A Domestic Administrator is not a mailbox. Under Japan's product-safety laws the administrator receives ministerial notices on your behalf, holds your test records, and is the person METI calls when something goes wrong. Choose the provider the way you would choose a registered agent with real duties. Ten questions:
- Which of the five METI duties are covered, and how? Ask for the wording of the delegation contract. Contact point, recall measures, receipt of notices, records, inspections — all five must be there.
- What is the liability cap, and what is excluded? A cap at the annual fee is common. Make sure product defects stay your liability, not the administrator's, and that the administrator's own negligence is covered.
- Who holds the test reports and certificates? You should keep originals; the administrator keeps copies and a product list. Ask how they are shared with you and with METI on request.
- What happens if you become unreachable? Good providers terminate immediately and notify METI; ask for the notice period and the definition of "unreachable".
- Is product-liability insurance required, and whose? Many providers require you to hold PL cover for Japan. Ask whether they carry their own professional liability insurance.
- Can the same provider act as customs ACP? If you ship stock to Amazon FBA in your own name, one contract for both roles saves a second onboarding.
- What language does METI correspondence come back in? You want the original Japanese plus an English summary within one business day.
- How fast do they answer a marketplace document request? Amazon.co.jp holds listings while it waits. Ask for a service level in business days.
- How is pricing structured? Annual fee per product model, per product family, or flat; what a recall costs per hour; what is billed at cost.
- Will they verify you before signing? A provider that accepts any company without checking registration and product ownership is taking on risk that will eventually land on its clients.
For a comparison of English-speaking providers with published pricing, see the Domestic Administrator guide. Torii Japan Compliance answers all ten questions in its own draft agreement — early access.
Informational summary, not legal advice. Contract terms are yours to negotiate.