Product Liability and Safety_2026

JAPAN Trends and Developments Contributed by: Shingo Yamada, Yugo Komori, Yasuhiro Akita and Yusei Kanehara, Oh-Ebashi LPC & Partners

Oh-Ebashi LPC & Partners Kishimoto Building 2F 2-2-1 Marunouchi, Chiyoda-ku Tokyo 100-0005 Japan Tel: +81 3 5224 5566 Fax: +81 3 5224 5565 Email: yugo.komori@ohebashi.com Web: www.ohebashi.com/en/

Introduction Discussions concerning product safety and prod - uct liability in Japan can be traced back to incidents such as the nylon rope rupture accidents of the 1950s. Thereafter, the legal and regulatory framework was progressively strengthened: the Consumer Prod - uct Safety Act entered into force in 1974; the Prod - uct Liability Act entered into force in 1995; and, in 2007, the Recall Handbook for Consumer Products was issued. Through these and other developments, Japan’s regime for product safety and product liability has been steadily reinforced. At present, this framework in Japan is entering a new transitional phase. In a manner comparable to devel - opments in the European Union – where in recent years the General Product Safety Regulation has come into force and the Product Liability Directive has undergone comprehensive revision – numerous laws and guidelines in Japan relating to product safety and product liability have been enacted and amended in light of factors such as the expansion of online shop - ping and the advancement of a digital and circular economy. Further deliberations and reviews remain ongoing. The following sections set out explanations of product safety and product liability respectively, with a particu - lar focus on the enactment and amendment of recent key legislation and guidelines, as well as the current state of related discussions.

Product Safety Amendments of the Four Product Safety Acts In recent years, four principal statutes relating to prod - uct safety in Japan (the “Four Product Safety Acts”) have been amended and have been in force since 25 December 2025. Specifically, the Four Product Safe - ty Acts comprise the Consumer Product Safety Act (CPSA), the Electrical Appliances and Materials Safety Act (EAMSA), the Gas Business Act (GBA), and the Act on the Securing of Safety and the Optimisation of Transaction of Liquefied Petroleum Gas (LPGA). Each of these statutes regulates a particular catego - ry of products (“Specified Products”). The principal aspects of the amendments are as follows. Strengthening of regulations applicable to overseas business operators As a result of the present amendments, overseas busi - ness operators that directly sell Specified Products to consumers in Japan (defined as “Specified Import - ers”) have been brought within the scope of regula - tion. Specified Importers include overseas operators that sell products through digital transaction platforms (DPFs) operated by third parties, as well as those that sell products through their own websites targeting the Japanese market. Specified Importers are required to ensure that Spec - ified Products comply with the technical standards prescribed by law, and they are prohibited from selling Specified Products that do not bear markings (such as the PSC mark) indicating conformity with such stand - ards. In addition, Specified Importers must appoint, within Japan, a responsible person (a “Domestic

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