First-Class Registration vs. Second-Class Licensing for Freight Forwarding: Which Do You Need?

Bottom line first: If you arrange transport by other carriers without owning your own trucks (forwarding), you need a procedure under Japan's Freight Forwarding Business Act. Truck-based forwarding, and sea/air/rail forwarding that does not include pickup and delivery, is covered by a "first-class freight forwarding business" registration with the Minister of Land, Infrastructure, Transport and Tourism (Art. 3(1)). By contrast, if you undertake sea, air, or rail transport together with the pickup and delivery (truck collection/delivery) before and after it as a single through service, you need a "second-class freight forwarding business" license (Art. 20). This article is general information organizing the split between first- and second-class, the financial base (net assets of 3 million yen or more), and how this differs from general trucking. Whether a registration or license is granted depends on the transport bureau's review.

What is the difference between first-class registration and second-class licensing?

A freight forwarding business arranges transport for shippers by using the transport of the carriers who actually move the goods (actual carriers), without owning the vehicles, ships, aircraft, or railcars itself. The Freight Forwarding Business Act (Act No. 82 of 1989) divides this into "first-class" and "second-class."

Category	Procedure	Business covered (summary)
First-class	Registration with the Minister (Art. 3(1))	Forwarding other than second-class. Truck forwarding, and sea/air/rail forwarding that does not include pickup and delivery
Second-class	License from the Minister (Art. 20)	Using sea, air, or rail carriers' transport and undertaking the pickup and delivery (truck collection/delivery) before and after it as a single through service

The dividing line is whether you undertake sea/air/rail transport as a through service together with pickup and delivery (Art. 2(7)(8) definitions). Arranging port-to-port container transport alone is first-class; collecting from the shipper's warehouse, shipping by sea, and delivering by truck at the destination as one service is second-class. Our office supports, within the scope of an administrative scrivener's work, confirming which category applies and preparing and filing the application. Whether it is granted depends on the transport bureau's review.

What financial base and offices does first-class registration require?

First-class registration is granted if none of the grounds for refusal in Art. 6 apply. In practice, the financial base (Art. 6(1)(vii)) and facilities (Art. 6(1)(vi)) matter most.

Item	Content (summary)
Financial base	Under Art. 8 of the Enforcement Regulations, net assets of 3 million yen or more is the benchmark. A newly formed company that has not yet closed its first fiscal year is treated as meeting this with capital of 3 million yen or more
Office	You must have the right to use it, and it must comply with the City Planning Act, Building Standards Act, and related laws
Warehouse	If you store goods, you must secure a facility suited to storage; not required if you do not store
Disqualification	You must not fall under any ground in Art. 6(1)

After registration, a registration and license tax applies (Registration and License Tax Act, Appended Table 1; confirm the amount at the time of filing). Because offices and warehouses require zoning and use-right checks first, confirm the requirements before signing a lease. For the property-side requirements, also see the requirements for transport-business offices and vehicle depots compiled by Yotsuba Real Estate, a separate entity.

What do you need for international transport or pickup/delivery under a second-class license?

A second-class license (Art. 20) is required when you combine sea, air, or rail transport with truck pickup and delivery as one through service. Many international sea and air freight forwarders obtain this license.

Item	Content (summary)
Financial base	As with first-class, net assets of 3 million yen or more is the benchmark
Pickup/delivery system	Plan the pickup/delivery area and the transport that carries it out (own trucking or entrustment to other carriers) so that transport safety is ensured
Office/warehouse	Secure the facilities needed to run the business
License / tax	A registration and license tax applies after the license (Appended Table 1; confirm the amount at the time of filing)

For international transport, additional points arise, such as how the use of foreign actual carriers is handled and the notification of international tariffs. Because the distinction from first-class is that you undertake pickup and delivery as one service, if you do the pickup and delivery with your own trucks, you must also design whether a general trucking license is needed.

How do you distinguish general trucking (green plates) from forwarding?

The required procedure changes fundamentally depending on whether you "carry with your own trucks" or "arrange other carriers' transport."

Form of business	Required procedure	Basis
Carry for hire with your own trucks (green plates)	License for general motor truck transportation	Motor Truck Transportation Business Act, Art. 3
Carry for hire with light trucks (black plates)	Notification for light motor truck transportation	Motor Truck Transportation Business Act
Arrange other carriers' transport without vehicles (truck/domestic)	First-class freight forwarding registration	Freight Forwarding Business Act, Art. 3(1)
Undertake sea/air/rail plus pickup and delivery as one service	Second-class freight forwarding license	Freight Forwarding Business Act, Art. 20

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The requirements for general trucking with your own vehicles (offices, depots, minimum number of vehicles) are covered in the license for general motor truck transportation, and the notification for light trucking (black plates) in the notification for light motor truck transportation. Whether forwarding alone suffices, or a trucking license is also needed, depends on whether you carry the goods yourself.

What is the flow from application to opening?

The flow is similar for first-class (registration) and second-class (license), but the weight of the review differs.

Stage	Content / benchmark
Preliminary check	Confirm first- or second-class, whether the financial base (net assets of 3 million yen or more) is met, and whether an office and warehouse can be secured
Filing	File with the competent regional transport bureau (some cases involving foreign vessels are handled at the ministry)
Standard processing period	Published by the bureau. Roughly 2–3 months for first-class and 3–4 months for second-class as a benchmark (absent deficiencies; confirm with the filing office)
Registration / license	Pay the registration and license tax
Opening	Complete opening procedures such as setting and notifying fares and charges, and start operations

Our office supports confirming the category and preparing and filing the application, within the scope of an administrative scrivener's work. Incorporation registration for a newly formed company is handled by a judicial scrivener, and the search for and lease of offices and warehouses by a licensed real estate broker, each contracted separately as independent business entities. Our office does not receive referral fees. See the engagement flow, the fee schedule, and the overview of our permit and application services.

FAQ

Q. Can I start the business without owning a single truck?
A. Yes. A freight forwarding business arranges transport for shippers using actual carriers' transport, without owning transport means. Truck forwarding without pickup and delivery can start with a first-class registration (Freight Forwarding Business Act, Art. 3(1)). If you carry with your own vehicles, you separately need a license such as general motor truck transportation.

Q. Should I choose first-class or second-class?
A. If you undertake sea, air, or rail transport together with pickup and delivery (collection/delivery) as one through service, second-class licensing is the basis; otherwise, first-class registration. Truck-only domestic forwarding is first-class. Because it depends on the form of your business, we recommend checking against your business plan.

Q. How much capital do I need?
A. For both first- and second-class, the financial base benchmark is net assets of 3 million yen or more (Enforcement Regulations, Art. 8). A company that has not yet closed its first fiscal year is treated as meeting this with capital of 3 million yen or more. Confirm the calculation method and documents with the filing office.

Q. What if I want to be an international freight forwarder?
A. If you combine international sea or air transport with pickup and delivery (truck collection/delivery) as one service, a second-class license is typical. If you only arrange port-to-port or airport-to-airport without pickup and delivery, it may be first-class. Because points such as international tariff notification differ from domestic-only cases, individual confirmation is needed.

Sources (primary information)

• e-Gov Law Search, "Freight Forwarding Business Act" (Act No. 82 of 1989), Arts. 2, 3(1), 6, 20 (accessed 2026-09-15)
• Freight Forwarding Business Act Enforcement Regulations, Art. 8 (financial base = net assets of 3 million yen or more) (accessed 2026-09-15)
• Ministry of Land, Infrastructure, Transport and Tourism, "Guide to Registration/Licensing of Freight Forwarding Business" (first/second split, office/warehouse/pickup-delivery requirements, benchmark processing periods) (accessed 2026-09-15)
• Registration and License Tax Act, Appended Table 1 (accessed 2026-09-15)

This article is general information and does not guarantee any individual registration/license outcome, required documents, or review period. Details of the financial-base calculation, pickup/delivery system, and standard processing periods should be confirmed with the regional transport bureau and the ministry's latest guide. Incorporation registration is handled by a judicial scrivener, and the search for and lease of offices and warehouses by Yotsuba Real Estate (a licensed real estate broker), each contracted separately as independent business entities; our office does not receive referral fees. Yotsuba Administrative Scrivener Office and Yotsuba Real Estate are separate entities. Individual judgments are made by a qualified professional after consultation. Written by Joji Uramatsu (administrative scrivener and licensed real estate transaction specialist).