The Tokushoho Legal Notice Page Japan Requires: Every Field, and What Overseas Sellers Get Wrong

What the Page Is, and What Triggers the Duty

The Act on Specified Commercial Transactions (特定商取引法, Act No. 57 of 1976) regulates several selling formats. The one that captures ecommerce is 通信販売 — mail-order selling, defined in Article 2(2) as a sale where the trader receives the order by post "or other means specified by ordinance," which includes the internet, and which is not telephone solicitation. If you take orders from Japanese consumers through a website, an app or a marketplace listing, that is the box you are in.

Article 11 then attaches a disclosure duty not to the sale but to the advertisement: "where a seller advertises the terms of sale, it shall display the following matters in the advertisement." A storefront is an advertisement. Because listing a dozen statutory items beside every product would be unreadable, Japanese practice consolidated them onto a single linked page — the 特定商取引法に基づく表記 page. The page is a convention; the duty is the statute.

Two consequences follow immediately. First, the obligation is per-advertisement, so if you sell on Amazon.co.jp, Rakuten and your own Shopify store, each of those surfaces needs the disclosure, and each marketplace has its own form for it. Second, the page has to stay true. It is not a launch artefact you write once; if you change couriers, lead times, return terms or the person named as responsible, the page is now wrong, and being wrong is the state the enforcement provisions are written for.

The Field List: Article 11 Plus Ordinance Article 23

Article 11 lists five items on its face and then defers a sixth to ministerial ordinance. Article 23 of the Enforcement Ordinance fills that in with ten more. The combined list below is what a complete page carries; both sources are read from the current statutory text at e-Gov.

Most published pages are shorter than this, because several rows are conditional — you only carry the software row if you sell software, the subscription row if you sell subscriptions. But the first three rows of the ordinance list are not conditional for a foreign company running an online store, and they are the ones that stop launches.

The Three Fields Overseas Sellers Cannot Answer

An address. Ordinance Article 23(1) asks for the trader's address, and it is asking about the trader, not about a mailbox. A brand whose entire Japanese presence is a Shopify theme and a cross-border courier account has to decide what goes here — the overseas head office, or a Japanese address it does not yet have. There is no third option where the field is left blank. This is also the point at which platform policy and the statute diverge in ways worth checking before you commit to a channel: some Japanese-market platforms will not accept an overseas address at registration at all, which is one of the structural differences in our comparison of BASE and Shopify for a foreign-owned Japanese store.

A telephone number. Same subsection, and the one most often fudged. A number is not an email address and not a contact form. If your support model is asynchronous, the disclosure duty and the support model have to be reconciled before launch rather than after the first complaint.

A named individual. Ordinance Article 23(2) requires a corporation advertising electronically to publish the name of its representative or of the person responsible for mail-order operations. That is a genuine choice with a real consequence: you can name the CEO of the parent company, or you can name whoever actually runs the Japanese channel. Overseas brands frequently default to the former without noticing that the same statute, at Article 15-2, lets the competent minister bar directors and employees personally — for the same period as a business suspension — from starting the same business again, where the ordinance's test of having played a leading role is met. Naming a person is a governance decision, not a form field.

And then the fourth, which only bites if you have already succeeded: Ordinance Article 23(3) says that a foreign corporation, or an individual domiciled abroad, that has an office or equivalent establishment in Japan must also publish that office's location and telephone number. Open a Japanese branch, hire a country manager with a desk, take space at a 3PL you control, and a disclosure obligation attaches that did not exist the day before. The page is one of the things that has to change when your Japanese footprint changes.

The Return Field Rewrites Your Policy If You Leave It Blank

Article 15-3(1) is the provision behind every summary that says Japan gives online shoppers eight days. Read precisely, it says that a buyer may withdraw the application or cancel the contract until eight days have elapsed from the day the goods were delivered — unless the seller displayed its own special terms on withdrawal. The eight-day right is therefore a default that applies when you said nothing, not a floor you cannot contract below.

That inverts the usual instinct about disclosure. Leaving the return field empty is not a neutral omission that a regulator might one day notice; it is an affirmative election of the statutory default, effective immediately, enforceable by any customer. Article 15-3(2) settles the one question sellers ask next: where the buyer exercises that right, the cost of collecting or returning the goods is borne by the buyer.

And this is where the disclosure page alone is not enough. The proviso to Article 15-3(1) sets a stricter test for electronic consumer contracts — which is what almost every online order is: there, the special terms must be displayed in the advertisement and by a further method prescribed by ordinance. Article 44 of the Enforcement Ordinance defines that further method as displaying the terms, conspicuously and legibly, on the screen where the customer performs the operation that constitutes the order. So a seller who writes excellent return terms on the 特定商取引法に基づく表記 page and says nothing about them at checkout has not met the proviso, and the eight-day default applies anyway. The terms have to appear in both places.

Two drafting rules sit alongside that. Ordinance Article 24(3) requires the withdrawal and cancellation terms — including any special terms — to be displayed somewhere the customer can easily see and read clearly. Burying them is treated differently from stating them. And Article 11(5) itself requires the content of the special terms, so "returns accepted under our policy" is not a disclosure; the window, the conditions and who pays shipping are. Whether you then want to operate that policy yourself or hand it to a partner is a separate decision, covered in our guide to outsourcing Japanese returns or handling them in-house.

Price, Shipping and Everything Else the Buyer Pays

Article 11(1) requires the selling price, and where shipping is not included in it, both the price and the shipping charge. Ordinance Article 24(1) adds that shipping must be shown as an amount. Ordinance Article 23(4) then catches everything else: where there is money the buyer must pay beyond the price under Article 11(1), you disclose its nature and its amount.

For a cross-border seller that last row is where the hard cases live. Import duty and consumption tax collected at the door, a courier's clearance handling fee, a cash-on-delivery charge, a gift-wrap fee — each is money the buyer pays that is not the selling price. "Customs charges may apply" names a category without giving an amount, which is what the subsection asks for. Where a charge genuinely cannot be quantified in advance, the honest structures are to absorb it into a delivered-duty-paid price or to state the basis and the range rather than to gesture at it.

Note that this is a separate question from the currency and tax-inclusive display rules that govern the price tag itself. Those we cover in whether a Japanese storefront should price in yen or dollars; here the point is narrower — whatever the buyer ends up paying, the disclosure page has to name it and quantify it.

When You May Legally Omit Fields

The proviso to Article 11 allows a seller to leave some items out of the advertisement if the advertisement states that it will, on request, supply a document or an electronic record containing them without delay. Ordinance Article 25 governs what that buys you, and the answer is: less than it sounds.

Article 25(1) permits omitting the buyer-borne charges only if you omit all of them, and even then the items you may further drop are enumerated, not open-ended. Article 25(2) covers the case where you do disclose all buyer-borne charges — and there the selling price is not among the items that may be dropped, which are limited to Article 11(2), (3), (5) and (6). Both routes carve out the same protected core: whether cancellation is possible, the period in which it is possible, the other conditions, and who bears the cost of collection or return. Article 25(2) adds a further proviso — you may not omit payment timing where you take money before delivery, nor the delivery-timing item where you do not dispatch promptly after the order, nor the liability terms where you exclude liability for non-conforming goods.

Read together, the omission route protects exactly the disclosures a consumer would need to evaluate a seller they are suspicious of. For a storefront, where marginal page length is free, the practical advice is simply to publish the full list. The proviso was written for print catalogues and constrained ad space, and invoking it on a website mostly creates an argument you did not need to have.

The Disclosure Page Is Not the Checkout Screen

A recurring and expensive misreading is that a complete 特定商取引法に基づく表記 page discharges the whole disclosure obligation. It does not. Article 12-6(1) imposes a separate duty on the final screen where a customer confirms a specific order: that screen must display the quantity of goods or services, plus the Article 11(1) to 11(5) items for that order. Article 12-6(2) prohibits displays that mislead the customer about whether pressing the button constitutes an order, or that mislead about those same items.

The consequences differ sharply. An Article 11 failure is handled administratively first. An Article 12-6 failure is directly criminal: Article 70(2) provides up to three years' imprisonment or a fine of up to 3 million yen, and where the violation is committed in a corporation's business, Article 74(1)(ii) raises the fine on the corporation to up to 100 million yen. Article 15-4 separately lets a customer who was misled by a false or missing Article 12-6 display rescind the order.

For most overseas brands this means the checkout template matters as much as the footer link — and on a platform you do not control, it means the platform's checkout has already made these choices for you, while on your own storefront they are yours.

What Enforcement Actually Looks Like

Not publishing the Article 11 items is not, by itself, a crime. It starts a chain:

1. An instruction (Article 14(1)). Where a seller breaches Article 11, 12, 12-6 or the related provisions and the minister considers that fair trading or buyers' interests may be harmed, the minister may instruct it to take measures correcting the breach and protecting buyers. This is an instruction, not yet a business order.
2. Ignoring the instruction (Article 71(2)). Up to six months' imprisonment or a fine of up to 1 million yen, or both.
3. Business suspension (Article 15(1)). Where the harm is serious, or the instruction is ignored, suspension of all or part of the mail-order business for up to two years. Where the trader is an individual, the minister may simultaneously bar them from serving as an officer responsible for that business in any company for the same period.
4. Personal bans (Article 15-2). When a suspension is imposed on a company, directors and employees — including those who held the role within the preceding year — can be prohibited personally from newly starting that business, for the same period. Article 43 of the ordinance narrows who this reaches: the person must have played a leading role in carrying out the suspended business.
5. Breaching a suspension (Article 70(3), Article 74(1)(i)). Up to three years or 3 million yen for the individual, and up to 300 million yen for the corporation.

Read the chain as a whole rather than as a list of maximum numbers: it escalates from a request to fix the page, to sanctions aimed at the company, to sanctions aimed at named people. The individual named under Ordinance Article 23(2) is who that chain eventually points at — which is why the choice deserves more thought than it usually gets.

Marketplace or Own Store: Who Fills This In

On Amazon.co.jp, Rakuten and Yahoo! Shopping, the disclosure lives in a seller-profile form the platform renders. The platform supplies the template and enforces completeness at onboarding; the content is the seller's, and so is the accuracy. That division is the source of a common failure mode in outsourced operations: the agency completes the onboarding form once, at launch, from whatever was true that week, and nobody owns it afterwards. When the brand later changes its return window or its contact number in one channel, the others silently go stale. If you run an agency arrangement, this page is worth naming explicitly in the scope — it is one of the items we flag when comparing a Rakuten ECC with an independent agency.

On your own storefront nothing is supplied. You write the page, choose where it links from, and decide what happens to it when operations change. The duty attaches to the advertisement either way; only the scaffolding differs.

One point the statute does not settle: language. Neither Article 11 nor Ordinance Article 23 specifies a language, and we have not found an official instrument that does. The practical position is that the duty runs to Japanese consumers, Japanese marketplaces render these forms in Japanese, and a disclosure a consumer cannot read is a weak answer to a complaint — so Japanese is the working standard, with an English version alongside it if you want one. Treat that as a practical judgement, not a quoted rule.

A Practical Sequence

1. Resolve the three hard fields before you build the page. Address, telephone number, named individual. These are business decisions with cost and governance attached, not copywriting.
2. Draft the return terms deliberately, and publish them twice. Decide whether you want the eight-day statutory default under Article 15-3(1) or your own terms. If your own, write the window, the conditions and who pays shipping — then display them both on the disclosure page and, per Article 44 of the ordinance, on the order screen itself. Only one of the two is not enough for an online order.
3. Enumerate every charge. Walk one real order end to end and list every yen the customer parts with. Each non-price item needs a nature and an amount under Ordinance Article 23(4).
4. Publish the full list rather than relying on the proviso. The omission route protects little and costs an argument.
5. Check the checkout screen separately. Article 12-6 is a different duty with a materially larger corporate fine attached. Confirm the confirmation screen shows the quantity and the Article 11(1)–(5) items.
6. Reconcile every channel. Each marketplace profile and your own page should say the same thing. Put a recurring check on it — this belongs in the same cycle as the rest of your monthly Japanese store operations.
7. Have a Japanese lawyer review the finished page. Everything above is the structure of the obligation. Whether your specific wording satisfies it is a legal judgement.

Common Mistakes

• Leaving the return field blank. This does not defer the question; Article 15-3(1) answers it for you with eight days from delivery.
• Stating return terms on the disclosure page only. For an electronic consumer contract the proviso to Article 15-3(1) requires the terms in the advertisement and on the order screen (ordinance Article 44). Miss the second and the eight-day default applies regardless of what the page says.
• Writing "as soon as possible" for delivery. Ordinance Article 24(2) asks for a period or a deadline.
• Writing "shipping varies by region." Ordinance Article 24(1) requires shipping to be expressed as an amount.
• Naming a department instead of a person. Ordinance Article 23(2) asks for the name of the representative or the responsible officer.
• Treating "other charges" as a disclaimer. Ordinance Article 23(4) asks for the nature and the amount of each.
• Assuming a complete page covers checkout. Article 12-6 is separate, and the corporate exposure behind it is an order of magnitude larger.
• Publishing once and never revisiting. A page that was accurate at launch and is inaccurate now is the condition the enforcement provisions are written about — and opening a Japanese office adds a field under Ordinance Article 23(3) that was not there before.

Where LAUNOVA Fits

The boundary first. LAUNOVA is an ecommerce operations firm, not a law firm. We do not certify wording as compliant, do not advise on whether the Act reaches a particular cross-border structure, and do not represent anyone before Japanese authorities. A Japanese lawyer does that work, and this article is background for that conversation rather than a substitute for it.

What sits with us is the operating layer underneath the page. Which of these fields can your business populate today, and which describe something you do not have yet. What your return window actually is once the warehouse, the courier and the marketplace rules are accounted for, rather than what the draft policy says. Whether the disclosure on your Rakuten profile, your Amazon.co.jp profile and your own storefront say the same thing this month. And what has to change on the page when the operation changes. If you are planning a Japanese launch, our overview of cross-border ecommerce into Japan sets out how these pieces fit together — tell us your brand, your channels and your launch date and we will scope the operating side. Pricing is quoted against the work rather than published as a rate card.