Legal Requirements for Selling Online in Japan: A Complete Guide
Japan is one of the most attractive ecommerce markets in the world, but it is also one of the most regulated. Over the past five years, we at noren have helped more than 50 brands launch Shopify stores in Japan, and we can say with certainty that legal compliance is not optional, not secondary, and not something you can figure out later. It is the foundation on which every successful Japan ecommerce operation is built.
Non-compliance can result in administrative orders, fines of up to tens of millions of yen, forced store closures, and in severe cases, criminal penalties including imprisonment. We have seen foreign brands receive cease-and-desist notices within weeks of launching because they failed to include a legally required disclosure page. We have seen product shipments seized at customs because of missing safety certifications. These are not hypothetical risks.
This guide covers every major legal requirement you need to understand before selling online to Japanese consumers. We will walk through consumer protection law, tax display rules, the invoice system, data privacy, product-specific regulations, advertising restrictions, business entity options, and trademark protection. At the end, you will find a practical compliance checklist you can use as you build your Shopify store for Japan.
特定商取引法 (Tokushoho): The Specified Commercial Transactions Act
What It Is
The Specified Commercial Transactions Act, known in Japanese as 特定商取引法 (Tokutei Sho Torihiki Ho) or simply Tokushoho, is Japan's primary consumer protection law governing online sales. It is administered by the Consumer Affairs Agency (消費者庁) and applies to any business selling products or services to consumers in Japan, regardless of where that business is incorporated.
If Japanese consumers can buy from your Shopify store, Tokushoho applies to you.
Required Disclosure Items
Under Tokushoho, every online store must display a dedicated page containing specific business and transaction information. This page is commonly titled 特定商取引法に基づく表記 (Notation Based on the Specified Commercial Transactions Act). The following items must be disclosed:
- Business name (事業者名) - Your legal entity name. If you operate as a sole proprietor, your full personal name is required.
- Representative name (代表者名) - The name of the company representative or business owner.
- Physical address (所在地) - A real, physical business address is mandatory. PO Boxes are not acceptable. If you operate from a home address and do not wish to disclose it publicly, the law allows you to state that the address will be provided promptly upon request, but you must then provide it without delay when asked.
- Phone number (電話番号) - A working telephone number where consumers can reach your business. Similar to the address, you may note it will be provided upon request, but prompt disclosure is required.
- Email address (メールアドレス) - A contact email for customer inquiries.
- Product or service pricing (販売価格) - Prices must be displayed inclusive of consumption tax (more on this below).
- Additional charges (商品代金以外の必要料金) - Shipping fees, handling charges, and any other costs the consumer will bear.
- Payment methods and timing (支払方法・支払時期) - All accepted payment methods and when payment is collected.
- Delivery timeline (引渡し時期) - When the consumer can expect to receive the product after ordering.
- Return and cancellation policy (返品・キャンセルに関する事項) - Your return policy, including whether returns are accepted, under what conditions, and who bears the return shipping cost. If you do not accept returns, this must be clearly stated.
- Conditions for contract formation (申込みの有効期限等) - When the purchase contract is considered formed (typically at order confirmation or shipment).
Where to Display It
The Tokushoho disclosure page must be easily accessible from anywhere on your site. Standard practice in Japan is to create a dedicated page and link to it from the site footer. On Shopify, we at noren typically create this as a standalone page (e.g., /pages/legal or /pages/tokushoho) and add it to the footer navigation menu.
The page should be in Japanese. If your store is bilingual, maintain both a Japanese and English version, but the Japanese version is the legally operative one.
Template Example
Below is a simplified example of how a Tokushoho page is typically structured. This is for illustrative purposes; your actual page must reflect your real business details.
| 項目 (Item) | 内容 (Details) |
|---|---|
| 事業者名 | noren株式会社 (noren Inc.) |
| 代表者名 | 山田太郎 |
| 所在地 | 〒150-0001 東京都渋谷区神宮前1-1-1 |
| 電話番号 | 03-XXXX-XXXX(受付時間:平日10:00~18:00) |
| メールアドレス | info@example.co.jp |
| 販売価格 | 各商品ページに税込価格を表示 |
| 商品代金以外の必要料金 | 送料:全国一律660円(税込)、10,000円以上のご注文で送料無料 |
| 支払方法 | クレジットカード(VISA, Mastercard, AMEX, JCB)、PayPay、コンビニ決済、銀行振込 |
| 支払時期 | クレジットカード:ご注文時 / コンビニ決済:ご注文後7日以内 / 銀行振込:ご注文後7日以内 |
| 引渡し時期 | ご注文確認後、3~5営業日以内に発送 |
| 返品・交換 | 商品到着後7日以内にご連絡ください。未使用品に限り返品・交換を承ります。お客様都合の場合、返送料はお客様負担となります。不良品の場合は当社負担。 |
| 申込みの有効期限 | 注文確認メール送信時に契約が成立します |
Penalties for Non-Compliance
Violations of Tokushoho can result in administrative orders (業務改善指示), suspension orders (業務停止命令) for up to two years, and fines. For serious violations involving fraud or deceptive practices, criminal penalties of up to three years imprisonment or fines of up to 3 million yen for individuals (or 100 million yen for corporations) may apply. The Consumer Affairs Agency actively monitors online stores and acts on consumer complaints.
総額表示義務: Tax-Inclusive Pricing Obligation
Since April 2021, all consumer-facing prices in Japan must include consumption tax. This is not a suggestion; it is a legal obligation under the Consumption Tax Act. Every price that a consumer sees on your Shopify store must include the 10% consumption tax.
How to Display Prices
The most common and recommended format is:
¥1,100(税込)
The notation 税込 (zeikomi) means "tax included." While other formats are technically acceptable (such as showing the tax-exclusive price alongside the tax-inclusive price), the safest and most consumer-friendly approach is to show the tax-inclusive price prominently, optionally followed by the tax-exclusive amount in smaller text.
Acceptable examples:
- ¥1,100(税込)
- ¥1,100(税込 / 本体価格 ¥1,000)
- ¥1,100(うち消費税 ¥100)
Unacceptable: Displaying ¥1,000 + tax, or ¥1,000(税別)without prominently showing the tax-inclusive total.
The Reduced Tax Rate
Japan applies a reduced consumption tax rate of 8% to food products and non-alcoholic beverages (intended for takeout or home consumption). If you sell food or beverages on your Shopify store, your prices for those items should reflect the 8% rate, not 10%. Alcohol is taxed at the standard 10% rate.
Common Shopify Mistakes
We at noren frequently encounter these tax display issues on Shopify stores targeting Japan:
- Tax not included in displayed prices. Shopify's default behavior in many configurations shows prices exclusive of tax, with tax added at checkout. For Japan, you must configure your store so that product prices include tax.
- Missing 税込 notation. Even if your prices include tax, Japanese consumers expect to see the 税込 label. Use theme customization or metafields to append this.
- Incorrect tax rate for food products. If you sell both food (8%) and non-food (10%) items, you need to configure separate tax rates in Shopify. This requires careful product tagging and tax override settings.
- Cart and checkout showing tax separately. Ensure the entire purchase flow, from product page to checkout confirmation, displays tax-inclusive pricing consistently.
インボイス制度: The Qualified Invoice System
Japan implemented its Qualified Invoice System (インボイス制度, also called the Invoice System) on October 1, 2023. This system primarily affects B2B transactions and the ability of business buyers to claim input tax credits on consumption tax.
When It Applies
If your customers include businesses that need to claim consumption tax deductions, they will require a qualified invoice (適格請求書) from you. This is especially relevant if you sell wholesale, offer corporate gifting, or serve business customers alongside consumers.
Registration Requirements
To issue qualified invoices, you must register as a Qualified Invoice Issuer (適格請求書発行事業者) with the National Tax Agency. Upon registration, you receive a registration number (T + 13-digit number for corporations, or T + 13-digit number assigned for sole proprietors). This number must appear on all invoices you issue.
A qualified invoice must include:
- Name and registration number of the issuer
- Date of the transaction
- Description of goods or services
- Price by tax rate category (8% and 10% items listed separately)
- Consumption tax amount by rate
- Name of the recipient
Impact on Your Shopify Store
For primarily B2C sellers, the invoice system's direct impact is limited, as individual consumers generally do not claim input tax credits. However, if even a portion of your customers are businesses, you should register and ensure your order confirmation emails or printed receipts meet the qualified invoice requirements. Shopify's built-in receipts and order confirmations may need customization to include your registration number and the required tax breakdowns.
個人情報保護法 (APPI): Japan's Data Privacy Law
The Act on Protection of Personal Information (個人情報保護法, commonly referred to as APPI) is Japan's comprehensive data privacy law. Amended significantly in 2022, it governs how businesses collect, use, store, and transfer personal information of individuals in Japan.
Privacy Policy Requirements
Any business handling personal information of Japanese consumers must publish a privacy policy (プライバシーポリシー) that discloses:
- The purpose of collecting and using personal data
- How data is managed and secured
- Whether data is shared with third parties, and if so, with whom
- How individuals can request disclosure, correction, or deletion of their data
- Contact information for privacy-related inquiries
Cookie Consent
Japan's approach to cookies is less prescriptive than the EU's GDPR. APPI does not explicitly require cookie consent banners in all cases. However, the 2022 amendments introduced the concept of "personally referable information" (個人関連情報), which covers cookies and device identifiers when they can be linked to an individual at the receiving party's end. If you share cookie data with third parties (such as ad platforms) who can link it to individuals, you need the individual's consent.
In practice, we at noren recommend implementing a cookie consent mechanism on Japanese Shopify stores, particularly if you use tracking pixels, retargeting ads, or analytics tools that share data with third parties. This protects you legally and aligns with growing privacy awareness among Japanese consumers.
Cross-Border Data Transfer
This is critically important for foreign companies. Under APPI, transferring personal data of Japanese individuals to a third country requires one of the following:
- The individual's consent, with prior information about the destination country's data protection system
- The receiving country having data protection standards recognized as equivalent to Japan's (the EU, UK, and a few others qualify)
- The receiving party implementing data protection measures equivalent to APPI standards, verified through regular audits
If you operate your business outside Japan and store customer data on servers outside Japan (as is common with Shopify's infrastructure), you must address cross-border transfer in your privacy policy and, in many cases, obtain consent.
APPI vs. GDPR
APPI and the EU's GDPR share philosophical similarities but differ in important ways:
| Aspect | APPI (Japan) | GDPR (EU) |
|---|---|---|
| Legal basis for processing | Purpose specification and notification | Six legal bases including consent and legitimate interest |
| Consent requirements | Required for sensitive data and cross-border transfers | Required as one of six legal bases; stricter opt-in requirements |
| Cookie regulation | Limited; mainly for third-party sharing | Explicit consent required (via ePrivacy Directive) |
| Data breach notification | Required to Personal Information Protection Commission and affected individuals | 72-hour notification to supervisory authority |
| Penalties | Up to 100 million yen for corporations | Up to 4% of global annual revenue or 20 million euros |
| Right to be forgotten | Right to request deletion (narrower scope) | Broad right to erasure |
If you are already GDPR-compliant, you have a strong foundation, but you cannot assume full APPI compliance. Specific adjustments are needed, particularly around cross-border transfer disclosures and the handling of personally referable information.
Product-Specific Regulations
Beyond the general legal requirements, Japan has extensive product-specific regulations that can catch foreign sellers off guard. Here are the most important ones we encounter at noren.
Electrical Products: PSE Mark
Any electrical product sold in Japan must carry the PSE (Product Safety of Electrical Appliances and Materials) mark. There are two types: the diamond-shaped PSE mark for high-risk products (such as cables, adapters, and lithium-ion batteries) and the circular PSE mark for other electrical products. Selling electrical products without the appropriate PSE mark is illegal and can result in product seizure, fines, and criminal penalties.
If you import electrical products to sell on your Shopify store in Japan, you must ensure they have been tested and certified by a registered conformity assessment body and carry the correct PSE mark.
Food Products: Food Sanitation Act
Importing food into Japan for sale requires compliance with the Food Sanitation Act (食品衛生法). All food imports must be notified to quarantine stations, and products must meet Japan's standards for additives, pesticide residues, labeling, and packaging. Food labels must be in Japanese and include ingredients, allergens (Japan has its own list of mandatory allergen disclosures, which differs from other countries), nutritional information, expiration dates, and storage instructions.
Selling food online adds additional requirements under Tokushoho and potentially the Food Labeling Act (食品表示法). We strongly recommend working with a specialized food import consultant if this is your product category.
Cosmetics
To sell cosmetics in Japan, you must register with the prefectural government where your business is located as a Cosmetics Manufacturing and Sales Business (化粧品製造販売業). This applies even if you are only importing and selling cosmetics, not manufacturing them. The registration process requires appointing a qualified responsible person (総括製造販売責任者) who meets specific educational or experience criteria.
Each cosmetic product must also be individually notified or approved, depending on whether it is classified as a "cosmetic" or a "quasi-drug" (医薬部外品) under Japanese regulations.
Pharmaceuticals
Japan's Pharmaceutical and Medical Device Act (薬機法, formerly the Pharmaceutical Affairs Act) strictly regulates the sale of pharmaceuticals, medical devices, and quasi-drugs. Many products that are sold freely over the counter in other countries require specific licenses to sell in Japan. Online sales of certain categories of pharmaceuticals require a licensed pharmacist and specific regulatory approvals. This is not an area where you can afford to guess. Professional legal and regulatory advice is essential.
Alcohol
Selling alcoholic beverages online in Japan requires a mail-order liquor sales license (通信販売酒類小売業免許) from the relevant tax office. The application process involves demonstrating proper facilities, financial stability, and compliance with liquor tax obligations. Without this license, selling alcohol through your Shopify store is illegal.
Supplements and Health Foods
Japan has strict rules about health claims on food products, including supplements. Under the Health Promotion Act and the Act against Unjustifiable Premiums and Misleading Representations, you cannot make medical or therapeutic claims about food products unless they are registered under specific government programs such as Foods for Specified Health Uses (特定保健用食品, TOKUHO) or Foods with Function Claims (機能性表示食品). Making unapproved health claims can lead to regulatory action, fines, and reputational damage.
景品表示法: Advertising and Promotional Restrictions
The Act against Unjustifiable Premiums and Misleading Representations (景品表示法, Keihin Hyoji Ho) regulates advertising, promotional activities, and product representations in Japan. Violations are actively pursued by the Consumer Affairs Agency and can result in administrative orders, surcharges, and public naming of offending companies.
Sale and Discount Display Rules
If you run sales or display discounted prices on your Shopify store, you must follow strict rules:
- The original price must have been the actual selling price for a reasonable period. You cannot inflate a "regular price" just to show a larger discount. The general guideline is that the original price must have been offered for the majority of the most recent eight-week period.
- "Limited time offer" claims must be genuine. If you advertise a sale as ending on a specific date, it must actually end on that date.
- Comparison with competitor prices must be accurate and verifiable at the time of the advertisement.
Misleading Representations
It is illegal to make representations about your products that are significantly better than the reality (優良誤認表示) or to display prices and conditions that are significantly more advantageous than the reality (有利誤認表示). This covers everything from exaggerated product descriptions to misleading claims about materials, country of origin, or performance.
Influencer Marketing Disclosure
Following updated guidelines from the Consumer Affairs Agency, influencer marketing and "stealth marketing" (ステルスマーケティング, often called ステマ) are now explicitly regulated. As of October 2023, content created under the direction of a business must be clearly identified as an advertisement. If you work with Japanese influencers or content creators to promote products on your Shopify store, ensure that all sponsored content includes clear advertising disclosures such as PR, 広告, or プロモーション labels.
Business Entity Options for Foreign Companies
How you structure your business presence in Japan affects your legal obligations, tax treatment, and operational capabilities. Here are the main options we at noren see foreign brands use.
Cross-Border Selling (No Japan Entity)
You can sell to Japanese consumers from a foreign entity without establishing a presence in Japan.
- Pros: Lowest upfront cost, fastest to launch, no Japan corporate tax obligations (though consumption tax obligations may apply above certain thresholds)
- Cons: Limited payment method options (many Japan-specific payment methods require a Japan entity), consumers may be wary of purchasing from a foreign company, shipping logistics are more complex, returns handling is difficult, and you still must comply with Tokushoho and other consumer protection laws
- Limitations: Cannot obtain certain licenses (liquor, cosmetics) without a Japan presence, limited ability to partner with Japanese logistics providers, and some advertising platforms restrict access to foreign entities
株式会社 (KK / Kabushiki Kaisha): Standard Corporation
The Kabushiki Kaisha is Japan's standard corporate form, equivalent to a C-Corporation or Ltd.
- Setup cost: Approximately ¥200,000-300,000 in registration taxes and fees, plus professional service fees of ¥200,000-500,000
- Capital requirement: Minimum ¥1 technically, but ¥5,000,000+ is recommended for visa sponsorship and credibility
- Timeline: 2-4 weeks for incorporation, longer if directors are overseas residents
- Pros: Highest credibility with Japanese consumers, partners, and financial institutions; full access to all licenses and permits; ability to sponsor employee visas
- Cons: Higher setup and ongoing costs, annual corporate tax obligations, requires a representative director with a Japan address (though workarounds exist for foreign companies)
合同会社 (GK / Godo Kaisha): LLC Equivalent
The Godo Kaisha is Japan's equivalent of a Limited Liability Company.
- Setup cost: Approximately ¥60,000-100,000 in registration taxes (no notarization fee for articles of incorporation), plus professional service fees
- Timeline: 1-3 weeks
- Pros: Significantly cheaper to establish, simpler governance structure, flexible profit distribution
- Cons: Lower perceived credibility compared to a KK (though this matters less for online-only businesses), cannot issue shares, some Japanese companies prefer to do business with KK entities
Branch Office Registration
A foreign company can register a branch office (支店) in Japan without creating a separate legal entity.
- Setup cost: Approximately ¥60,000-90,000 in registration fees, plus professional service fees
- Timeline: 2-4 weeks
- Pros: Maintains single global entity structure, profits and losses flow to parent company
- Cons: The parent company bears full liability for branch operations, requires appointment of a Japan representative, some Japanese banks are reluctant to open accounts for branch offices
Trademark Registration in Japan
We cannot overstate the importance of registering your trademark in Japan before launching your store. Trademark squatting is a real and active problem in Japan. We at noren have seen multiple cases where foreign brands enter the Japanese market only to discover that someone has already registered their brand name or logo with the Japan Patent Office.
The Process
Trademark registration in Japan is handled by the Japan Patent Office (特許庁, JPO). Japan uses a first-to-file system, meaning the first party to file a trademark application generally has priority, regardless of who used the mark first. This is different from the United States, which uses a first-to-use system.
Timeline and Cost
- Timeline: 8-12 months from application to registration under normal examination. Expedited examination (早期審査) is available and can reduce this to 2-3 months in some cases.
- Cost: Government filing fees are approximately ¥12,000 per class at application, plus ¥32,900 per class at registration (for 10 years). Professional attorney fees typically add ¥100,000-200,000 per class. Total cost per class generally falls in the range of ¥150,000-350,000 (roughly $1,000-3,000 USD).
- Classes: You must register in each relevant Nice Classification class. An apparel brand, for example, might need Class 25 (clothing), Class 18 (bags), and Class 35 (retail services).
Why You Should File Before Launching
File your trademark application in Japan as early as possible, ideally before you announce any plans to enter the Japanese market. Once your brand becomes known in connection with Japan, the risk of squatting increases. If someone else registers your mark before you do, you face an expensive and time-consuming opposition or invalidation process, and there is no guarantee of success.
If you have an existing trademark in another country, you can use the Madrid Protocol to extend your registration to Japan, which can simplify the process and reduce costs.
Practical Legal Compliance Checklist for Shopify
Use this checklist as you prepare your Shopify store for the Japanese market:
- Tokushoho page created - Dedicated page with all required disclosure items, in Japanese, linked from the footer
- Tax-inclusive pricing configured - All product prices include consumption tax; 税込 notation visible
- Correct tax rates applied - 10% standard rate; 8% for food and non-alcoholic beverages
- Privacy policy published - In Japanese, covering APPI requirements including cross-border data transfer disclosures
- Cookie consent mechanism - Implemented if using third-party tracking or advertising pixels
- Return policy clearly stated - Both on the Tokushoho page and on a customer-facing returns page
- Product-specific licenses obtained - PSE certification, food import notifications, cosmetics registration, liquor license, or other applicable permits
- Advertising claims reviewed - All product descriptions and marketing materials compliant with 景品表示法
- Influencer content labeled - All sponsored or directed content clearly disclosed as advertising
- Invoice system registration - Completed if serving business customers; registration number displayed on invoices
- Trademark filed with JPO - Application submitted before public launch in Japan
- Business entity decision made - Cross-border, KK, GK, or branch office, based on your operational needs
- Legal counsel engaged - A Japanese attorney or legal services provider retained for ongoing compliance questions
Working with noren on Legal Compliance
We at noren are Shopify specialists, not lawyers. We do not provide legal advice, and we always recommend that brands work with qualified Japanese legal professionals for compliance matters. What we do offer is deep practical experience in building legally compliant Shopify stores for the Japanese market. We know exactly how to configure Shopify's tax settings, structure Tokushoho pages, implement privacy policies, and set up the technical infrastructure that supports compliance.
We also work with a network of trusted legal partners, including attorneys specializing in Japanese ecommerce law, trademark attorneys, and regulatory consultants for product-specific categories. When you work with noren, we can connect you with the right professionals and ensure that the legal and technical sides of your store work together seamlessly.
Japan's legal landscape for ecommerce is complex, but it is navigable. With the right guidance and thorough preparation, you can build a store that is fully compliant, earns consumer trust, and operates confidently in one of the world's most valuable ecommerce markets.
About noren
暖簾 (noren) is the traditional curtain that hangs at the entrance of Japanese shops. It represents craftsmanship, trust, and a warm welcome.
noren Inc. is a Tokyo-based Shopify Partner specializing in Japanese ecommerce. Over the past five years, we've built 50+ Shopify stores for Japanese and international brands across fashion, food & beverage, outdoor, beauty, and lifestyle categories.
Let us help you open your noren in Japan.