Telecommunications Business Act and Imported Terminal Equipment

The Telecommunications Business Act and imported terminal equipment refers to the Japanese regulatory checks that may apply to imported communication devices connected to telecommunications carrier networks in Japan.

Examples include smartphones, LTE routers, mobile Wi-Fi routers, modems, communication modules, IP phones, fax machines, IoT gateways, industrial communication devices and other equipment used by connecting to Japanese telecommunications lines.

Even if a communication device is legally sold overseas, it may still require confirmation under Japan’s Telecommunications Business Act when it is used or sold in Japan for connection to domestic telecommunications networks.

Overview

The Telecommunications Business Act is a Japanese law related to telecommunications services, telecommunications networks, network safety, reliability and user protection.

In import practice, the key issue is whether imported terminal equipment connected to a telecommunications carrier’s network satisfies the applicable technical standards.

If terminal equipment does not satisfy the technical standards, it may create problems such as incorrect connection, network disturbance, communication failure, emergency call issues or damage to telecommunications network equipment.

For this reason, imported communication equipment should be checked not only as cargo, but also as equipment that may be connected to Japanese telecommunications networks after import.

Difference from the Radio Act

The Telecommunications Business Act and the Radio Act are both important for imported communication devices, but they look at different points.

Item	Radio Act	Telecommunications Business Act
Main target	Radio equipment that emits radio waves	Terminal equipment connected to telecommunications carrier networks
Typical examples	Wi-Fi devices, Bluetooth devices, wireless modules, drones, radio equipment	Smartphones, modems, LTE routers, IP phones, fax machines, communication modules
Main check point	Frequency, output power, interference prevention and Giteki mark	Technical standards conformity, design certification and connection conditions for terminal equipment
Practical question	Does the product emit radio waves in Japan?	Will the product connect to a Japanese telecommunications carrier network?

Devices such as smartphones, LTE routers and IoT gateways may require checks under both laws because they have wireless functions and may also connect to telecommunications carrier networks.

Imported Equipment Commonly Affected

Imported equipment that may require confirmation under the Telecommunications Business Act includes:

• Smartphones and mobile phones
• SIM-free routers and mobile Wi-Fi routers
• LTE and 5G communication modules
• IoT gateways and remote monitoring devices
• IP phones and VoIP equipment
• Fax machines, telephones and PBX-related equipment
• Communication modems, ONUs and routers
• POS terminals, payment terminals and M2M devices
• In-vehicle communication terminals and industrial communication devices

Confirmation may also be necessary where a communication module is built into machinery, appliances, medical or beauty devices, industrial equipment or other finished products.

Technical Standards Conformity Approval and Design Certification

The Telecommunications Business Act includes systems to confirm whether terminal equipment satisfies technical standards.

Technical Standards Conformity Approval is a system for checking whether individual terminal equipment complies with the applicable technical standards.

Design Certification is a system mainly used for mass-produced terminal equipment, where the design and production control system are checked for conformity with the technical standards.

Importers and sellers should confirm whether the equipment has Japanese approval or certification, and whether the model, certification number, marking method, communication method and line type match the actual imported product.

T Mark and Certification Number

For terminal equipment under the Telecommunications Business Act, a conformity mark, auxiliary mark and certification number may be displayed to show that the equipment has received the relevant approval or certification.

The T mark is used as an auxiliary mark related to the Telecommunications Business Act.

In practice, checking only whether a T mark exists is not enough. Importers should also check the certification number, notification number, model name, covered device, display location and relationship with the Radio Act Giteki mark.

For smartphones and communication terminals, certification information may appear not only on the device body or label, but also in the settings screen, instruction manual or manufacturer documents.

Self-Confirmation System

In addition to approval or certification by a registered certification body, the terminal equipment system may also involve self-confirmation by a manufacturer, importer or other relevant business operator under certain conditions.

Self-confirmation does not simply mean that a company may check the product casually by itself.

Even when self-confirmation is used, the business operator may need to obtain test data, confirm conformity with technical standards, check the design and production control system, prepare notification documents and submit the required information.

If an overseas manufacturer provides self-certification documents, importers should still check whether those documents correspond to the Japanese Telecommunications Business Act system.

Customs Clearance and Domestic Use or Sale Are Different Questions

Customs clearance and domestic use or sale are different questions.

A communication device may be imported as cargo, but if it will be connected to a telecommunications carrier network in Japan, technical standards conformity under the Telecommunications Business Act may still need to be checked.

If certification or marking problems are discovered after domestic sale, the importer or seller may face sales suspension, return handling, retailer claims, administrative response, recall handling or customer support problems.

For imported terminal equipment, checking before import or sale is much safer than trying to solve certification problems after distribution has begun.

Overseas E-Commerce, Samples and Demonstration Products

Communication devices sold on overseas e-commerce sites or through crowdfunding may not be designed for the Japanese market.

For overseas-version smartphones, overseas routers, SIM communication modules and IoT terminals, the issue is not only whether the frequency band or communication method works in Japan. Terminal equipment approval or certification under the Telecommunications Business Act may also need to be confirmed.

Even for sample imports or exhibition goods, if the device will actually connect to a telecommunications carrier network in Japan during demonstration or testing, the intended use should be checked.

Descriptions such as “not for sale,” “for testing” or “for exhibition” do not automatically remove the need for confirmation. The practical question is whether the device will connect to a Japanese telecommunications network.

Products with Built-In Communication Modules

In recent years, communication modules such as LTE, 5G, LPWA, Wi-Fi or Bluetooth modules may be built into machinery, industrial equipment, appliances or other finished products.

Even if the finished product does not look like a communication terminal from the outside, confirmation may be necessary if the built-in module connects to a telecommunications carrier network in Japan.

Importers should check product specifications, communication module model, certification number, communication method, SIM usage, eSIM usage and planned connection to Japanese telecommunications networks.

Forwarder and Customs Broker Practical Notes

Forwarders and customs brokers are not normally responsible for guaranteeing compliance under the Telecommunications Business Act.

However, if product descriptions, invoices, packing lists, HS codes or product photos include terms such as smartphone, router, modem, LTE, 5G, SIM, eSIM, IoT, gateway, IP phone, fax, terminal or module, it is useful to remind the importer to check Telecommunications Business Act requirements.

HS codes alone do not always reveal the communication function. Electrical equipment, machinery, industrial devices or embedded-module products may require attention if they connect to telecommunications carrier networks.

In practice, forwarders should encourage the importer to confirm the following points:

• Will the product connect to a telecommunications carrier network in Japan?
• Does the product have SIM, eSIM, LTE, 5G or IP phone functions?
• Does the terminal equipment have technical standards conformity approval or design certification?
• Can the importer confirm the certification number or marking documents?
• Can the T mark, certification number or notification number be confirmed?
• Is the product designed for the Japanese market?
• Is the importer trying to sell an overseas-version product without Japanese confirmation?
• Has the Radio Act Giteki mark also been checked?
• Are PSE Mark or other regulatory checks also required?

Relationship with Radio Act and PSE

Imported communication terminals may require checks under the Telecommunications Business Act, the Radio Act and the Electrical Appliances and Materials Safety Act at the same time.

If the product has a wireless communication function, the Radio Act and Giteki mark should be checked separately.

If the product includes an AC adapter, charger, power cord or other electrical accessory, PSE Mark requirements under the Electrical Appliances and Materials Safety Act may become relevant.

For smartphones, routers, IoT terminals and products with built-in communication modules, importers should separately check terminal equipment certification, radio equipment certification and electrical product safety requirements.

Documents and Information to Check

• Product specification sheet
• Instruction manual
• Product photos
• Terminal equipment approval or certification number
• T mark, certification number or notification number display materials
• Giteki mark or Radio Act certification number display materials
• Communication method, line type and frequency band information
• SIM, eSIM, LTE or 5G support information
• Communication module model information
• Manufacturer documents showing Japanese-market specifications
• Test results, notification documents and conformity confirmation materials where self-confirmation is used
• Invoice
• Packing list
• Sales page or product description page
• Other regulatory certification or labeling documents, such as PSE-related materials

Common Problems

• The importer checks only whether the product can physically use a Japanese SIM card.
• The importer confirms the Radio Act Giteki mark but forgets terminal equipment certification.
• The product has a built-in LTE or 5G module that is not clearly described in the invoice.
• Certification number or T mark information does not match the imported model.
• An overseas-version smartphone or router is sold without confirming Japanese certification.
• The device is imported as a sample but used for live network demonstration in Japan.
• The main product is checked, but the embedded communication module is not checked.
• PSE requirements for AC adapters or chargers are overlooked.

These problems may lead to sales suspension, return handling, customer complaints, administrative response, network connection problems, retailer claims, relabeling work or additional confirmation after import.

Practical Notes for Shipments to Japan

For Japan-bound communication devices, origin-side suppliers and forwarders should understand that customs clearance is only one part of the process.

The practical question is not only whether the goods can enter Japan, but whether the device can be connected to Japanese telecommunications networks and sold or used in Japan under the applicable rules.

Early confirmation helps avoid sales delay, demonstration problems, return handling, marketplace suspension and additional certification checks after arrival.

Key Takeaway

The Telecommunications Business Act is important for imported terminal equipment connected to Japanese telecommunications carrier networks.

The Radio Act mainly concerns radio equipment that emits radio waves, while the Telecommunications Business Act concerns terminal equipment connected to telecommunications networks.

Forwarders and customs brokers do not guarantee legal compliance, but they can help prevent problems by reminding importers to check technical standards conformity approval, design certification, T mark, certification number, Giteki mark, Japanese-market specifications and PSE-related requirements before shipment or sale.