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Permits and Licensing (From the Practice of an Administrative Scrivener)

Collection-operator and fluorocarbons-recovery-operator registration under the End-of-Life Vehicle Recycling Act: what a used-car or repair business needs

Watercolor illustration of a scaffolded construction site, a small truck and a helmet
浦松 丈二

浦松 丈二

行政書士・宅地建物取引士(四葉行政書士事務所/四葉不動産株式会社)

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A \"collection\" business that takes in end-of-life vehicles and a \"fluorocarbons-recovery\" business that recovers fluorocarbons from car air-conditioners both require registration with the prefectural governor with jurisdiction over the business office (End-of-Life Vehicle Recycling Act Articles 42 and 53). The registration is renewed every five years; dismantling and shredding are not registration but permit (Articles 60 and 67).

In short: a "collection" business that takes in end-of-life vehicles and a "fluorocarbons-recovery" business that recovers the fluorocarbons of car air-conditioners both require registration with the prefectural governor with jurisdiction over the business office (End-of-Life Vehicle Recycling Act Articles 42 and 53). The registration is renewed every five years; dismantling and shredding are not registration but permit (Articles 60 and 67).

Information checked: 27 October 2026. This article, for businesses engaged in used-car sales, vehicle repair and dismantling and the professionals who support their start-up, focuses narrowly on the requirements and flow of collection-operator registration and fluorocarbons-recovery-operator registration under the Act on Recycling of End-of-Life Vehicles (the End-of-Life Vehicle Recycling Act). For the authorization for disassembly maintenance (specified maintenance), see the authorization application for a specified-maintenance business; for the condition of the work site (property) for dismantling and shredding, see the separate-business real-estate article property requirements for vehicle dismantling and shredding. The provisions were reconciled with e-Gov.

What businesses need collection-operator or fluorocarbons-recovery-operator registration?

The treatment of end-of-life vehicles is divided, stage by stage, by the type of operator and the procedure. The collection business is the business of first taking in an end-of-life vehicle, carried on by operators in the position of receiving the scrapped car from the user — used-car dealers, petrol stations, repair shops and the like. The fluorocarbons-recovery business is the business of recovering, from an end-of-life vehicle, the fluorocarbons used in the car air-conditioner. Both are given a role within the vehicle-recycling system, and to carry them on as a business requires registration.

Registration is needed where you do it "as a business." End-of-Life Vehicle Recycling Act Article 42(1) provides that a person who intends to carry on the collection business must obtain the registration of the prefectural governor with jurisdiction over the location of the business office, and Article 53(1) provides that a person who intends to carry on the fluorocarbons-recovery business must likewise obtain the registration of the prefectural governor. You cannot carry on the business without registration. After obtaining registration or permit, registration of the operator with the Vehicle Recycling System (the information-management centre) becomes necessary in practice (confirm the specific steps in the system guidance as of the reference date).

Type of businessWhat business it isProcedure
Collection businessTakes in end-of-life vehicles from users (dealers, repair shops, etc.)Registration (Article 42)
Fluorocarbons-recovery businessRecovers the fluorocarbons of car air-conditionersRegistration (Article 53)
Dismantling businessDismantles end-of-life vehicles and takes out parts and materialsPermit (Article 60)
Shredding businessShreds and presses dismantled vehiclesPermit (Article 67)

Who do you apply to, and where (the prefecture)?

The application goes to the prefectural governor with jurisdiction over the location of the business office. End-of-Life Vehicle Recycling Act Articles 42(1) and 53(1) each provide for the registration of "the prefectural governor with jurisdiction over the location of the business office" (in areas such as designated cities where the mayor handles the affairs, the contact may be the city). Where you place business offices in several prefectures, note that registration is required in each prefecture.

The registration is renewed every five years. End-of-Life Vehicle Recycling Act Article 42(2) provides, for collection-operator registration, that "unless it is renewed every five years, it loses effect by the passage of that period," and fluorocarbons-recovery-operator registration is likewise renewed every five years under Article 53(2). Because a missed renewal lets the registration lapse, deadline management is the key. The forms and fees for the application and attached documents, and the recovery equipment and technical ability required of a fluorocarbons-recovery operator, are set by each prefecture's practice, and the specific forms and amounts are unverified in this article. Confirm with the latest guidance of the prefecture with jurisdiction (the vehicle-recycling section).

ItemCollection businessFluorocarbons-recovery business
ProcedureRegistration (Article 42(1))Registration (Article 53(1))
Application destinationThe prefectural governor with jurisdiction over the business officeSame
ValidityRenewed every five years (Article 42(2))Renewed every five years (Article 53(2))
After registrationOperator registration with the Vehicle Recycling SystemSame

How does this differ from a dismantling- or shredding-operator permit?

Whereas the collection and fluorocarbons-recovery businesses are "registration," the dismantling and shredding businesses are "permit," a heavier procedure. End-of-Life Vehicle Recycling Act Article 60(1) provides that a person who intends to carry on the dismantling business must obtain the permit of the prefectural governor with jurisdiction over the business office, and Article 67(1) likewise provides for the permit of the prefectural governor for the shredding business. As for the validity of the permit, Articles 60(2) and 67(2) provide that it must be renewed "every period, not less than five years, set by Cabinet Order" (the specific period set by Cabinet Order is unverified in this article).

In the permit review, facilities and equipment conforming to standards for the preservation of the living environment, and the ability to carry on the business properly, are examined. Dismantling and shredding need a work site (yard), and property-side conditions — the use-zone, the impact on the neighbourhood, oil-water separation, enclosure, storage standards — are the premise of the permit. The specific conditions of the work site (property) are covered in the separate-business real-estate article property requirements for vehicle dismantling and shredding. Which stage you carry out in-house (only collection, or through dismantling and shredding) changes the procedure and property required.

CategoryProcedureBasisNature
Collection / fluorocarbons-recoveryRegistrationArticles 42, 53Registered once the requirements are met
Dismantling / shreddingPermitArticles 60, 67Permitted after a review of facilities and ability

Have a question about your situation?

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Who handles the registration, the maintenance authorization and the storage site?

Starting a vehicle-recycling business divides by procedure. Preparing and filing the documents for collection-operator and fluorocarbons-recovery-operator registration, and for dismantling- and shredding-operator permits, is within an administrative scrivener's scope (our office). A shop that carries out disassembly maintenance (renamed "specified maintenance" by the amendment in force from April 2020) separately needs the authorization of the Director-General of a District Transport Bureau under Road Transport Vehicle Act Article 78 (authorization of a specified-maintenance business), which is a transport-branch / District-Transport-Bureau procedure. Finding the property for the work site and storage is handled by a real-estate agent, and tax by a tax accountant.

Who to engageScope
四葉行政書士事務所 (Yotsuba Administrative Scrivener Office)Preparing and filing collection / fluorocarbons-recovery registration and dismantling / shredding permit documents
Transport branch / District Transport BureauAuthorization of disassembly (specified) maintenance — Road Transport Vehicle Act Article 78
四葉不動産株式会社 (Yotsuba Real Estate Co., Ltd.)Finding, sale and lease of the work-site / storage property (yard, warehouse)
Tax accountantThe business's tax (corporate tax, consumption tax, etc.)
The prefecture (vehicle-recycling section)Review and grant of the registration / permit

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.

See licensing support, the engagement process and the fee schedule.

FAQ

Q. Does a used-car dealer need registration to take in a scrapped car?
A. If you take in an end-of-life vehicle as a business, collection-operator registration is required (End-of-Life Vehicle Recycling Act Article 42(1)). The application goes to the prefectural governor with jurisdiction over the business office, and the registration is renewed every five years (paragraph 2). After registration, operator registration with the Vehicle Recycling System is also needed in practice. Confirm the specific forms and fees with the prefecture with jurisdiction.

Q. Is fluorocarbons-recovery-operator registration separate from collection-operator registration?
A. It is a separate registration. The business of recovering the fluorocarbons of car air-conditioners needs the prefectural governor's fluorocarbons-recovery-operator registration, separately from the collection business (End-of-Life Vehicle Recycling Act Article 53(1)). If you do both collection and fluorocarbons recovery, you obtain both registrations. Both are renewed every five years (Articles 42(2) and 53(2)).

Q. How do registration and permit differ?
A. The collection and fluorocarbons-recovery businesses are "registration" (Articles 42 and 53), granted once the requirements are met. The dismantling and shredding businesses are "permit" (Articles 60 and 67), after a review of facilities and ability. The permit is renewed every period, not less than five years, set by Cabinet Order (the specific Cabinet-Order period is unverified). The heavier the scope handled, the heavier the procedure.

Q. Can I also entrust the maintenance authorization (disassembly maintenance) to an administrative scrivener?
A. The authorization for disassembly maintenance (specified maintenance) is the authorization of the Director-General of a District Transport Bureau under Road Transport Vehicle Act Article 78, a transport-branch / District-Transport-Bureau procedure. It is a system separate from the registration / permit under the End-of-Life Vehicle Recycling Act, with a different office in charge. Support in preparing the documents is within an administrative scrivener's scope, but the authorization itself is issued by the transport authority. See the article on the authorization application for specified maintenance for details.

Sources (Primary Information)

  • e-Gov: Act on Recycling of End-of-Life Vehicles (2002 Act No. 87): Article 42 (collection-operator registration; paragraph 1 — the registration of the prefectural governor with jurisdiction over the business office; paragraph 2 — renewal every five years), Article 53 (fluorocarbons-recovery-operator registration; paragraph 1 — the prefectural governor's registration; paragraph 2 — renewal every five years), Article 60 (dismantling-operator permit; paragraph 2 — renewal every period, not less than five years, set by Cabinet Order), Article 67 (shredding-operator permit). Final amendment date unverified.
  • e-Gov: Road Transport Vehicle Act (1951 Act No. 185): Article 78 (authorization of a specified-maintenance business — the Director-General of a District Transport Bureau; renamed from "disassembly maintenance" to "specified maintenance" by the amendment in force from April 2020). Final amendment date unverified.
  • Guidance of each prefecture (the vehicle-recycling section) on registration / permit applications, and the operator-registration guidance of the Vehicle Recycling System (the information-management centre) (referenced 27 October 2026). The forms and fees for registration / permit applications, the equipment and technical ability required of a fluorocarbons-recovery operator, and the validity (the period set by Cabinet Order) of a dismantling / shredding permit are set by local government and Cabinet Order, and individual forms, amounts and periods are unverified in this article.

Checked 27 October 2026. The provisions were reconciled with e-Gov. The forms and fees for registration / permit applications, the equipment requirements of a fluorocarbons-recovery operator, the validity (the period set by Cabinet Order) of a dismantling / shredding permit, the specific steps for operator registration with the Vehicle Recycling System, and the final amendment dates of each law are unverified. Reconfirm with the latest guidance of the prefecture and the transport branch with jurisdiction before proceeding.

This is general information and does not guarantee whether a registration, permit or authorization will be granted, or a procedural outcome. Individual judgements are made by a qualified professional after reviewing the materials. Written by Joji Uramatsu, administrative scrivener and licensed real-estate transaction specialist.

Let's start by sorting out your situation.

Yotsuba Gyoseishoshi Office (Kohinata, Bunkyo-ku; a 5-minute walk from Myogadani Station on the Tokyo Metro Marunouchi Line) supports you from organizing the requirements through document preparation and application.

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