What the energy-performance labelling scheme (from April 2024) changed for property sale/rental ads

The key point: From 1 April 2024 (Reiwa 6), a business selling or renting buildings is to endeavour to show an "energy-performance label" in ads and the like for buildings newly built from April 2024 onward. The basis is the best-effort duty in the Act on the Improvement of Energy Consumption Performance of Buildings (Building Energy Efficiency Act = Act No. 53 of 2015) art. 27(1), and a notification by the Minister of Land, Infrastructure, Transport and Tourism (MLIT) that sets the matters and the method of display (MLIT Notification No. 970 of 2023, promulgated 25 September 2023). The label carries energy-consumption performance showing the degree of reduction from the national energy-saving standard (a star rating), insulation performance for homes, whether renewable-energy equipment is present, the evaluation date and more, and on a dwelling label the estimated annual energy cost can also be shown optionally. This is a "best-effort duty," not a "display obligation," but the Minister may give a recommendation, publication and an order to a business that does not display properly (art. 28). What a real-estate company (we) handle is the brokerage of placing the label in ads, the information provision including the important-matters explanation (Real Estate Brokerage Act art. 35), and organising what the owner should arrange first. The energy calculation behind the label and issuing a BELS evaluation certificate go to an architect / registered housing-performance evaluation body; building confirmation and completion inspection to a designated confirmation body / building authority; a subsidy application for energy-saving renovation to each scheme's window (we do not handle it)—each an independent business contracted with separately (no referral fees are exchanged). The final judgment on calculating a particular property's energy performance and conformity rests with the respective licensed professionals and evaluation bodies.

For owners putting homes or commercial property into sale/rental ads, and for sellers/lessors using a broker, this article organises what changed with the energy-performance label and estimated energy cost, in the order of the law and MLIT materials. This is general information; the final judgment on calculating a property's energy performance and preparing the label rests with an architect / registered housing-performance evaluation body and the competent authorities.

Yotsuba Real Estate Co., Ltd. (四葉不動産株式会社), based in Bunkyo, Tokyo, provides surveys and brokerage of residential and commercial real estate. You can consult us from the stage of "what do I have to display when I advertise this property".

On what basis did the energy-performance labelling scheme start, and when?

The basis is art. 27 of the Building Energy Efficiency Act. Art. 27(1) provides that a business selling or renting buildings (a "sales business etc.") must endeavour to display the energy-consumption performance of that building. Art. 27(2) provides that the MLIT Minister sets, and publishes by notification, the matters to be displayed and the method of display and other matters the business is to observe.

Receiving art. 27(2), the notification set is the "Matters a sales business etc. is to display regarding a building's energy-consumption performance, the method of display, and other matters a sales business etc. is to observe in displaying a building's energy-consumption performance" (MLIT Notification No. 970 of 2023, promulgated 25 September 2023). Operation under this notification began on 1 April 2024 (Reiwa 6). A best-effort duty existed before under a 2016 notification too, but what took concrete shape this time is the use of a label in the form set by the state.

Item	Content
Basis law	Building Energy Efficiency Act (Act No. 53 of 2015) art. 27, art. 28
Notification	MLIT Notification No. 970 of 2023 (promulgated 25 September 2023)
Operation start	1 April 2024 (Reiwa 6)
Status	Best-effort duty (not a display obligation; non-compliance may draw a recommendation, publication, order)

In sale/rental ads, what exactly is to be displayed?

What is covered is the ad and the like when selling or renting a building newly built from April 2024 onward. Newspaper and magazine ads, flyers, brochures and internet ads—the media a buyer/renter sees to choose a property—are covered. For display, the state-set "energy-performance label" is used in principle.

The main items on the label are below. The dwelling label and the building/non-residential label differ in part.

Display item	Content	Note
Energy-consumption performance	The degree of reduction from the national standard, shown by a star rating on multiple levels (based on primary energy consumption excluding renewables)	Mandatory
Insulation performance	The envelope's insulation performance, shown on multiple levels	Mandatory for homes (absent for non-residential)
Renewable-energy equipment	"Renewable-energy equipment present" if solar PV etc. is installed	Shown when installed
Estimated energy cost	The estimated annual energy cost (yen)	Optional on a dwelling label; not shown on a building label
Net-zero energy etc.	Display of achieving the ZEH / ZEB level	Shown in the case of third-party evaluation
Evaluation date / type	The evaluation date; self-evaluation or third-party	Mandatory

The star rating is the multi-level rating of "energy-consumption performance," showing how far primary energy consumption excluding renewables is reduced from the national standard. Insulation performance is an item only on the home label, shown on a separate scale. The estimated energy cost is an item that can be shown optionally on a dwelling label; it is not necessarily on every label.

Who calculates the stars and estimated energy cost on the label, and how?

The label's evaluation comes in two forms: "self-evaluation" done by the business, and "third-party evaluation (BELS)" done by an evaluation body.

Self-evaluation is where the sales/rental business creates the label from the result of calculating the building's energy-consumption performance. A "self-evaluation label / certificate creation program" that supports the calculation and label creation is published on the website of the Housing Performance Evaluation and Labeling Association. Third-party evaluation is issued as BELS (the building energy-performance labelling scheme) by an evaluation body such as a registered housing-performance evaluation body, and the net-zero-energy (ZEH/ZEB) display goes on the label in the case of third-party evaluation.

Type of evaluation	Who does it	Status of the label
Self-evaluation	The sales/rental business (the calculation presumes an architect's cooperation)	The label states it is a self-evaluation
Third-party evaluation (BELS)	An evaluation body such as a registered housing-performance evaluation body	States it is a third-party evaluation; a ZEH/ZEB display is possible

The point to grasp, separating the roles, is that the energy calculation behind the star rating, the insulation scale and the estimated energy cost is the specialist field of an architect or a registered housing-performance evaluation body. What a real-estate company (we) handle is the brokerage of placing a finished label in ads correctly and the information provision in the important-matters explanation; we do not do the energy calculation itself. On the idea of energy-saving investment and ZEH, the article on zero-emission conversion of wooden rental housing / condominiums and subsidies, which covers the builder-side energy saving and subsidies, is a useful reference. This article is limited to "display at the time of advertising (a best-effort duty)"; a subsidy application is each scheme's window's field.

Is display an obligation or a best-effort duty, and how are existing properties treated?

Displaying the energy-performance label is a "best-effort duty" under Building Energy Efficiency Act art. 27(1). It is not an "obligation" forcing display itself. However, the MLIT Minister may recommend that a business not displaying per the notification should display (art. 28(1)), may publish the fact if the recommendation is not followed (para. 2), and, where the business without justifiable grounds does not take the recommended measure and this is found to significantly harm the improvement of energy-consumption performance, may order it after hearing the Panel on Infrastructure Development (para. 3). A best-effort duty is not a scheme where anything goes.

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Existing buildings (those for which building confirmation was done before 1 April 2024, and the like) are encouraged to display as with new builds if the energy performance is known, but failing to display does not draw a recommendation etc. A custom-built house is also out of scope under the scheme, with display per the scheme encouraged.

Target	Treatment of display
Ads selling/renting buildings newly built from April 2024	Best-effort duty (non-compliance may draw a recommendation / publication / order)
Existing buildings	Encouraged (not subject to a recommendation etc.)
Custom-built houses	Out of scope (encouraged)

Is a property with no label, or a low one, disadvantaged in a sale or a listing?

To put it within general information, the presence of a label or the level of the rating does not immediately decide whether a property can be sold or rented. It is a best-effort duty, and it is not a scheme where a transaction becomes impossible for want of a label. On the other hand, the more properties in the same area and price range carry an energy-performance label, the more a property without one can look inferior in a buyer's/renter's comparison. The estimated annual energy cost tends to draw interest as information bearing directly on running costs after move-in.

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)	Brokerage of label display in ads; information provision incl. important-matters explanation; organising what to arrange
Architect / registered housing-performance evaluation body	Energy calculation; issuing the BELS certificate / label
Designated confirmation body / building authority	Building confirmation / completion inspection
Each scheme's window	Subsidy application for energy-saving renovation (we do not handle it)
Judicial scrivener	Building / company registration
Tax accountant	Tax on the sale or rental

The property and the ad are ours, the energy calculation and label issuance the architect's / evaluation body's—with the windows separated, connected smoothly from one and the same window. No referral fees are exchanged.

Before placing the ad, what should an owner arrange?

What runs smoothly if the owner arranges it before placing the ad is the following. The objective property-side information (completion date, timing of building confirmation, presence of design documents and the energy calculation, presence of a BELS certificate) is what we confirm as a premise of brokering the ad.

What to arrange	Whom to consult
Whether to create the label by self-evaluation or to obtain a third-party evaluation (BELS)	Architect / registered housing-performance evaluation body
Preparing the energy-calculation result / design documents	Architect (the original designer at new-build, etc.)
Brokerage of label display in ads / important-matters explanation	Real estate (us)
A subsidy where energy-saving renovation is involved	Each scheme's window

For advice on property ads and the energy-performance label, bring it to Yotsuba Real Estate—initial consultation is free

In your message, write the property type (home or commercial), whether new or existing, whether a BELS certificate exists, and whether it is for sale or rent. We talk through the steps of placing the label in the ad, and organising where to refer the energy calculation, label issuance and subsidy.

Frequently asked questions

Q. Is displaying the energy-performance label an obligation or a best-effort duty?
A. A best-effort duty. Building Energy Efficiency Act art. 27(1) provides that a business selling or renting buildings must endeavour to display energy-consumption performance; it is not an obligation forcing display itself. However, a business that does not display per the notification (MLIT Notification No. 970 of 2023) can be given a recommendation by the MLIT Minister, publication if not followed, and even an order (art. 28). A best-effort duty is not a scheme where you need not display.

Q. From when, and which properties, are covered?
A. Operation began on 1 April 2024 (Reiwa 6). Covered is the ad and the like (newspaper/magazine ads, flyers, brochures, internet ads) when selling or renting a building newly built from April 2024 onward. Existing buildings are encouraged to display if the energy performance is known, but do not draw a recommendation etc. if not displayed. A custom-built house is out of scope, with display per the scheme encouraged.

Q. Does the real-estate company decide the stars and the estimated energy cost on the label?
A. No. The energy calculation behind the energy-consumption performance shown in stars, the insulation performance and the estimated energy cost is the field of an architect or a registered housing-performance evaluation body. Self-evaluation is created by the business from the calculation result, and third-party evaluation is issued by an evaluation body as BELS. What a real-estate company (we) handle is the brokerage of placing a finished label in ads correctly and the information provision in the important-matters explanation; we do not do the energy calculation itself.

Q. Is the estimated annual energy cost on every label?
A. No. The estimated energy cost is an item that can be shown optionally on a dwelling label; it is not shown on a building label. Energy-consumption performance (stars), the evaluation date and the self/third-party distinction are mandatory, but the estimated energy cost and whether renewable-energy equipment is present differ by property and type of evaluation. The details of the display form are set in the notification and can be amended, so confirm the latest MLIT guidance and the notification text, noting the date consulted.

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 notification, forms and operational details can be amended, so confirm them in the MLIT guidance on the energy-performance labelling scheme, noting the date consulted. The calculation of a particular property's energy performance and the label's creation are judged by an architect / registered housing-performance evaluation body and the competent authorities. Public materials were all consulted on 7 November 2026. The sources below are in Japanese.

• e-Gov Law Search: Act on the Improvement of Energy Consumption Performance of Buildings (Act No. 53 of 2015; art. 27(1) = the best-effort duty of a sales business etc. to display energy-consumption performance, art. 27(2) = the MLIT Minister sets and publishes by notification the matters and method of display, art. 28 = recommendation, publication and order to a business not displaying per the notification, plus report collection and on-site inspection)
• "Matters a sales business etc. is to display regarding a building's energy-consumption performance, the method of display, and other matters a sales business etc. is to observe" (MLIT Notification No. 970 of 2023, promulgated 25 September 2023; the matters to display and the form. Confirm the latest version including later amendments)
• MLIT "Building energy-performance labelling scheme (energy-performance label)" guidance (operation start April 2024; the targets, label display items, and the self-evaluation / third-party evaluation (BELS) distinction. Consulted 7 November 2026)
• Housing Performance Evaluation and Labeling Association "self-evaluation label / certificate creation program" and "BELS" guidance (consulted 7 November 2026)

This article provides general information and does not guarantee a particular property's energy performance or the label's content. Brokerage of label display in ads and information provision are real estate's (ours); the energy calculation and the BELS certificate / label issuance an architect's / registered housing-performance evaluation body's; building confirmation / completion inspection a designated confirmation body's / building authority's; a subsidy application for energy-saving renovation each scheme's window'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 residential and commercial real estate. Author profile

Updated: 7 November 2026