What are the conditions for a warehouse property to become a 'bonded warehouse' where imported goods sit before duty?

The key point: A "bonded warehouse" (hozei-zochijo), where imported foreign goods can sit in a duty-unpaid state, is a place licensed by the Director-General of Customs under Customs Act (Act No. 61 of 1954) art. 42 (1). For a warehouse property, three things matter: (1) location based on distance from the customs office (customs practice treats a route of roughly within 25 km of the competent customs office as the guide), (2) a structure and equipment that keep goods safely and prevent wrongdoing (locking, security), and (3) not falling within the grounds for refusal in art. 43 (which include an unsuitable location or facilities). The licence may be renewed for a period not exceeding ten years (art. 42 (2)), and foreign goods may sit duty-unpaid for two years from the day storage was first approved, extendable by the Director-General of Customs for special reasons (art. 43-2). We (a real-estate transaction business) handle the check of the property's zoning and structure and the lease/sale brokerage of the warehouse; support with the licence application documents is a customs broker's or administrative scrivener's, import/export customs clearance a registered customs specialist's, and the business of taking others' goods into custody for storage a registration under the Warehousing Business Act (a separate procedure), each an independent business contracted with separately (no referral fees are exchanged).

For importers and e-commerce operators, logistics firms, and the real-estate professionals who look for or let commercial warehouses, this article organises "what kind of warehouse property can obtain a bonded-warehouse licence," in the order of the Customs Act text, customs practice, and the difference from the Warehousing Business Act. This is general information; the final judgment on whether a particular property can obtain a bonded-warehouse licence, and which bonded area suits, rests with the competent customs office and qualified professionals.

Yotsuba Real Estate Co., Ltd. (四葉不動産株式会社), based in Bunkyo, Tokyo, provides surveys of commercial warehouses and lease/sale brokerage. For a warehouse property you want to make a bonded warehouse, you can consult us from what can be confirmed before contracting.

How do a bonded warehouse, a "bonded storehouse," and a warehousing registration differ?

The first thing to grasp is that "bonded" and "warehousing business" are separate systems. A bonded warehouse is a customs licence under the Customs Act—a place where foreign goods can sit duty-unpaid. A warehousing registration is a registration with the Minister of Land, Infrastructure, Transport and Tourism under the Warehousing Business Act—the qualification for the business of taking others' goods into custody and storing them. The two differ in governing law and jurisdiction, and you may hold both if needed.

Under the Customs Act, a "bonded area" has five types, and a bonded warehouse is one of them. Each type differs in the goods and period it can hold and in the licence/designation mechanism.

Type of bonded area	Governing article	Character
Designated bonded area	Customs Act art. 37	A public facility designated by the Minister of Finance; for short loading/unloading and temporary storage
Bonded warehouse	Customs Act art. 42	Licensed by the Director-General of Customs; allows long-term storage of foreign goods
Bonded factory	Customs Act art. 56	Licensed by the Director-General of Customs; processing/manufacturing of foreign goods while bonded
Bonded exhibition site	Customs Act art. 62-2	Licensed by the Director-General of Customs; exhibiting foreign goods at fairs etc.
Integrated bonded area	Customs Act art. 62-8	An area where storage, processing, exhibition and the like can be done together

The term "bonded storehouse" is often used colloquially to mean a bonded warehouse. Meanwhile, Warehousing Business Act art. 3 provides that "a person intending to run a warehousing business must receive the registration conducted by the Minister of Land, Infrastructure, Transport and Tourism," and art. 6 provides that registration is refused where the warehouse's facilities/equipment do not meet the ministerial standards for each type. The property requirements for a warehousing registration are covered in the property requirements for registering a commercial warehouse (Japanese). If you only store your own goods, a warehousing registration is not required; if you take others' goods into custody and store them, a separate warehousing registration is required. Having a bonded-warehouse licence does not double as a warehousing registration.

What location and structure does customs look at for the bonded-warehouse licence?

The bonded-warehouse licence examines not only the applicant (the person) but also the place and the equipment. Customs is generally said to examine from the viewpoints of the personal requirement (the applicant's suitability), the locational requirement (distance from the customs office, etc.), the facility requirement (security, locking, etc.), and the quantitative requirement (the expected volume of goods handled). What matters on the property side is the locational and facility requirements.

Customs Act art. 42 (1) defines a bonded warehouse as "a place that the Director-General of Customs has licensed as one where foreign goods may be loaded/unloaded or carried, or may be placed." As to that licence, art. 43 lists in its items the cases in which the Director-General of Customs may refuse a licence (grounds for refusal), and among them is a ground corresponding to "the location or equipment being found unsuitable for a bonded warehouse." Location and structure take effect here as the suitability of the property.

Viewpoint	What customs looks at (practice)
Locational requirement (location)	A route of roughly within 25 km of the competent customs office is the guide in principle. Even beyond that, roughly within 100 km, there may be room to allow it if roads, ports, airports and other transport facilities are in place
Facility requirement (structure/security)	Because foreign goods sit duty-unpaid, a structure/equipment—locking, partitioning, entry control—that prevents loss of goods and wrongdoing
Quantitative requirement	Whether the facility's scale matches the expected volume of goods handled
Other laws / use	Whether the Building Standards Act zoning allows a (commercial) warehouse, and whether fire and other regulations for the goods can be met

The locational figures (25 km, 100 km) are guides based on customs practice (such as basic circulars) and are not numbers written in the Act itself. There are exceptional treatments for facilities that do not fit the distance standard, such as those inside a coastal factory loading/unloading directly to and from a ship. The final judgment on this rests with the competent customs office. We organise the points you can confirm before contracting from records and on site—the candidate warehouse's zoning, structure, frontage road and distance from the nearest customs office—and hand you the issues to confirm with bonded/customs professionals.

For how long can you keep goods without paying duty?

The biggest advantage of a bonded warehouse is that you can keep foreign goods for a long time before paying customs duty and consumption tax. Customs Act art. 43-2 sets the period foreign goods may sit in a bonded warehouse at two years from the day the goods were first approved to be placed there, and provides that, where there are special reasons, the Director-General of Customs may, on application, designate a necessary period and extend it.

The premise here is "storage approval." Customs Act art. 43-3 (1) provides that, where you intend to keep foreign goods beyond three months from the day they were brought into the bonded warehouse, you must apply to the Director-General of Customs and receive approval before that three months passes. In short: up to three months after bringing them in, you may keep them without approval; to keep them longer you receive approval (storage approval), and long-term storage of two years from the approval day is allowed.

Period	Content	Basis
Up to three months from the day brought in	May be kept without storage approval	Customs Act art. 43-3 (1)
Two years after approval (storage approval)	Long-term storage of foreign goods duty-unpaid	Customs Act art. 43-2 (1)
Extension beyond two years	For special reasons, the Director-General of Customs designates a period and extends	Customs Act art. 43-2 (2)
For a designated bonded area	In principle one month (shorter than a bonded warehouse)	Under Customs Act art. 36

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This mechanism of "deferring payment of customs duty/consumption tax while the goods sit" is meaningful for cash flow for operators who want to stagger the timing of import and domestic sale. However, which goods to treat as imported (taken out) and when, and when to pay customs duty/consumption tax, are customs/tax judgments and not a field we advise on. What can be confirmed on the property side is a storage environment that withstands long-term storage (temperature, humidity, partitioning) and whether the structure fits the bonded standards.

Who handles the licence application, customs clearance, and warehousing—respectively?

Using a bonded warehouse spans separate professional fields: surveying the property, the bonded-warehouse licence application, day-to-day customs clearance, and the warehousing registration for taking others' goods. What we handle is the check of the warehouse property's zoning and structure and the lease/sale brokerage; everything else we connect to each professional or registered operator, each an independent business contracted with separately.

Trouble	Who to ask
Checking the warehouse property's zoning, structure and location; lease/sale brokerage	Us (a real-estate transaction business)
Preparing documents and supporting the bonded-warehouse licence application	Customs broker / administrative scrivener (owner may also apply themselves)
Customs clearance of import/export goods (declaration, duty payment)	Registered customs specialist (customs broker)
The business of taking others' goods into custody and storing them	Warehousing Business Act registration (Minister of Land, Infrastructure, Transport and Tourism; separate procedure)
Fire, dangerous-goods and other regulations according to the goods	Fire department / the agency with jurisdiction
Registration of ownership transfer, leasehold, etc.	Judicial scrivener

These are each independent businesses, contracted with separately. We neither receive nor pay referral or introduction fees. Whether a bonded-warehouse licence can be obtained is ultimately decided by the competent customs office examining the location, structure and the applicant's suitability. Looking at the property, we take consultations from separating the issues—the locational requirement, the facility requirement, zoning, and the storage period—and arranging where to confirm each. For finding a commercial warehouse, see also the consultation desk for commercial/investment real estate (Japanese).

Consult Yotsuba Real Estate about a warehouse property that can be a bonded warehouse—initial consultation is free

In your message, write "bonded-warehouse property" and include the type of goods handled, the desired area, the floor area and ceiling height needed, and a rough idea of the nearest port/airport. Without presuming whether it can be obtained, we begin with checking the location, structure, zoning and storage period, and arranging which parts to refer to customs/warehousing professionals.

Frequently asked questions

Q. Do I need a bonded-warehouse licence just to store my own imported goods?
A. A bonded-warehouse licence (Customs Act art. 42) matters when you want to keep foreign goods for a long time before paying customs duty and consumption tax. Unless it is a licensed place, you cannot, in principle, store foreign goods duty-unpaid. The business of taking others' goods into custody and storing them separately requires a Warehousing Business Act registration (art. 3), and a bonded-warehouse licence does not double as a warehousing registration. What you need changes depending on whether it is bonded storage of your own goods or a storage business for others' goods.

Q. How close to customs does the property have to be to get a licence?
A. Customs practice treats a route of roughly within 25 km of the competent customs office as the guide in principle, and even beyond that, roughly within 100 km, there may be room to allow it if roads, ports, airports and other transport facilities are in place. But these are guides based on customs practice (such as basic circulars), not numbers in the Act itself, and there are exceptional treatments for facilities such as those inside a coastal factory. The judgment on distance rests with the competent customs office.

Q. About how many years can goods sit without paying duty?
A. Customs Act art. 43-2 (1) sets the period foreign goods may sit in a bonded warehouse at two years from the day storage was first approved (storage approval). For special reasons, the Director-General of Customs may, on application, designate a necessary period and extend it (art. 43-2 (2)). Note that to keep goods beyond three months from the day brought in, you must receive storage approval in advance (art. 43-3 (1)). When to treat goods as imported (taken out) and pay customs duty/consumption tax is a customs/tax judgment.

Q. Will a real-estate company do the bonded-warehouse licence application for me?
A. No. Supporting the bonded-warehouse licence application is the field of a customs broker/administrative scrivener, and import/export customs clearance is the field of a registered customs specialist; we do not do them. What we handle is the check of the warehouse property's zoning, structure and location, and the lease/sale brokerage. This article is general information and does not guarantee that a particular property can obtain a licence, so confirm the prospects with the competent customs office and bonded/customs professionals.

Sources

The following public materials are starting points. Laws are amended, so check the current text, paragraph, item, enforcement date and latest amendment on e-Gov Law Search. The final judgment on the suitability of location/structure, the prospects of a licence, and the treatment of the storage period rests with the competent customs office and qualified professionals. All were consulted on 27 October 2026. They do not guarantee that a particular property can obtain a bonded-warehouse licence. The sources below are in Japanese.

• e-Gov Law Search: Customs Act (Act No. 61 of 1954; art. 42 = bonded-warehouse licence [(1) a place licensed by the Director-General of Customs, (2) renewal within a period not exceeding ten years, (3) public notice], art. 43 = requirements of the licence [grounds on which the Director-General of Customs may refuse, including the location or equipment being unsuitable for a bonded warehouse], art. 43-2 = the period foreign goods may be placed [(1) two years from the day storage was approved, (2) extension by the Director-General of Customs], art. 43-3 = approval to place foreign goods [(1) storage approval to keep goods beyond three months from the day brought in])
• Japan Customs: Overview of the bonded system and bonded-warehouse licence application procedure (the five types of bonded area [designated bonded area, bonded warehouse, bonded factory, bonded exhibition site, integrated bonded area] and a comparison of storage periods, the examination viewpoints [personal, locational, facility, quantitative requirements], and the distance guide for the locational requirement; the figures/practice are per basic circulars; consulted 27 October 2026; the judgment rests with the competent customs office)
• e-Gov Law Search: Warehousing Business Act (Act No. 121 of 1956; art. 3 = a person intending to run a warehousing business must receive the registration of the Minister of Land, Infrastructure, Transport and Tourism, art. 6 = refusal of registration [the warehouse's facilities/equipment not meeting the ministerial standards for each type, etc.]; a system separate from the bonded-warehouse licence)

This article provides general information and does not guarantee whether a particular property may obtain a bonded-warehouse licence, the treatment of the storage period, or the suitability of zoning/structure. The suitability of location/structure and the licence examination are judged by the competent customs office; support with the licence application documents by a customs broker/administrative scrivener; customs clearance by a registered customs specialist; the warehousing registration by the Minister of Land, Infrastructure, Transport and Tourism; and registration by a judicial scrivener.

Joji Uramatsu (浦松 丈二), Representative Director and licensed real estate transaction specialist, Yotsuba Real Estate Co., Ltd. (四葉不動産株式会社). We provide surveys of commercial warehouses and lease/sale brokerage. Author profile

Updated: 27 October 2026