Registering a poisons and deleterious substances sales business in Japan: premises and the handling supervisor

In short: to sell poisons or deleterious substances such as reagents or agricultural chemicals, you need a sales-business registration from the prefectural governor for each store (Article 3(3) and Article 4 of the Poisonous and Deleterious Substances Control Act). Registration presupposes that the store meets the premises standard (Article 4-4 of the enforcement regulation) and that a poisons-and-deleterious-substances handling supervisor is in place (Articles 7 and 8).

Sources checked: 23 October 2026. This article organises the store, premises and staffing from property selection onward. The provisions were reconciled with e-Gov, but the final amendment dates and full commencement histories of each law, and each municipality's fees and standard processing periods, remain unverified. The competent prefecture (public health centre) and qualified professionals assess individual registration.

What is a poisons and deleterious substances sales-business registration, and what categories are there?

Article 3(3) of the Act provides that no one may sell or deliver poisons or deleterious substances — or store, transport or display them for the purpose of sale or delivery — unless they hold a sales-business registration. Under Article 4, the registration is granted for each store by the prefectural governor for the store's location; in cities and special wards with a public health centre, the mayor or ward head is the point of contact.

Under Article 4-2, the sales-business registration is divided into three categories by the items that may be handled. The broader the items, the broader the examination category required of the supervisor, so confirm the category when deciding the format.

Registration category	Items that may be handled	Basis
General sales business	No item restriction	Article 4-2
Agricultural-item sales business	Only items needed for agriculture as set by ministerial ordinance	Article 4-2, Article 4-3(1)
Specified-item sales business	Only items set by ministerial ordinance	Article 4-2, Article 4-3(2)

An agricultural-item seller may not handle items other than agricultural items, and a specified-item seller may not handle items other than those designated (Article 4-3). Which item falls in which category is set by ministerial ordinance; confirm it in the competent authority's latest guidance.

Where are the store's premises standards set?

One registration requirement is the premises. Article 5 provides that registration is withheld where the store's premises do not meet the standard set by ministerial ordinance. That standard is Article 4-4 of the enforcement regulation. Article 4-4(2) provides that, for a sales-business store, items (ii) to (iv) of paragraph (1) (storage, display, transport) apply mutatis mutandis. Item (i) of paragraph (1), required of a manufacturing plant (structure and treatment equipment for manufacturing work), does not apply to a sales-business store.

Item to confirm	Basis (enforcement regulation Article 4-4)
Equipment that stores poisons/deleterious substances separately from other goods	Paragraph (1), item (ii)(a) (applied to sales businesses)
No risk of leakage or seepage from containers or storage equipment	Paragraph (1), item (ii)(b)/(c)
A lockable fixture at the storage place (or a sturdy fence where locking is inherently impossible)	Paragraph (1), item (ii)(d)/(e)
A lockable fixture at the display place	Paragraph (1), item (iii)
No risk of leakage from transport equipment	Paragraph (1), item (iv)

Numeric areas and how partitions are drawn differ in detail by municipal review criteria. For a leased property, the key points are whether you can secure a partitioned storage space and lockable storage and display fixtures, and whether you can prepare the outline diagram of the store's equipment to attach. This article does not give fixed figures or forms (they vary by municipality and we have not verified them, so they remain unverified). The final judgement on premises conformity is made by the receiving authority.

Who may be the handling supervisor?

Article 7 provides that a sales business must place a dedicated handling supervisor at each store to prevent harm to public health from poisons and deleterious substances. The seller may also serve as the supervisor. When a supervisor is placed or changed, notify the prefectural governor within 30 days (Article 7(3)).

Who may be a supervisor is set in Article 8.

Qualification	Content
Pharmacist	Article 8(1)(i)
A person who completed a course in applied chemistry	A graduate etc. of a school set by ministerial ordinance (Article 8(1)(ii))
A person who passed the handling examination	Article 8(1)(iii)

However, a person under 18, a person who cannot properly perform the work due to a mental or physical disorder, a drug addict, or a person for whom three years have not passed since the execution of a sentence for an offence relating to poisons and deleterious substances cannot be a supervisor (Article 8(2)). The handling examination has three divisions — general, agricultural items and specified items — and a person who passed the agricultural-item or specified-item examination may be a supervisor only at a store handling those items (Article 8(3) and (4)). The category handled and the supervisor's qualification must correspond.

Where and with what documents is the registration filed?

The filing is to the prefectural governor for the store's location (the mayor or ward head in cities and special wards with a public health centre). The application states the registration matters in Article 6 (the applicant's name and address, the store's location, etc.) and attaches an outline diagram of the store's equipment and documents certifying the supervisor's qualification. The forms for attachments differ by municipality, so confirm them in the competent authority's guidance.

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A registration does not last forever. Article 4(3) provides that a sales-business registration lapses unless renewed every six years (every five years for manufacturing and import businesses). Relocating the store, changing equipment, or changing the supervisor may trigger a change notification or a new registration. Confirm what counts as a notification or change procedure in the receiving authority's latest guidance.

Who handles premises, the supervisor and labour? (Separating the engagements)

Opening a poisons-and-deleterious-substances sales business combines work of different kinds — the filing, the premises, the people and the property. The basic approach is to engage a separate specialist for each.

Who to engage	Scope
四葉行政書士事務所	Preparing registration documents (assisting the applicant's own filing)
四葉不動産株式会社	Selecting the store property; preliminary checks on zoning and management rules; viewing brokerage
Architect / contractor	Designing or renovating storage equipment, partitions and locking fixtures
Pharmacists and other qualified persons	Serving as the handling supervisor and judgements on handling
Labour and social security attorney	Employment, work rules and social-insurance design for staff

四葉行政書士事務所, 四葉社会保険労務士事務所 and 四葉不動産株式会社 are each a separate, independent business. You contract with each field's provider separately as an independent business, and each provider bills and receives payment directly. Our office receives no referral fee. A handling supervisor is a post taken up by a qualified person in their own name and cannot be filled by proxy. The prefecture's or public health centre's pharmaceutical-affairs section is the administrative point of contact for registration, not a party engaged under a professional-services contract.

See permits and licensing support, the engagement process and the fee schedule. A drugstore selling drugs is a separate system — see the store-sales permit — and a dispensing pharmacy is covered in the pharmacy permit: premises and managing pharmacist. A poisons-and-deleterious-substances registration has a different governing law and categories from these.

FAQ

Q. Do I need a registration even to sell only a small amount of poisons or deleterious substances?
A. If you sell or deliver as a business, a sales-business registration is the premise regardless of quantity (Article 3(3)). You cannot sell or display without a registration. The category and procedure change with the items and the form of trade, so confirm with the pharmaceutical-affairs section.

Q. Can a non-pharmacist be the handling supervisor?
A. In some cases, yes. Besides a pharmacist, a person who completed an applied-chemistry course at a school set by ministerial ordinance, and a person who passed the handling examination, qualify (Article 8(1)). But a person who passed the agricultural-item or specified-item examination is limited to a store handling those items (Article 8(4)).

Q. How long does registration take, and what does it cost?
A. The registration fee is set by prefectural ordinance and differs by municipality. The standard processing period is shown in each municipality's review criteria. It depends on whether the premises and documents are ready. This article does not give fixed amounts or days (the variation is large and we have not verified them, so they remain unverified).

Q. Once registered, is renewal unnecessary?
A. No. A sales-business registration lapses unless renewed every six years (Article 4(3)). The timing and method of renewal are set in each municipality's guidance, so confirm them well before the deadline.

Sources (Primary Information)

• e-Gov: Poisonous and Deleterious Substances Control Act (1950 Act No. 303): Article 3(3) (prohibition on sale), Article 4 and Article 4(3) (business registration and renewal), Article 4-2 (categories), Article 4-3 (item restrictions), Article 5 (registration standard), Article 6 (registration matters), Article 7 (handling supervisor), Article 8 (supervisor qualification, disqualifications, examination divisions). Final amendment dates and full commencement histories were not obtained (unverified).
• e-Gov: enforcement regulation (1951 Ministry of Health and Welfare Ordinance No. 4): Article 4-4(1) (premises standard) and (2) (a sales-business store applies items (ii) to (iv) of paragraph (1) mutatis mutandis).
• Osaka City: guide to applying for a sales-business registration: the three categories, six-year renewal, and that the mayor is the point of contact in a public-health-centre city (referenced 2026-10-23). Fixed fees and forms vary by municipality and remain unverified.
• Okinawa Prefecture: sales-business registration: filing to the prefectural governor for each store, six-year renewal, three categories (referenced 2026-10-23).

Checked 2026-10-23. Article numbers are limited to what was reconciled with e-Gov. Final amendment dates, specific premises figures, attachment forms, and fees and standard processing periods remain unverified and should be reconfirmed in the competent authority's latest guidance before filing.

This is general information and does not guarantee the grant of an individual registration, a supervisor's eligibility, premises conformity, or processing time or cost. Judgements on handling poisons and deleterious substances are made by qualified professionals such as pharmacists, and the final decision on a registration is made by the competent authority. Written by Joji Uramatsu, administrative scrivener and licensed real-estate transaction specialist.