Opening a restaurant in a skeleton (bare-shell) unit — how exhaust, grease trap and fire safety decide the property

In short: whether a skeleton (bare-shell) unit works for a restaurant is mostly decided before you sign, by four things — (1) the use zone (a Category-1 low-rise exclusive residential zone or an exclusive industrial zone will not, as a rule, allow one); (2) whether an exhaust duct can be run to the exterior wall or roof, with the lessor's consent; (3) whether a grease trap can be retrofitted, given the plumbing beneath the floor or outside; and (4) whether fire compartments, sprinklers and escape routes hold up for the floor and area. The final decision rests with the health centre, the specified administrative authority and the fire service. Confirm this groundwork at the property stage and you avoid the rework after fit-out.

"A leased-in (converted) unit is fast because the equipment is already there; a skeleton lets you build freely" — both are true in part, but a skeleton (a unit with no interior) demands, behind that "freedom," that you judge before signing whether exhaust, plumbing and fire-safety equipment can be built from zero. This article is for individuals and companies opening a restaurant from a skeleton unit in Tokyo: what you can confirm before signing the lease, set out in order from the Food Sanitation Act, the Building Standards Act, the Fire Service Act and the Entertainment Business Act. Investigation, brokerage and the lease of the property are handled by our company (Yotsuba Real Estate Co., Ltd.) as information; final confirmation rests with the health centre, the specified administrative authority and the fire service.

How does the property check change between a skeleton and a leased-in unit?

A leased-in (converted) unit turns on whether you can inherit the previous tenant's exhaust, grease trap and health-centre setup. A skeleton turns on whether those can be built from the ground up. The branch is reversed.

What to look at	Leased-in	Skeleton
Exhaust / kitchen equipment	Can existing equipment be used or inherited?	Can a duct be run new to the exterior wall / roof?
Grease trap	Already installed? Enough capacity?	Can it be retrofitted below floor / outside?
Health-centre facility standard	Does the prior structure meet current standards?	Can hand-washing, partitions, floor/walls be built to standard?
Cost and time	Scope of fixture transfer / restoration	A full interior design and build is the premise

The same structure — reviewing a prior tenant's setup and the health-centre link — arises beyond restaurants, in beauty and barber shops too. A case where a health-centre notification precedes the contract is at what to confirm for a beauty or barber shop property. For a skeleton, confirm the four points below before signing.

Does that use zone let you open a restaurant (the Category-1 low-rise and exclusive-industrial trap)?

A restaurant is treated as a "shop," and whether it can be built is set by use zone in Article 48 and Table 2 of the Building Standards Act (Act No. 201 of 1950). This is the first gate.

Use zone	Rough treatment of a restaurant (shop)
Category-1 low-rise exclusive residential	As a rule not allowed; limited to a combined-use dwelling (residence ≥ ½ of total floor area, shop ≤ 50 m²)
Category-2 low-rise exclusive residential	May be built as a shop of a certain scale, such as within 150 m²
Category-1 medium-to-high-rise exclusive residential	May be built on conditions, such as within 500 m² and no higher than the 2nd floor
Residential / quasi-residential / neighbourhood-commercial / commercial / quasi-industrial	Easier to build
Exclusive industrial	Not allowed (a restaurant cannot be built)

"It is a tenant building, so of course it can open" does not follow. In a Category-1 low-rise exclusive residential zone or an exclusive industrial zone, a restaurant itself cannot, as a rule, be built. And converting an office or a shop of another trade into a restaurant may require a use-change confirmation application (Article 87(1)) depending on the floor area. The use-zone feasibility and whether a use-change is needed can be confirmed with the specified administrative authority before signing. How the use zone bears on a business property is also set out in what to confirm before signing for a clinic property. Business property in general is at investment and business real estate.

How do you confirm the property can run an exhaust duct to the exterior wall or roof?

Kitchen exhaust is where restaurant properties differ most. In a skeleton the duct is not installed, so confirm before signing:

• Exhaust route: is there a vertical shaft / pipe space or room to penetrate the exterior wall, so a duct can reach the wall or roof from the kitchen?
• Lessor's consent: wall penetration and a rooftop exhaust outlet often need the consent of the lessor / management association under the lease or management rules.
• Consideration for neighbours: the position of the exhaust outlet easily causes odour and noise disputes; look at orientation and height in advance.
• Balance with air supply: strong exhaust needs matching air supply; is there room to design first-type ventilation?

Because exhaust touches the building structure itself, a property the lessor marks "not allowed" simply will not support heavy-cooking formats. Duct design and construction are the work of the contractor (designer). We (the real estate agent) assist with the groundwork of whether the property can meet these conditions and with negotiating terms with the lessor. Because exhaust feasibility decides the format, we confirm it together with which parts of the lease to read.

Can a grease trap be retrofitted — and what is decided by the plumbing and the underfloor?

A grease trap (an oil-and-grease interceptor) stops the oil and residue in kitchen wastewater from flowing into the sewer. Article 10 of the Sewerage Act (Act No. 79 of 1958) requires drainage equipment within a public-sewer service area, and Article 8 of its enforcement order sets the technical standard for drainage equipment. For restaurants that discharge much oil, each locality's sewerage ordinance / drainage-equipment guideline generally requires an interceptor (grease trap) (accessed 2 September 2026).

For a skeleton, confirm whether there is room to retrofit one.

Check	Why it matters
Underfloor room	A floor-embedded type needs the floor slab dug; on an upper-floor unit it may be impossible
Room to place outside	If no underfloor room, is there space and a piping route for an outdoor type?
Drainage gradient	Can the gradient be taken from kitchen to interceptor to public sewer?
Wastewater quality standard	Discharge standards for oil (n-hexane extract) etc. are set by local ordinance; exceed them and it will not be accepted

The capacity, type and quality standard of a grease trap vary by locality. Check the page of the sewerage authority with jurisdiction directly at the outset. Plumbing design is the contractor's work; we assist with the groundwork on whether there is room to install at the property stage.

For fire compartments, sprinklers and escape routes, what do the floor and area control?

A restaurant is a specified fire-defence object listed in item (3)(ro) of Appended Table 1 of the Enforcement Order of the Fire Service Act, and the requirements are stricter because an unspecified crowd comes and goes. Article 17 of the Fire Service Act (Act No. 186 of 1948) imposes on those concerned a duty to install and maintain fire-defence equipment to the technical standard set by order. At the property stage, these bite:

Point	What decides it
Automatic fire alarm	Likely required in a specified fire-defence object; the standard changes with total floor area and floor
Sprinkler system	The target changes with area and number of floors (basement, windowless floor, high floor); basement and high-floor units need care
Escape route / two-way escape	With floors and occupant load, the number and width of exits and stairs are questioned
Fire compartments	Area and shaft compartments are questioned on the Building Standards Act side, and interior-finish restrictions apply

A basement, windowless or high-floor unit carries heavier equipment requirements for the same area. These are decided by the floor and area and by existing common equipment, so it is safer to consult the fire service (the fire station with jurisdiction) before building out the interior. For work needing building confirmation, the consent of the fire chief / fire-station head (Article 7 of the Fire Service Act) is a premise. Equipment design and construction are the work of the fire-equipment contractor and the architect.

The health-centre permit and fire/building work — who do you ask, in what order (separate engagement)?

To open a restaurant, Article 55 of the Food Sanitation Act requires the permission of the prefectural governor or the like. The permit is granted when the health centre finds the facility meets the standard set by the prefecture's ordinance under Article 54 (in Tokyo, the Food Sanitation Act Enforcement Ordinance). So the flow is this.

Order	What to do	Who
1	Confirm use zone and whether a use-change is needed	Specified administrative authority; licensed real estate agent
2	Groundwork on exhaust, grease trap, fire safety	Licensed real estate agent; contractor
3	Lease contract	Licensed real estate agent
4	Fit-out (kitchen, partitions, exhaust, drainage, fire equipment)	Contractor; architect; fire-equipment contractor
5	Application for the restaurant permit	Operator; administrative scrivener
6	Health-centre facility inspection; fire-service consent	Health centre; fire service
7	Open after permission	Operator

If you mainly serve alcohol after midnight, then separately you file, under Article 33(1) of the Act on Control and Improvement of Amusement Business (the "Entertainment Business Act"), a notification of commencement of a late-night alcohol-serving restaurant business with the public safety commission (via the police station with jurisdiction) at least 10 days before opening. Preparation of documents submitted to public offices — the restaurant permit and the late-night notification — is undertaken by Yotsuba Administrative Scrivener Office. The counter, forms, local figures and intake operation vary. Check the pages of the health centre, fire service and police station with jurisdiction directly at the outset.

Who should you consult?

Investigation of the property, brokerage, and the sale or lease contract are handled by Yotsuba Real Estate Co., Ltd. (licensed real estate agent, Tokyo Governor (1) No. 113304). Preparation of documents submitted to public offices — the restaurant permit and the late-night alcohol-serving notification — is handled by Yotsuba Administrative Scrivener Office. The design of exhaust ducts, fire compartments and sprinklers and building confirmation are handled by an architect; the design and installation of fire-defence equipment, by a fire-equipment contractor; plumbing and the grease trap, by the contractor. The final decision rests with the health centre, the specified administrative authority and the fire service; tax goes to a tax accountant, and employment and social insurance to a certified social insurance labour consultant (Yotsuba Certified Social Insurance Labour Consultant Office).

These are independent business entities. You engage each directly. We neither pay nor accept referral fees or introduction commissions. Registration goes to a judicial scrivener, tax to a tax accountant, and employment contracts, work rules and new social-insurance coverage to a certified social insurance labour consultant — each engaged by you directly. Consultation is free of charge.

Frequently asked questions

Q. Skeleton or leased-in — which opens a restaurant faster?
A. Generally, a leased-in unit with equipment in place means less work and is often faster. But if the prior tenant's equipment does not meet current health-centre standards, it must be rebuilt. A skeleton can be built freely, but exhaust, grease trap and fire safety must be designed and built from zero, which takes time and money. Which suits you depends on the format and the property, so confirm property by property.

Q. On what kind of property can a restaurant not open?
A. In a Category-1 low-rise exclusive residential zone or an exclusive industrial zone, a restaurant (shop) cannot, as a rule, be built (Building Standards Act Article 48, Table 2). Heavy cooking can also be hard where an exhaust duct cannot reach the exterior wall / roof, a grease trap cannot be installed, or fire equipment does not hold up in a basement or high floor. Confirm feasibility with the specified administrative authority, health centre and fire service.

Q. Is a grease trap always required? Can it be retrofitted?
A. For restaurants discharging much oil, each locality's sewerage ordinance / drainage guideline generally requires an interceptor (grease trap) (Sewerage Act Article 10 and enforcement-order Article 8 are the basis for drainage equipment and its technical standard). Whether it can be retrofitted depends on underfloor / outdoor room and the drainage gradient. Capacity, type and quality standards vary by locality, so confirm with the sewerage authority with jurisdiction.

Q. Do I need any notification to serve alcohol late into the night?
A. If you mainly serve alcohol after midnight, you file a notification of commencement of a late-night alcohol-serving restaurant business under Entertainment Business Act Article 33(1), with the public safety commission (via the police station with jurisdiction) at least 10 days before opening. It is separate from the restaurant permit. Preparation of the notification is undertaken by an administrative scrivener. The requirements are set by ordinance and operation varies, so confirm with the police station with jurisdiction.

Sources (primary)

• e-Gov "Food Sanitation Act" — Act No. 233 of 1947. Art. 54 (prefecture sets facility standards by ordinance for businesses with marked public-health impact); Art. 55 (business permit — governor's permission). The 2018 amendment took effect 1 June 2021. Accessed 2 September 2026.
• e-Gov "Building Standards Act" — Act No. 201 of 1950. Art. 48 (use-zone restrictions); Table 2 (buildings by use zone); Art. 87(1) (confirmation on use change). Accessed 2 September 2026.
• e-Gov "Fire Service Act" — Act No. 186 of 1948. Art. 7 (fire-service consent at building confirmation); Art. 17 (duty to install and maintain fire-defence equipment). A restaurant is a specified fire-defence object in item (3)(ro) of Appended Table 1 of the enforcement order. Accessed 2 September 2026.
• e-Gov "Act on Control and Improvement of Amusement Business" — Act No. 122 of 1948. Art. 33 (late-night alcohol-serving restaurant business); notification to the public safety commission at least 10 days before opening. Accessed 2 September 2026.
• e-Gov "Sewerage Act" — Act No. 79 of 1958. Art. 10 (duty to install drainage equipment); enforcement-order Art. 8 (technical standard for drainage equipment). A grease trap is required by each locality's sewerage ordinance / drainage guideline. Accessed 2 September 2026.

Use-zone feasibility and whether a use-change confirmation is required vary with the property's floor area, structure and zone designation; final confirmation rests with the specified administrative authority. The capacity, type and wastewater-quality standard of a grease trap, and the targets for fire-defence equipment (automatic fire alarm, sprinkler, etc.), vary by locality and by the property's floors, area and structure. This article does not assess any individual property. Confirm with the health centre, fire service, sewerage authority and police station with jurisdiction at the outset.

This article is general information. It does not judge or guarantee the feasibility of any particular property or of a restaurant permit. Investigation and brokerage, and the sale/lease contract, are undertaken by Yotsuba Real Estate Co., Ltd. (licensed real estate agent); preparation of the restaurant permit and other documents submitted to public offices, by Yotsuba Administrative Scrivener Office — 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. Property and permits are put on the same table. Full profile: author page.