A property for a drugstore (store-based medicine retailing): zoning and floor area

The key point: For a drugstore that does no dispensing—mostly Class-2 and Class-3 OTC medicines—zoning and floor area are what bite first. Store-based medicine retailing is treated as a "store engaged in retail" under the Building Standards Act, so it is in principle not allowed in the Category-1 low-rise exclusive residential zone (only the Cabinet-Order combined-use dwelling, with a shop part of 50 m² or less, is permitted), capped at 150 m² in the Category-2 low-rise zone, 500 m² in the Category-1 mid/high-rise residential zone, 3,000 m² in the Category-1 residential zone, and barred entirely in the exclusive industrial zone (Building Standards Act art. 48; Appended Table 2). When converting from another use (a fit-out or a different use), a change-of-use confirmation is required once the area for that use exceeds 200 m² (art. 87(1); art. 6(1)(i)). The licence itself is granted per store by the prefectural governor (the mayor of a city with a public health centre, or the ward head of a special ward), and it may be refused if the structure and equipment fail the ministerial standards (Pharmaceuticals and Medical Devices Act art. 26(1) and (4)). What a real-estate company (we) handle is the property-suitability survey—zoning, floor area, frontage road, loading access, the condition of any existing building—and brokerage including the important-matters explanation (Real Estate Brokerage Act art. 35). The store-sales licence application and the registered-seller / pharmacist staffing belong to an administrative scrivener; shifts timed to the required person's on-site presence and social insurance to a certified social insurance labour consultant; the change-of-use confirmation to an architect and the building authority; registration to a judicial scrivener; tax to a tax accountant—each an independent business contracted with separately (no referral fees are exchanged). The final judgment on whether medicines may be sold rests with the public health centre and the licensed professionals.

For operators opening a new drugstore and for real-estate staff handling such properties, this article organises what you can confirm before signing, in the order of the law and municipal guidance. This is general information; the final judgment on whether a property meets the Pharmaceuticals and Medical Devices Act / Building Standards Act rests with the competent public health centre / building authority and the respective licensed professionals.

Yotsuba Real Estate Co., Ltd. (四葉不動産株式会社), based in Bunkyo, Tokyo, provides surveys and brokerage of commercial real estate. You can consult us from the stage of "can I open a drugstore in this property".

How does a drugstore differ from a pharmacy, and what licence does the property need?

A "drugstore" and a "pharmacy" are different categories in law. A pharmacy fills prescriptions and dispenses, and needs a pharmacy opening licence (Act art. 4). A drugstore in the sense used here does no dispensing and sells designated OTC and general OTC medicines; it falls under the "store sales business" licence among medicine-sales businesses (Act art. 24(1), art. 25, art. 26).

The range a store sales business may sell is limited. Art. 27 bars a store sales operator from selling 薬局医薬品 (pharmacy-only medicines, including prescription medicines). So a store sales business may sell designated OTC and general OTC medicines, and general OTC medicines are classified by risk into Class 1, Class 2 and Class 3 (Act art. 36-7).

Category	Basis	Medicines mainly handled	Effect on the property
Pharmacy	Act art. 4 (opening licence)	Dispensing + OTC	A dispensing room is a premise
Store sales (drugstore)	Act art. 24(1), art. 26	Designated / general OTC (Class 1–3)	No dispensing room; storage/display equipment for medicines needed

This article assumes the latter—a store sales business without dispensing. From the property side, the absence of a dispensing room gives latitude in the sales-floor and loading design, but under the Building Standards Act it fully bears the zoning, floor-area and change-of-use restrictions as a "store engaged in retail".

Can a drugstore open under the zoning, and does floor area cap it?

Store-based medicine retailing is treated as a "store engaged in retail" under Building Standards Act Appended Table 2. Whether it may open, and the floor-area ceiling, split by zone (art. 48; Appended Table 2):

Zone	Retail store: permitted / ceiling	Basis
Category-1 low-rise exclusive residential	In principle not allowed (only a Cabinet-Order combined-use dwelling, shop part ≤ 50 m²)	Table 2 (i)
Category-2 low-rise exclusive residential	≤ 150 m²; not on the third floor or above	Table 2 (ii)
Category-1 mid/high-rise residential	≤ 500 m²; not on the third floor or above	Table 2 (iii)
Category-2 mid/high-rise residential	roughly ≤ 1,500 m²	Table 2 (iv)
Category-1 residential	barred above 3,000 m² (≤ 3,000 m² allowed)	Table 2 (v)
Category-2 residential / quasi-residential / neighbourhood commercial / commercial / quasi-industrial	in principle allowed (check separate limits for large uses)	Table 2
Industrial	a store up to 10,000 m² allowed	Table 2
Exclusive industrial	a store engaged in retail is not allowed	Table 2 (xi)

Two points. First, in the low-rise and mid/high-rise residential zones the floor-area ceiling bites: a roadside large-format store needs a Category-1 residential zone (≤ 3,000 m²) or a neighbourhood-commercial / quasi-industrial zone, and you cannot put a 300 m² store in a Category-2 low-rise zone. Second, in the exclusive industrial zone a store engaged in retail cannot be built at all—even a cheap lot on a former factory site will not take a drugstore if the zone is exclusive industrial.

This property-side condition—zoning, floor area, frontage-road width, parking-provision ordinance—is what we survey and explain in the important-matters explanation (art. 35). Because the specific numbers and the Cabinet-Order details change on amendment, check the zoning map and municipal ordinance of the intended site, noting the date consulted.

What do you check on a change-of-use confirmation and the structure/equipment when converting an existing store?

A fit-out from a convenience store or another retail store looks attractive, with sales floor, back-of-house and loading in place. But the two costly things to overlook on conversion are the change-of-use confirmation and the medicine structure/equipment.

A store engaged in retail is a special building under Building Standards Act Appended Table 1 (iv). When converting from another use (office, warehouse, etc.) to a drugstore, if the floor area for that use exceeds 200 m², a change-of-use confirmation is required (art. 87(1), applying art. 6(1)(i)). At 200 m² or below, no confirmation is needed. This 200 m² line was raised from 100 m² by the 2019 amendment, in force on 25 June 2019.

Check item	Why it matters	How to check
Change-of-use confirmation	A retail store is a special building; conversion above 200 m² needs confirmation	Area of the changed part, the prior use; inquire with the building authority / confirmation body
Storage/display equipment for medicines	A store sales licence may be refused if structure/equipment fail the standard (Act art. 26(4))	A zone to store/display medicines apart from other goods; an information-provision setup if handling Class 1
Loading access / parking	Loading and customer vehicles turn on the municipal ordinance and frontage-road width	Loading space, the parking-provision threshold, frontage-road width
Condition of existing equipment	Even in a fit-out, check that water/drainage, electrical capacity and HVAC suffice for a sales floor	Contract power, distribution board, power for refrigerated fixtures, ventilation

Also note that "the previous store could operate" does not mean "your drugstore can use it." The store sales licence is per store and per licensee, so the previous tenant's licence does not carry over; you re-apply. Whether the zone to store and display medicines apart from other goods meets the structure/equipment standard is checked against the competent public health centre once the layout is set.

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The objective condition (area, electrical capacity, loading access) is ours to confirm; whether the structure/equipment meets the standard and the licence application belong to an administrative scrivener; the change-of-use confirmation to an architect and the building authority. For finding commercial property see the consultation desk for commercial / investment real estate; for a base/office property see the desk for business bases and office property. On zoning and floor area, the articles on a clinic property and zoning and a care-business property and zoning are useful references.

Once the property is set, to whom do you split the licence, staffing, labour and tax?

A drugstore opening really begins once the property is set. The store sales licence is granted per store by the prefectural governor (the mayor of a city with a public health centre, or the ward head of a special ward) (Act art. 26(1)). It may be refused if the store's structure and equipment fail the ministerial standards, or if the system for selling and supplying medicines is inadequate (art. 26(4)).

Staffing is designed alongside the property. The operator must manage the store in person or through a designated person, and that store manager must be a pharmacist or a registered seller under the ministerial ordinance (art. 28(1), (2)). A store handling only Class-2 and Class-3 medicines can make a registered seller the store manager; a store handling Class-1 medicines needs a pharmacist—a difference that drives the hiring plan. Preparing this licence application and designing the registered-seller / pharmacist staffing is an administrative scrivener's field; see the administrative-scrivener article on the drugstore (store sales) structure/equipment and registered sellers.

The roles split as below. These cannot be bundled into one contract; each is an independent business contracted with separately.

Who	Role
Real estate (we)	Survey of zoning, floor area, loading access, existing building; brokerage incl. important-matters explanation
Administrative scrivener	Store sales licence application; registered-seller / pharmacist staffing
Architect / building authority	Change-of-use confirmation; structure/equipment design
Labour consultant	Shifts timed to opening hours and the required person's presence; night/holiday premiums; social insurance
Judicial scrivener	Building / company registration
Tax accountant	Tax after opening

The property is ours, the licence the administrative scrivener's, the change-of-use the architect's—with the windows separated, connected smoothly from one and the same window. No referral fees are exchanged.

Bring your drugstore property search to Yotsuba Real Estate—initial consultation is free

In your message, write "drugstore," the desired area, the expected sales-floor size, the classes handled (whether you stock Class 1, or mainly Class 2/3), and whether it is a fit-out or a bare lot. We talk through everything from confirming zoning, floor area, the need for a change-of-use confirmation and loading access, to organising who to refer the licence, staffing, labour and tax to.

Frequently asked questions

Q. Are there properties where a drugstore cannot open due to zoning?
A. Yes. Store-based medicine retailing is treated as a "store engaged in retail" under the Building Standards Act and cannot open in the exclusive industrial zone (Table 2 (xi)). The Category-1 low-rise exclusive residential zone is in principle barred, limited to a Cabinet-Order combined-use dwelling (shop part ≤ 50 m²). There are also floor-area ceilings: 150 m² in the Category-2 low-rise zone, 500 m² in the Category-1 mid/high-rise zone, 3,000 m² in the Category-1 residential zone (art. 48; Appended Table 2). A roadside large-format store is chosen from the neighbourhood-commercial / quasi-industrial or Category-1 residential (≤ 3,000 m²) zones.

Q. When converting an office or warehouse to a drugstore, is a change-of-use confirmation needed?
A. A store engaged in retail is a special building (Appended Table 1 (iv)), so a change of use where the floor area for that use exceeds 200 m² requires a confirmation (art. 87(1) applying art. 6(1)(i)). At 200 m² or below, no confirmation is needed. This 200 m² line was raised from 100 m² by the amendment in force on 25 June 2019. The final judgment on need rests with the building authority / confirmation body, and the design is an architect's field.

Q. Where is the store sales licence filed, and what about the property is examined?
A. The store sales licence is granted per store by the prefectural governor (the mayor of a city with a public health centre, or the ward head of a special ward) (Act art. 26(1)). It may be refused if the store's structure and equipment fail the ministerial standards, or if the selling/supply system is inadequate (art. 26(4)). A zone to store and display medicines apart from other goods is among the points examined. Preparing the application is an administrative scrivener's field; we handle the property-condition check and brokerage.

Q. If the store handles only Class-2 and Class-3, is a pharmacist unnecessary?
A. The store manager must be a pharmacist or a registered seller (Act art. 28(2)), and a store handling only Class-2 and Class-3 medicines can make a registered seller the store manager. A store handling Class-1 medicines needs a pharmacist. This bears directly on the hiring plan and the opening-hours shift design: organising the staffing system is an administrative scrivener's field, and shifts timed to opening hours plus social insurance a labour consultant's. From the property side, we confirm whether a route and back-of-house let the required person stay on site at all times.

Sources

The following public materials are starting points. Laws are amended, so check the current article, paragraph, item, enforcement date and latest amendment on e-Gov Law Search. The zoning map and parking-provision ordinance of the intended site differ by municipality and change from time to time, so confirm them with the municipality concerned. Whether a particular property meets each standard is judged by the competent public health centre / building authority and the respective licensed professionals. Public materials were all consulted on 6 November 2026. The sources below are in Japanese.

• e-Gov Law Search: Act on Securing Quality, Efficacy and Safety of Products including Pharmaceuticals and Medical Devices (Act No. 145 of 1960; art. 24(1) = medicine-sales licence, art. 25 = licence types, art. 26(1) = store sales licence granted per store by the prefectural governor etc., art. 26(4) = may refuse where structure/equipment fail the standard, art. 27 = a store sales operator may not sell pharmacy-only medicines, art. 28(1),(2) = store manager must be a pharmacist or registered seller, art. 36-7 = Class-1/2/3 classification of general OTC medicines)
• e-Gov Law Search: Enforcement Regulation of the same Act (MHW Ordinance No. 1 of 1961; structure/equipment and display standards for store sales; confirm the specific numbers in the regulation text and MHLW notices)
• e-Gov Law Search: Building Standards Act (Act No. 201 of 1950; art. 48 / Appended Table 2 = building restrictions within zones for a store engaged in retail; Appended Table 1 (iv) = a store engaged in retail as a special building; art. 6(1)(i) = confirmation where a special building's use area exceeds 200 m²; art. 87 = application to change of use)
• The zoning map, parking-provision ordinance and development guidance published by the municipality of the intended site (confirm with the municipality; consulted 6 November 2026)

This article provides general information and does not guarantee that a particular property meets the Pharmaceuticals and Medical Devices Act / Building Standards Act. The property-suitability survey and brokerage are real estate's (ours); the store sales licence application and the registered-seller / pharmacist staffing an administrative scrivener's; the change-of-use confirmation and structure/equipment design an architect's and the building authority's; shifts and social insurance a labour consultant's; registration a judicial scrivener's; tax a tax accountant's—each judged and handled by them.

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). As a licensed real estate transaction specialist in Bunkyo, Tokyo, we provide surveys and brokerage of commercial real estate. Author profile

Updated: 6 November 2026