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Exporting electrical and electronic products from Japan

Electronics leave Japan on an export declaration to Customs. Under the Foreign Exchange and Foreign Trade Act, cryptographic equipment meeting METI's specifications needs export permission, though the METI order excludes many civilian goods using public or commercial encryption. Chapters 84 and 85 of the tariff fall in the catch-all, and laptops for Russia need approval.

Updated · Each section links to the official source it comes from

Export control law
Foreign Exchange and Foreign Trade Act, Article 48
Encryption
Appended Table 1, row 9; METI goods order, Article 8(ix)
Catch-all
Tariff classes 68 to 93, including Chapters 84 and 85
Russia
METI approval for listed goods, including portable computers
Certificates of origin
Chambers of commerce; EPA self-certification

Before the goods leave

The questions to answer, in the order they usually come up.

  1. 1Does the product have a cryptographic function, and is it within row 9 or one of its exclusions? Read more
  2. 2Has METI notified you that an application for export permission is needed? Read more
  3. 3Does the buyer want a certificate of origin or preferential origin? Read more
  4. 4Who declares it to Customs, and with which permission? Read more
  5. 5Is the export permit kept for the consumption tax exemption? Read more

The rules, by area

What each area covers, the texts that set it, and what the official pages say.

Encryption and telecommunications equipment

Row 9 of Appended Table 1 to the Export Trade Control Order lists telecommunications and cryptographic equipment that meets METI's specifications; exports to any region need permission.

  • Row 9 covers, among others, transmission telecommunication equipment and cryptographic equipment or its components, with specifications set by METI order.
  • Article 8(ix) of the METI goods order lists cryptographic equipment using symmetric keys longer than 56 bits, or listed asymmetric algorithms, for data confidentiality, such as security devices, telecommunications devices and computers.
  • It excludes, among others, civilian mobile phone terminals meeting stated conditions, wireless personal area network devices using only public or commercial encryption standards, and certain network-connected terminals and devices for civilian or industrial use that use only public or commercial encryption standards which users cannot change.
  • These texts are cited from English translations as amended in 2021 and 2023; METI's current Japanese text governs.

How we help: Compliant Always keeps the classification, and the clause relied on for an exclusion, with the product record, and answers importers' questions from it. Ask about this

Export controls (FEFTA)

Under the Foreign Exchange and Foreign Trade Act, some goods need METI permission or approval before export.

  • Exporting goods listed in Appended Table 1 of the Export Trade Control Order to the regions listed needs the permission of the Minister of Economy, Trade and Industry (FEFTA, Article 48).
  • Row 16 of that table, the catch-all, covers goods in tariff classes 25 to 40, 54 to 59, 63, 68 to 93 and 95 that are not listed elsewhere: permission is needed where a METI order specifies the case, or METI notifies the exporter, because the goods may be used to develop nuclear, biological or chemical weapons, missiles or conventional arms.
  • Appended Table 2 goods need METI approval, and exports to Russia of goods listed in Appended Table 2-3, item (iii) and specified by METI order also need approval.
  • Customs confirms the permission or approval before it permits the export.
  • Appended Table 2-3, item (iii) includes portable automatic data processing machines with at least a central processing unit, keyboard and display, so exporting those METI has specified to Russia needs approval.

How we help: Compliant Always keeps the classification and any licence with the product and shipment, dated, and answers importers' questions from that record. Ask about this

Certificates of origin

Non-preferential certificates from chambers of commerce, and proof of preferential origin under Japan's EPAs.

    • Chambers of commerce across Japan issue ordinary certificates of origin, which certify the country of origin from the commercial invoice; they do not certify the place of production within Japan.
    • Under Japan's EPAs, preferential origin is shown either by a certificate of origin from a designated body (third-party certification) or by an origin statement made by the exporter, producer or importer (self-certification).
    • Exports from Japan can use self-certification under the Japan-Australia EPA, CPTPP, the Japan-EU EPA, the Japan-UK EPA, RCEP (to Australia, New Zealand and Korea) and the Japan-US Trade Agreement.
    • The Japan Chamber of Commerce and Industry is designated by METI to issue third-party EPA certificates of origin, except for the Japan-Singapore EPA, which local chambers issue.

    How we help: Compliant Always keeps each certificate or origin statement with the shipment it covers, beside the bill of materials behind it, and answers importers' origin questions from the record. Ask about this

    Export declaration and customs clearance

    Goods leave Japan on an export declaration to Customs and an export permit, with the permits other laws require.

    • Exporters declare the goods to the Director-General of Customs and obtain an export permit, after any physical examination (Customs Act, Articles 67 and 70).
    • The declaration gives the goods' code, name, quantity and price, the destination, the consignor and the carrier, and is lodged with an invoice; a packing list and permits under other laws may be needed.
    • The exporter or a customs broker acting for it files the declaration; goods are usually permitted once in the hozei (bonded) area.
    • Where another law requires a permit, approval or inspection, Customs does not permit export until it is shown (Customs Act, Article 70).
    • Exporters keep books and documents, such as contracts, invoices and packing lists, for 5 years from the day after the export permit.

    How we help: Compliant Always keeps the invoice, packing list and export permit with the shipment and lot, dated, and shows what is missing before the goods are declared. Ask about this

    Consumption tax exemption on export

    Sales that are exports are exempt from consumption tax, on proof of export.

      • When a sale is an export transaction, consumption tax is exempted; input tax on purchases for that export can still be credited.
      • Proof is needed: for goods given an export permit, the export permit (a document certified by the Director-General of Customs), kept for 7 years.
      • Postal exports of 200,000 yen or less use Japan Post's receipt and dispatch slip instead.

      How we help: Compliant Always keeps each export permit with the sale it proves, dated, and shows which shipments still lack one. Ask about this

      Who answers for what

      WhoWhat they answer forHow we help
      ExporterClassifying the goods under the export control lists, any METI permission or approval, and the export declaration.Classifications and licences kept with each product and shipment, dated.
      ManufacturerThe technical facts behind a classification, such as key lengths and whether users can change the cryptographic function.Specifications kept with the product for classification questions.
      Customs brokerLodging the declaration with the permission it needs.The shipment's documents in one place before the declaration.
      METIPermission under Article 48 of FEFTA and approval under the Export Trade Control Order.Each licence kept with the shipments it covers.

      Where are the goods going?

      Most of what electrical and electronic products have to meet is set where they are sold. Each guide sets out the rules on arrival, with the official source for each.

      Questions businesses ask

      Do electronics need an export licence to leave Japan?
      Only some. Goods in Appended Table 1 of the Export Trade Control Order need METI permission, such as listed telecommunications and cryptographic equipment, and catch-all goods where METI specifies the case or notifies the exporter. Other electronics leave on an ordinary export declaration.
      Does encryption in consumer electronics need a Japanese export licence?
      Not where an exclusion applies. METI's goods order excludes, among others, certain network-connected terminals for civilian or industrial use that use only public or commercial encryption standards which users cannot change. The conditions are detailed, so the clause relied on matters.
      Are Bluetooth and other short-range wireless devices controlled?
      The METI goods order excludes wireless personal area network devices that use only encryption standards open to the public or for commercial use, and their components, from the cryptographic equipment it lists.
      Are mobile phones controlled as cryptographic equipment?
      Civilian mobile phone terminals are excluded where they meet the conditions in the METI goods order, for example where they cannot send encrypted data directly to another terminal or through radio access network equipment.
      Which electronics fall under Japan's catch-all control?
      Goods in tariff classes 68 to 93, which include Chapter 84 machinery and Chapter 85 electrical equipment, not listed elsewhere. Permission is needed where METI specifies the case, or notifies the exporter, because of a risk of weapons use.
      Do laptops exported from Japan to Russia need approval?
      They can. Portable automatic data processing machines with at least a central processing unit, keyboard and display are in Appended Table 2-3, item (iii); exporting those METI has specified to Russia needs METI approval.
      How do I get a certificate of origin for electronics made in Japan?
      From a chamber of commerce, for an ordinary certificate. For EPA rates, the exporter self-certifies under agreements such as the Japan-EU and Japan-UK EPAs and CPTPP, or JCCI issues the certificate under third-party agreements.
      Is consumption tax charged on electronics exported from Japan?
      No, export sales are exempt from consumption tax. The exporter keeps the export permit, certified by Customs, for 7 years as proof.
      How long must I keep export records in Japan?
      Books and documents such as contracts, invoices and packing lists are kept for 5 years from the day after the export permit, under the Customs Act.
      How does Compliant Always help with exporting from Japan?
      Our team reads the rules for the routes you ship. Compliant Always shows which export documents apply to your product, keeps them with the shipment beside what the destination asks for, and watches the sources for changes. It shows what the requirements say and what your documents show; you decide.

      Sources

      Compliant Always is a product of Lettuce Labs LLC. It shows what requirements say and what your documents show. It is not legal advice, and you decide.

      Tell us what you make, and we will show you the rules for it.

      Name the product and the markets you sell in. We will come back to you with what applies in Japan and what your paperwork needs to show.

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