What should you check in a property for opening a craft-beer brewery (liquor manufacturing)?

In short: for a property to open a craft-beer brewery (liquor manufacturing), four things bite first: (1) the use district — a brewery is a "factory" under Building Standards Act Table 2, and the district where it may go is narrowed by the floor area of the work space and by hazard / environmental impact; (2) the building side — floor loading to carry tanks, ceiling height, electrical capacity, cold/storage zones; (3) brewing wastewater — high BOD, subject to the Water Pollution Control Law as a designated facility plus sewerage / septic-tank rules; (4) the minimum production quantity for the liquor manufacturing licence (60 kL/year for beer, 6 kL/year for happoshu). The licence itself is under the jurisdiction of the competent tax office (National Tax Agency) and is not the work of a real estate agent or an administrative scrivener. Investigation, brokerage and the sale/lease contract for the property are handled by our company (Yotsuba Real Estate Co., Ltd.); preparation of documents such as the taproom's restaurant-business permit for the public health centre, by Yotsuba Administrative Scrivener Office. The licence goes to the tax office, the building confirmation and floor-loading design to an architect, the wastewater equipment to a facilities contractor, and liquor / corporate tax to a tax accountant. These are independent business entities, and you engage each directly.

"The former tenant was a restaurant, so you can just put in the brewing tanks and open" — you lease on that basis, and when you start mashing you find the floor is about to give way, the wastewater cannot go into the sewer, and the electricity is short. The kind of rework that happens with restaurant and clinic properties weighs even heavier on a brewery. This article is for entrepreneurs opening a brewpub or small brewery in Tokyo, and for those leasing or seeking such a property: what you can confirm before you decide the lease or purchase, set out in order from the Liquor Tax Act, the City Planning Act, the Building Standards Act, the Water Pollution Control Law and the Food Sanitation Act. Because the liquor manufacturing licence itself is under the tax office's jurisdiction, we separate where to consult about obtaining it; this article focuses on the property conditions seen from the real estate side. Final confirmation of feasibility is done at the counters of the competent tax office, the designated administrative agency, the public health centre, the fire department and the local sewerage / environment department.

Which use districts allow a craft-beer brewery?

A brewery is, in law, a "factory that manufactures things." Its treatment differs from that of a restaurant (a shop) or a clinic, and the places where it may go are narrowed by the use district. This is the first gate.

Building Standards Act (Act No. 201 of 1950) Article 48 and Table 2 set out the buildings that may be built in each use district. For factories, the district is divided by two yardsticks: the total floor area of the work space, and whether there is a large hazard or a risk of markedly worsening the environment. Liquor manufacturing (brewing) does not usually fall into the categories of factories handling large volumes of dangerous goods or posing a risk of markedly worsening the environment, but the district where it may go changes with the size of the work space. Roughly:

Use district	Treatment as a factory (guide)
Category 1/2 exclusively low-rise residential / rural-residential	In principle not allowed (except parts of small combined dwellings)
Category 1/2 mid/high-rise exclusively residential	In principle not allowed (factories cannot be built)
Category 1/2 residential / quasi-residential	Allowed within a small work-space floor area (roughly 50 m² or less) meeting motor-output conditions
Neighbourhood commercial / commercial	Allowed with a work-space floor area of roughly 150 m² or less
Quasi-industrial	Factories with little hazard / environmental impact are in principle allowed (a brewery fits easily)
Industrial / exclusively industrial	Allowed (but a shop cannot be combined in exclusively industrial)

If you also want a taproom (on-site serving) and scale, quasi-industrial / industrial districts tend to be the realistic candidates, while note that a serving shop cannot be combined in an exclusively industrial district. The stages of work-space floor area (50 m², 150 m², etc.) and the treatment of motor output are divided by the operation of the designated administrative agency (the local building official), so match your intended production scale against the property's use district early. How use district and floor-area ratio move land pricing is set out at why Japanese land prices change with "floor-area ratio". Commercial property in general is at investment / commercial real estate; the points on company formation and office selection, at company formation and office selection.

What building-side requirements — floor loading, ceiling height, electrical capacity — are easy to overlook?

After the use district, what bites is whether the building itself can bear the brewing equipment. Items that a restaurant conversion does not cover line up.

Confirm before contract	Why it bites
Floor loading (imposed load)	A full fermentation / conditioning tank is hundreds of kilograms to several tonnes each. Some floors at office spec (about 300 kg/m²) cannot bear it
Ceiling height	Height is needed to raise vertical fermentation tanks, flues and piping
Electrical capacity	Chillers, boilers, pumps and refrigerators consume power. On a single-phase-only property, confirm whether three-phase (power) can be brought in
Hot-water / boiler / gas capacity	Large heat source is needed for the boil (wort heating)
Cold / storage zones	Whether temperature-controlled zones for fermentation, conditioning, raw materials (malt, hops) and product can be taken
Delivery route	Frontage and road width allowing tanks and product pallets in and out, and a forklift to pass

Floor loading in particular is easily overlooked. A full tank is locally heavy, and office or retail floor spec may require reinforcement. Whether the floor can be reinforced and the structure allows it is an architect's (structural design) judgment. After confirming the structure of the existing building, work out with the lessor before contract the extent of reinforcement needed and how it feeds back into the lease's restoration clause. For used buildings, also confirm whether a certificate of inspection exists. A used building without one may face obstacles in the change-of-use confirmation application and financing, and a survey of conformity may confirm the legality at the time of construction. This point is set out at can a used property without a certificate of inspection be converted to welfare use. Design and construction are handled by an architect and a facilities contractor; we (the real estate company) assist with the preliminary check of whether the property can meet these conditions and with negotiations with the lessor.

Where do you check brewing wastewater (BOD, volume) and the sewerage / septic-tank rules?

A brewery handles water and organic matter even more than a restaurant. Wastewater from mashing, washing, yeast and spent grain has high BOD (biochemical oxygen demand) and large volume. This bears directly on property selection.

First, a brewery can become an establishment with a designated facility under the Water Pollution Control Law (Act No. 138 of 1970). Table 1 of the enforcement order lists, as designated facilities, the bottle-washing facilities, the facilities heating raw materials by boiling, the filtration facilities, and the distillation facilities used for the liquor manufacturing business (beer, sake, etc.). When installing a designated facility, notification to the prefectural governor, etc. is required (Article 5 of the Law). When discharging into public waters (rivers, etc.), the effluent standards under Article 3 (permissible limits for BOD, SS, etc.) apply.

Next, many urban properties connect to the public sewer. Here the Sewerage Act (Act No. 79 of 1958) and each local government's sewerage ordinance apply, and notification of installation of a designated facility (Sewerage Act Article 12-3) or installation of a treatment facility (jogai-shisetsu) to treat wastewater exceeding the standard without dilution may be required. On a property using a septic tank outside the sewer area, treatment and maintenance under the Septic Tank Act are separately required.

Wastewater check	Where to confirm
Public sewer or septic tank; feasibility of connection	Local sewerage bureau; the property's water-supply/drainage drawings
Whether notification of a designated facility is required	Prefecture / local government (Water Pollution Control Law, Sewerage Act)
Whether a treatment facility is required (BOD, etc. discharge standards)	Local sewerage ordinance. Values differ by local government
Drainage-pipe diameter, gradient, margin of discharge volume	Facilities contractor; drainage drawings

The wastewater standard values and the operation of notification differ by local government and can change even at the time of writing. After conveying the brewing scale (how many kilolitres a year, brewed with how much water), confirm directly with the local sewerage / environment department before you start. Design and construction of drainage / treatment facilities are handled by a facilities contractor, and a designated works contractor is involved in the drainage consultation. Water supply/drainage and ventilation property conditions share many points with restaurants: when opening a restaurant in a skeleton property — how far property selection is decided by exhaust, grease trap and fire prevention and a cleaning-shop property and water supply/drainage and wastewater treatment are useful references.

What is the minimum production quantity for a liquor manufacturing licence, and who do you consult?

To manufacture liquor you need, separately from the property, a liquor manufacturing licence. This is a different matter of jurisdiction from the property.

Liquor Tax Act (Act No. 6 of 1953) Article 7(1) provides that a person intending to manufacture liquor must, for each manufacturing site, obtain the licence of the district director of the tax office having jurisdiction over the location of that site, separately by category of the liquor to be manufactured. In other words, the licence is under the jurisdiction of the competent tax office (National Tax Agency) and is not within the scope of a real estate agent or an administrative scrivener.

And the licence has a minimum production quantity standard. Liquor Tax Act Article 7(2) provides that the licence cannot be obtained where the expected production quantity for one year does not reach the quantity set for each category. The main quantities relevant to craft beer are:

Category	Minimum annual production quantity
Beer	60 kilolitres
Happoshu (sparkling liquor)	6 kilolitres
Fruit liquor	6 kilolitres
Liqueur	6 kilolitres
Sake (seishu)	60 kilolitres

This is the best-known dividing line in craft-beer start-ups. A "beer" licence requires an expected production of 60 kL a year, but making it in a way that falls under "happoshu" by using adjuncts such as fruit or spices lowers the minimum production quantity to 6 kL a year. This is why the common path is for a small brewery to start on a happoshu licence and consider a beer licence as scale grows. Note that the amendment to the Liquor Tax Act on 1 April 2018 (Heisei 30) broadened the definition of "beer" (the malt ratio was lowered from 67% or more to 50% or more, and adjuncts such as fruit and spices were allowed / Liquor Tax Act Article 3, item 12), so some products that were formerly happoshu came to be included in beer; but the distinction of minimum production quantity by licence remains. The cases where the licence may be refused (personal, locational, business-basis and supply-demand-adjustment requirements) are set out in Article 10 of the Law.

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The final judgment on the need for and feasibility of the licence rests with the competent tax office. After organising the intended categories and production quantities, consult the tax office's liquor guidance officer (liquor charge), or a professional well-versed in liquor licences. We and our office do not carry out the licence itself. We handle up to confirming whether the property meets the manufacturing, wastewater and electricity conditions.

If you combine brewing with a taproom (on-site serving), what changes about the property?

Making it a brewpub (with a taproom) where your own beer is served on-site adds, on top of the manufacturing licence, a permit for serving food and drink. The property conditions increase by one step too.

Serving beer on-site to let people eat and drink is a business requiring the restaurant-business permit (public health centre) under Food Sanitation Act (Act No. 233 of 1947) Article 55. Confirm before contract whether the kitchen, hand-washing and zoning can meet the public health centre's facility standards. The property conditions for a restaurant-business permit are set out at the restaurant-business permit and the public health centre's facility standards (administrative scrivener).

Further, selling the liquor you make outside the shop (retailing in bottles or cans) needs a separate liquor sales-business licence, and mainly serving liquor after midnight needs notification of a late-night liquor-serving restaurant business. These are licences separate from manufacturing, and preparation of the shop's licence-application documents is an administrative scrivener's work. The liquor retail licence and the shop's property requirements are set out at conditions for a shop property that can obtain a liquor retail licence; late-night serving notification, at requirements for notification of a late-night liquor-serving restaurant business (both administrative scrivener).

Confirmation added by combining	Jurisdiction / who
On-site restaurant-business permit	Public health centre / documents by administrative scrivener
Bottle/can retail (liquor sales-business licence)	Competent tax office
Notification of serving liquor after midnight	Police station / documents by administrative scrivener
Fire-fighting equipment and evacuation (more seats)	Fire department / fire-fighting-equipment officer
No combined shop in exclusively industrial	Designated administrative agency (use district)

Between a manufacturing-only property and one that also serves food and drink, the view of the use district, fire prevention and the public health centre changes. If you have a taproom, narrow the search in this order: avoid exclusively industrial districts, and choose a property that can meet the serving facility standards and fire prevention.

Whom do you ask separately for the licence, building, wastewater and food serving (separate engagement)?

Opening a craft-beer brewery is a field involving many professionals. Sorting out the traffic at the start avoids confusion.

What to do	Who
Investigation, condition check, brokerage, sale/lease contract of the property	Yotsuba Real Estate Co., Ltd. (licensed real estate agent)
Liquor manufacturing licence (Liquor Tax Act)	Under the competent tax office's (NTA) jurisdiction. The operator consults the tax office, or a professional well-versed in liquor licences
Taproom's restaurant-business permit / preparation of public-health-centre documents	Yotsuba Administrative Scrivener Office (administrative scrivener)
Change-of-use / building confirmation / floor-loading structural design	Architect (designated confirmation-and-inspection body)
Design and construction of water supply/drainage, wastewater treatment, treatment facility	Facilities contractor / designated works contractor
Fire consent and fire-fighting equipment	Fire department / fire-fighting-equipment officer
Liquor tax, corporate tax, accounting	Tax accountant
Employees' hiring, social insurance	Certified social insurance labour consultant

Investigation, brokerage and the sale/lease contract of the property are handled by Yotsuba Real Estate Co., Ltd. (licensed real estate agent, Tokyo Governor (1) No. 113304). Preparation of documents submitted to public offices, such as the restaurant-business permit, is handled by Yotsuba Administrative Scrivener Office. These two (the real estate company and the administrative scrivener office) are independent business entities. You engage each directly. We neither pay nor accept referral fees or introduction commissions. The liquor manufacturing licence goes to the competent tax office; building confirmation and structural design to an architect; wastewater equipment to a facilities contractor; fire-fighting equipment to a fire-fighting-equipment officer; liquor and corporate tax to a tax accountant — each engaged or consulted by you directly. Consultation is free of charge. Administrative counters, forms, ordinance figures and the operation of intake change. At the time you start, confirm directly the pages of the competent tax office, the designated administrative agency, the public health centre, the fire department and the local sewerage / environment department.

Frequently asked questions

Q. Can a craft-beer brewery be opened in a residential area (Category 1 exclusively low-rise residential)?
A. In principle no. A brewery is a "factory" under Building Standards Act Table 2 and cannot be built in Category 1/2 exclusively low-rise residential or mid/high-rise exclusively residential districts. There is room even in residential districts if the work-space floor area is small, but as production scale rises, neighbourhood-commercial / commercial (work space roughly 150 m² or less) or quasi-industrial / industrial districts are realistic. Feasibility by use district differs per property, so confirm at the designated administrative agency's counter.

Q. If it is a restaurant conversion property, can you just put in brewing tanks and start?
A. Not necessarily. Restaurant-spec floors often do not anticipate full tanks (hundreds of kilograms to several tonnes each), so floor-loading reinforcement may be needed. Electricity (power) capacity, hot-water / boiler and drainage diameter and treatment may also be short. Confirm floor loading and structure with an architect, and wastewater with a facilities contractor and the local government, before contract.

Q. Can brewery wastewater be discharged straight into the sewer?
A. Not necessarily as is. Brewing wastewater is high in BOD (organic matter) and large in volume, so in a public sewer, under the Sewerage Act and the local sewerage ordinance, notification of a designated facility or installation of a treatment facility may be required. The standard values differ by local government, so convey the intended brewing scale and confirm with the local sewerage / environment department before you start.

Q. Do you really have to be able to make 60 kilolitres a year to get a beer licence?
A. A "beer" licence requires an expected production of 60 kilolitres a year (Liquor Tax Act Article 7(2)). By contrast, making it in a way that falls under "happoshu" through the use of adjuncts lowers the minimum production quantity to 6 kilolitres a year. This is why many small breweries start on a happoshu licence. Because the judgment on the need for and feasibility of the licence is under the competent tax office's jurisdiction, organise the categories and production quantities and consult the tax office.

Sources (primary)

• e-Gov "Liquor Tax Act" — Act No. 6 of 1953. Art. 3, item 12 = definition of beer (malt ratio 50% or more, etc.); Art. 7(1) = liquor manufacturing licence (by category, per manufacturing site, district director of the competent tax office); Art. 7(2) = minimum production quantity standard (beer 60 kL, happoshu 6 kL, fruit liquor 6 kL, liqueur 6 kL, sake 60 kL, etc.); Art. 10 = cases where the licence may be refused. Accessed 26 September 2026.
• National Tax Agency "Interpretive circular on the Liquor Tax Act (Art. 7 liquor manufacturing licence)" — treatment of the licence categories, requirements and minimum production quantity standard. Accessed 26 September 2026.
• e-Gov "Building Standards Act" — Act No. 201 of 1950. Art. 48 = use-district restrictions; Table 2 = buildings within use districts (factories divided by total work-space floor area and hazard / environmental impact); Art. 6(1)(i) and Art. 87(1) = confirmation application on change of use of a special building. Accessed 26 September 2026.
• e-Gov "Water Pollution Control Law" — Act No. 138 of 1970. Art. 2(2) = designated facility; Art. 3 = effluent standards; Art. 5 = notification of installation of a designated facility. Table 1 of the enforcement order lists, as designated facilities, bottle-washing, boiling-heat-treatment, filtration and distillation facilities used for the liquor manufacturing business. Accessed 26 September 2026.
• e-Gov "Sewerage Act" — Act No. 79 of 1958. Art. 12-3 = notification of installation of a designated facility; treatment facility. The specific discharge-standard values are set by each local government's sewerage ordinance. Accessed 26 September 2026.
• e-Gov "Food Sanitation Act" — Act No. 233 of 1947. Art. 55 = business permit (including restaurant business; public health centre). The article number after the amendment effective 1 June 2021. Accessed 26 September 2026.

The feasibility by use district (the stages of work-space floor area, the treatment of motor output) and whether a change-of-use confirmation application is required vary with the property's floor area, structure and district designation, and are divided by the designated administrative agency's operation. This article does not assess any particular property. At the time you start, confirm at the counters of the designated administrative agency, the public health centre, the fire department and the local sewerage / environment department.
The wastewater discharge standards, the need for a treatment facility and the figures are set by each local government's sewerage ordinance and differ by local government. Convey the intended brewing scale and confirm with the local government.
The need for and feasibility of the liquor manufacturing licence and the liquor sales-business licence are under the competent tax office's (NTA) jurisdiction. Consult the tax office about the licence, and a tax accountant about the calculation and filing of liquor and corporate tax.
This article is general information. It does not judge or guarantee the feasibility of any particular property or the obtaining of a licence or permit. Investigation and brokerage of the property and the sale/lease contract are undertaken by Yotsuba Real Estate Co., Ltd. (licensed real estate agent); preparation of public-office documents such as the restaurant-business permit, by Yotsuba Administrative Scrivener Office — independent business entities, engaged separately and directly. Building confirmation and structural design are handled by an architect, and wastewater equipment by a facilities contractor. 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 licensing (administrative procedure) are put on the same table. Full profile: author page.