JAPAN Trends and Developments Contributed by: Shingo Yamada, Yugo Komori, Yasuhiro Akita and Yusei Kanehara, Oh-Ebashi LPC & Partners
Product Safety Pledge The Product Safety Pledge is a voluntary, public–pri - vate initiative aimed at enhancing the protection of consumers from recalled and unsafe products listed or sold on online marketplaces (OMs). The Japanese version of the Product Safety Pledge was established in June 2023 through collaboration between regulato - ry authorities concerned with product safety, including the Ministry of Economy, Trade and Industry (METI), and operators of online marketplaces, taking into account the “Statement on Product Safety Pledges” published by the OECD. The Product Safety Pledge sets out 12 commitments concerning recalled and unsafe products. The com - mitments include, inter alia, the regular monitoring of relevant information and appropriate responses, the establishment of contact points for receiving notifica - tions from regulatory authorities and requests for the removal of listings, and the removal of listings upon receipt of such requests. OM operators wishing to participate in the Product Safety Pledge are required to demonstrate that they have sufficient capability to implement all 12 com - mitments. They must submit documentation detailing how each commitment will be fulfilled, and, following execution of the pledge by their representative, submit a copy of the signed pledge to the Consumer Affairs Agency. As of January 2026, nine OM operators have signed the Product Safety Pledge. Law and guidelines relating to artificial intelligence The Act on the Promotion of Research, Development, and Utilisation of Artificial Intelligence-Related Tech - nologies (commonly referred to as the “AI Act”) has been in force since 4 June 2025, in order to promote AI innovation whilst addressing associated risks. There are multiple guidelines on AI that were issued by METI, prior to the enactment of the AI Act; for example, on 19 April 2024, the AI Business Operator Guideline was issued. This guideline was amended on 31 March 2026, which sets out the basic principles regarding the measures required for AI development, provision and use. The guideline defines the respon - sibilities of AI developers, AI providers and AI users,
Responsible Person”) tasked with implementing measures to prevent the occurrence and expansion of harm to general consumers, and must notify the Ministry of Economy, Trade and Industry accordingly. The Domestic Responsible Person must meet certain requirements, including having an address in Japan and the ability to communicate in Japanese. Obligations of DPF providers Pursuant to the Four Product Safety Acts, persons who provide a marketplace for transactions on digital platforms (DPFs) to consumers in Japan (“DPF Provid - ers”) are subject to the following obligations, irrespec - tive of whether the DPF or the DPF Provider is located within Japan. In particular, DPF Providers are under a duty to endeavour to co-operate with measures taken by manufacturers and other relevant business opera - tors of Specified Products in response to hazard-pre - vention orders, including product recalls and related actions. Furthermore, where there is a risk of harm to general consumers using a DPF, the regulatory author - ities may request that DPF Providers take measures such as the removal of product listings. Regulation of specified products for children Under the CPSA, among the Specified Products des - ignated therein, certain products primarily intended for use in children’s daily lives and recognised as requir - ing labelling, such as indications regarding methods of use and other warnings necessary to prevent harm to children’s life or body, are designated by Cabinet Order as “Specified Products for Children”. In respect of such products, the CPSA principally pro - vides that manufacturers and importers must ensure compliance with both technical standards and age- appropriateness standards. In addition, they are required to affix to the product indications of the target age, precautions for use, and other relevant warnings, together with the Children’s PSC mark. To date, the products designated by Cabinet Order as Specified Products for Children include infant beds and toys for infants; however, it is anticipated that fur - ther categories will be added in due course.
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