Property and siting requirements for vehicle dismantling and shredding (Automobile Recycling Act) — the environmental impact survey and storage facilities

In short: dismantling end-of-life vehicles needs a prefectural governor's permit (Automobile Recycling Act, Article 60), and shredding needs one from the governor as well (Article 67). What matters for the property comes first from three points: the use-zone (a factory handling hazardous substances such as waste oil, with noise and vibration, tends toward industrial zones); the facility standards of the permit (whether you can install equipment that stops scatter, spill, ground seepage, and noise); and, where a shredder or press is a waste-disposal facility under Article 15 of the Waste Management Act, the environmental impact survey. The real estate side goes as far as providing property and siting information; the permit application is referred to an administrative scrivener.

You want to start a vehicle dismantling, used-car, or scrap business, or expand your current site — and the first gate is "will a permit come through for this land and building?" This article is for operators and for the agents handling their business property, setting out what can be narrowed down on paper before the contract and the viewing, from the statutes and public materials. Whether the permit is granted is decided in the end by the licensing prefecture and qualified professionals; this article shows where to look when choosing the property.

From which work does vehicle dismantling and shredding need a permit?

Dismantling an end-of-life vehicle needs a dismantling permit; crushing or pressing it needs a shredding permit.

The Act on Recycling of End-of-Life Vehicles (Automobile Recycling Act; Act No. 87 of 2002) regulates the operators handling end-of-life vehicles stage by stage. Collection operators and fluorocarbon recovery operators are on a "registration"; but dismantling and shredding are on a "permit," a notch higher.

• Dismantling (Article 60) = the business of dismantling an end-of-life or dismantled vehicle. A permit from the prefectural governor having jurisdiction over the location of the business site (in cities with a public health center, that city's mayor).
• Shredding (Article 67) = the business of crushing or pre-crushing (pressing, shearing) a dismantled vehicle. Also a permit from the prefectural governor. The items to state in the shredding permit application are set out in Article 68.

Category of business	Procedure	Basis	Authority
Collection / fluorocarbon recovery	Registration	Automobile Recycling Act Arts. 42 & 53	Prefectural governor
Dismantling	Permit	Art. 60	Prefectural governor (mayor in public-health-center cities)
Shredding (incl. pre-crushing)	Permit	Art. 67	Prefectural governor (mayor in public-health-center cities)

The permit is examined per business site (i.e. per property), against the facility standards, the applicant's-capacity standard, and the disqualification grounds (for dismantling, Article 62). Because not only the "person" but "the place" must meet the standards, this bites before you settle on the property. A related business, the certified maintenance workshop, is judged on a different axis under the Road Transport Vehicle Act (Property requirements for a certified vehicle maintenance workshop). Property for displaying and storing used cars is covered in display lots and storage for used-car dealers and secondhand-goods dealers.

How do the use-zone and the environmental impact survey bear on choosing a property?

On the use-zone it leans industrial; the environmental impact survey bears via "a permit under a different statute."

Vehicle dismantling and shredding handle hazardous substances — waste oil and waste fluids — and involve noise and vibration from cutting, crushing, and heavy machinery: this is a "factory." Under the Building Standards Act, Appended Table 2 (restrictions on buildings within use-zones) and the City Planning Act (Act No. 100 of 1968), factories that are highly hazardous or markedly worsen the environment cannot be built in residential or commercial zones; in quasi-industrial zones the volume of hazardous substances is limited, so it leans toward industrial and exclusively-industrial zones. Because the line moves with the floor area of the workspace and the output of the motors, first line up the use-zone of the property against the scale of the workspace you envisage.

The "environmental impact survey" is not required as a statutory attachment for the dismantling or shredding permit itself under the Automobile Recycling Act. What it bears on is the permit for setting up an industrial-waste-disposal facility under Article 15 of the Waste Management Act (Act on Waste Management and Public Cleansing; Act No. 137 of 1970).

Which permit	Environmental impact survey	Basis
Dismantling / shredding permit (Automobile Recycling Act)	Not a statutory attachment (facility standards do require preventing harm to the living environment)	Automobile Recycling Act Arts. 60, 62, 67
Industrial-waste-disposal-facility installation permit (Waste Management Act)	The application must attach a document recording the results of the environmental impact survey	Waste Management Act Art. 15(3)

When a shredder, shearing machine, or press, or a facility for the waste plastics or rubble produced by dismantling, reaches a scale that makes it an industrial-waste-disposal facility under Article 7 of the Waste Management Act enforcement order (for example, over 5 tonnes a day for a certain crushing facility), a facility-installation permit from the prefectural governor becomes necessary separately from the Automobile Recycling Act permit. That application must attach a document recording the results of a survey of the impact on the living environment of the surrounding area (an environmental impact survey report) — Article 15(3). Whether your planned facility is such a "Article 15 facility" turns on its capacity and type, so confirm with the licensing prefecture before settling the property. Where it applies, the public-inspection and neighbourhood-notification steps make the procedure longer, and this feeds directly into the siting choice.

What facilities must a property have for storage, oil–water separation, and rainwater control?

The key is whether the structure keeps dirty water and oil from leaving the site.

The facility standards of the Automobile Recycling Act permit require a facility with the measures necessary so that no harm to the conservation of the living environment arises from scatter or spill of waste, seepage into the ground, odour, noise, or vibration. The particulars are fixed by the enforcement regulations (ministerial order) and by local practice; for the property, points like these are examined.

Point examined	What to confirm on the property
Floor surface	Whether the places for dismantling work and storage are paved with concrete etc. so oil and waste water do not seep into the ground
Oil–water separation	Whether there is a drainage route to install waste-oil / waste-fluid recovery equipment and an oil–water separator
Rainwater / drainage	Whether the gradient, gutters, and catch basins keep contaminated water from flowing off-site together with rainwater
Storage	Whether there is space to store end-of-life vehicles, dismantled vehicles, parts, and waste tyres by type, at a height and in partitions that do not collapse or scatter
Distance from neighbours	Whether the site allows a margin and screening so noise, vibration, and dust do not reach dwellings

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Where drainage goes into public waters, notification of a specified facility and compliance with effluent standards under the Water Pollution Control Act (Act No. 138 of 1970) may separately be required, and on land that was once a factory or filling station the Soil Contamination Countermeasures Act perspective also overlaps. Because these divide the outcome by "the ground and the drainage structure" rather than the size of the building, at the viewing always look at the floor, the gutters, and the drainage destination. On checking the legal compliance of a property itself, see Can a used property without an inspection certificate be converted to a welfare facility; for the overall approach to finding business land, consulting on business property and consulting on office and shop property.

Who does the permit application, registration, and tax go to? (sorting the referrals)

The real estate side goes as far as providing property and siting information. From there, you engage each professional separately.

Role	Who
Survey of property and siting; checking use-zone, drainage, and storage space; brokerage of lease or sale	Yotsuba Real Estate Co., Ltd. (licensed real estate agent, Tokyo Governor (1) No. 113304)
Dismantling / shredding permit application; documents for the Waste Management Act facility-installation permit; compiling the environmental impact survey report	Yotsuba Administrative Scrivener Office
Registration of land and building; incorporation registration	Judicial scrivener
Tax of incorporation and business transfer; consumption and corporate tax	Licensed tax accountant
Neighbourhood and contract disputes	Attorney

Yotsuba Real Estate Co., Ltd. and Yotsuba Administrative Scrivener Office are two independent business entities, engaged separately and directly by you. We neither pay nor accept referral fees or introduction commissions. The judicial scrivener, tax accountant, and attorney are each engaged by you directly as well. We take the consultation at one point of contact, but the engagements are split by entity. Consultation is free.

Frequently asked questions

Q. If I only buy and sell used cars, do I need a dismantling permit?
A. Merely taking in and selling vehicles as used cars needs no dismantling permit. A dismantling permit (Automobile Recycling Act Article 60) is needed when you "dismantle" an end-of-life or dismantled vehicle. Other procedures may bear, though — registration as a collection operator, or a secondhand-goods dealer permit under the Secondhand Goods Business Act. Which procedure applies varies with the content of the business, so confirm with an administrative scrivener.

Q. Can I dismantle vehicles in a warehouse in a quasi-industrial zone?
A. A quasi-industrial zone is one where highly hazardous factories or those markedly worsening the environment cannot be built. Because vehicle dismantling involves hazardous substances such as waste oil and brings noise and vibration, it may not be buildable depending on the scale of the workspace and the volume handled. The outcome divides by the use-zone and the workspace floor area and output, so check by lining up the use-zone and the scale for each property.

Q. If I install a shredder, is an environmental impact survey always required?
A. Not always. Attaching an environmental impact survey report is required where that shredder etc. is an industrial-waste-disposal facility under Article 15 of the Waste Management Act (of the types and capacities set in Article 7 of the enforcement order). Because it applies or not by capacity and type, confirming with the licensing prefecture based on the specifications of the planned machine is the sure way.

Q. Is it all right to contract the property first and apply for the permit later?
A. It is a hard order to recommend. The permit presumes the facility (property) meets the standards, and if the floor structure, drainage, storage space, or use-zone does not fit, the application will not go through. It is safer to check the use-zone, drainage route, and storage area before the contract and, if needed, to put a "termination if the permit is not granted" clause into the lease. Consult an administrative scrivener on the documents needed, and us on the contract clause.

Sources (primary)

• e-Gov, "Act on Recycling of End-of-Life Vehicles (Automobile Recycling Act)" — Act No. 87 of 2002. Art. 60 (dismantling permit); Art. 62 (dismantling permit standards and disqualification grounds); Art. 67 (shredding permit); Art. 68 (items in the shredding permit application). Accessed 19 September 2026.
• e-Gov, "Act on Waste Management and Public Cleansing (Waste Management Act)" — Act No. 137 of 1970. Art. 15 (installation permit for an industrial-waste-disposal facility); Art. 15(3) (attaching the environmental impact survey results); Art. 15-2 (permit standards). Types and capacities of facilities are in Article 7 of the enforcement order. Accessed 19 September 2026.
• e-Gov, "Building Standards Act" — Act No. 201 of 1950. Appended Table 2 (restrictions on buildings within use-zones); factory eligibility divides by workspace floor area and motor output. Accessed 19 September 2026.
• e-Gov, "City Planning Act" — Act No. 100 of 1968. Designation of use-zones. Accessed 19 September 2026.
• e-Gov, "Water Pollution Control Act" — Act No. 138 of 1970. Notification of a specified facility; effluent standards. Accessed 19 September 2026.
• Ministry of the Environment / METI, overview of the Automobile Recycling Act (dismantling and shredding permits) — the positioning of dismantling and shredding and an overview of the permit system. Accessed 19 September 2026.

The particulars of the facility standards for dismantling and shredding (floor structure, oil–water separation, storage height, rainwater control, etc.) are fixed by the enforcement regulations and the practice of each prefecture and public-health-center city. Check figures and specifications against the latest guide of the licensing authority; this article does not assert figures that vary by locality. Whether a shredder or press is an Article 15 industrial-waste-disposal facility divides by the type and capacity of the machine; confirm the determination with the licensing authority and an administrative scrivener. This article is general information and does not offer a legal determination or a judgment on whether a permit will be granted. The dismantling / shredding permit application and the Waste Management Act facility-installation documents are prepared by an administrative scrivener; registration of land and buildings by a judicial scrivener; tax by a licensed tax accountant; and disputes by an attorney. Property and siting surveys and lease or sale contracts are undertaken by Yotsuba Real Estate Co., Ltd. (licensed real estate agent), and the preparation of licensing documents by Yotsuba Administrative Scrivener Office — two independent business entities, engaged separately and directly. We neither pay nor accept referral fees.

About the author

Joji Uramatsu — licensed real estate transaction specialist (Tokyo Governor registration No. 293544) and administrative scrivener (registration No. 25087022). Representative Director, Yotsuba Real Estate Co., Ltd. (licensed real estate agent, Tokyo Governor (1) No. 113304); principal, Yotsuba Administrative Scrivener Office. Kohinata, Bunkyo, Tokyo, about five minutes' walk from Myogadani station. For business property, use-zone, drainage, storage, and the licensing requirements go on the same table. Full profile: author page.