renewal at the item's three-, five- or seven-year expiry — plus the per-unit inspection and three-year record retention that run for as long as you import.
5. Build the marketplace evidence pack before you list. Product-body mark image, mark type, notifying operator's name, registered body name where applicable, and your notification form ready to produce. A listing blocked at review costs the same launch window as a certificate you never started.

The pattern we see is rarely a brand that ignored the rules. It is a brand that checked the wrong object — reading the appliance and missing the adapter, or reading a summary written before December 2025 and assuming an overseas seller cannot be the responsible party at all. Both are cheap to fix in the weeks before a purchase order and expensive once stock sits in a Japanese warehouse.

Where we fit is narrow and worth stating plainly. LAUNOVA runs Japanese storefronts and marketplace operations for overseas brands. We are not a registered inspection body or a certification agent; we do not test products, issue certificates or file safety notifications, and this article is not legal advice. Conformity assessment belongs with a registered inspection body, and scope determination with a qualified technical consultant or a licensed administrative scrivener (行政書士); the fee figures here are one body's published schedule at the date stated, not a quotation. What we do is make sure the certification path, the responsible-party structure and the listing requirements are settled against a real launch sequence rather than discovered in the wrong order. If that is where your Japan plan sits, tell us what you are planning to sell. Scope and pricing are quoted against the work rather than published as a rate card.