Light-vehicle freight transport (black number plates): the notification, versus the general freight permit, and 2025 safety management
Delivery with a single light van (light-vehicle freight transport, the so-called black number plates) can be started by notification, not a permit. This article organises the difference from the general freight permit, the required documents and office/garage conditions, the safety-manager duty that took effect in 2025, and who to hand the property and labour matters to.
In short: delivery with a single light van (light-vehicle freight transport, the so-called black number plates) can be started by "notification," not the "permit" required for general freight motor vehicle transport. The basis is Article 2, paragraph 4 (the definition of light-vehicle freight transport) and Article 36, paragraph 1 (notification of operation) of the Motor Truck Transport Business Act. You file a light-vehicle freight transport operation notification and a business-vehicle liaison note with the Transport Branch Office with jurisdiction, and with that liaison note you register the black-number-plate vehicle at the Light Motor Vehicle Inspection Organization. From 1 April 2025, a duty to appoint a light-vehicle freight safety manager at each office was added (Article 36-2 of the same Act, Act No. 23 of 2024). This article is general information organising the difference between the notification and permit systems, the required documents and office/garage conditions, the safety-management duty that took effect in 2025, and who to hand the property and labour matters to. The acceptance of any individual notification and the required documents are a matter for the Transport Branch Office with jurisdiction and the Light Motor Vehicle Inspection Organization.
Can light-vehicle freight (black plates) be started by notification, not a permit?
Light-vehicle freight transport is defined in Article 2, paragraph 4 of the Motor Truck Transport Business Act as "the business of transporting cargo for consideration, in response to the demand of others, using automobiles (limited to light vehicles with three or more wheels and two-wheeled vehicles), other than general freight motor vehicle transport business and specified freight motor vehicle transport business." Light vans, light trucks and bike couriers fall under this.
Whereas general freight motor vehicle transport requires a "permit" under Article 3, light-vehicle freight transport can be started by "notification" under Article 36, paragraph 1. That paragraph provides that "a person intending to operate a light-vehicle freight transport business must, in accordance with the procedure prescribed by ministry ordinance, notify the Minister of Land, Infrastructure, Transport and Tourism of the name and location of the office, an overview of the business vehicles and other matters." In practice you notify the Transport Branch Office with jurisdiction.
| Item | Light-vehicle freight transport (black plates) |
|---|---|
| Type of procedure | Notification (Motor Truck Transport Business Act, Article 36, paragraph 1) |
| Vehicles used | Light vehicles with three or more wheels and two-wheeled vehicles (light vans, light trucks, motorcycles, etc.) |
| Number of business vehicles | Possible from one |
| Number plate | Business plate with yellow characters on black (the so-called black number plate) |
A notification is sufficient once accepted; it is not a scheme where the outcome is judged by an examination as with a permit. However, the form of the documents and the attachments differ by Transport Branch Office, so checking at the desk in advance helps avoid a return of the papers.
Where does it differ from general freight transport? (vehicles, operation manager, garage)
Even though both "transport cargo," general freight motor vehicle transport and light-vehicle freight transport are separate schemes with different procedures and requirements. The main differences are as follows.
| Item | General freight motor vehicle transport (green plates) | Light-vehicle freight transport (black plates) |
|---|---|---|
| Procedure | Permit (Article 3) | Notification (Article 36, paragraph 1) |
| Number of business vehicles | At least five | Possible from one |
| Operation manager | Appointment required | Appointment not required (a separate safety manager is appointed) |
| Maintenance manager | Required at a certain number of vehicles | In principle not required |
| Garage | Standards on location and size (at least 50 centimetres between vehicles, etc.) | Parking space with title to use (attachment or within a set distance is the guideline) |
| Time to start | Standard processing period roughly three to five months | Once the notification is accepted, you proceed to vehicle registration |
The permit requirements for general freight (five vehicles, an operation manager, garage size, the law examination and so on) are organised in the separate article Office and garage requirements for general freight motor vehicle transport. When starting with a single light van, first check against the business plan whether it falls under light-vehicle freight transport.
What documents are needed for the notification, and what are the office/garage conditions?
The central documents for the notification are the light-vehicle freight transport operation notification and the business-vehicle liaison note. You file the operation notification with the Transport Branch Office, and take the business-vehicle liaison note bearing its confirmation stamp to the Light Motor Vehicle Inspection Organization to register the black-number-plate vehicle (a business-use change of registration).
| Document | Content |
|---|---|
| Light-vehicle freight transport operation notification | States the name and location of the office and the number of business vehicles; filed with the Transport Branch Office |
| Notification of fares and charges | Notifies the fares and charges to be applied |
| Transport terms | Where you use the standard light-vehicle freight transport terms, you state so in the notification |
| Business-vehicle liaison note | Receives the confirmation of the Transport Branch Office and is used for vehicle registration at the Light Motor Vehicle Inspection Organization |
The office/garage conditions do not have detailed area standards as strict as general freight, but the following are guidelines.
- The office has title to use (ownership or a lease). In some cases you can make your home the office
- The garage can hold the planned business vehicles and has title to use. Attachment to the office is the principle; if separated, within a set distance (varies by area) is the guideline
- Where a leased property is used as a garage or office, you must check that the lease permits that use
The treatment of the garage/office distance and size differs by Transport Branch Office. Checking against the requirements on use and title before signing a property lease helps avoid a redo after the contract. It is more reliable to check the property-side requirements with the real-estate side.
What does the light-vehicle freight safety manager introduced in 2025 do?
Against the background of a rise in accidents involving light-vehicle freight transport, the Motor Truck Transport Business Act was amended (Act No. 23 of 2024, promulgated 15 May 2024), and the light-vehicle freight safety manager scheme began on 1 April 2025. The basis is Article 36-2 of the same Act.
| Item | Content |
|---|---|
| Duty to appoint | Appoint a light-vehicle freight safety manager at each office (Article 36-2) |
| Effective date | 1 April 2025 |
| Who is covered | Light-vehicle freight transport operators |
| Training | Complete the light-vehicle freight safety manager training before appointment; thereafter regular training every two years is required |
| Main duties | Roll call, guidance and supervision of drivers, and recording of operations, among the duties for ensuring safe operation |
| Appointment and notification | On appointment, notify the Transport Branch Office and the like |
| Transitional measure | Existing operators that filed the operation notification by 31 March 2025 may appoint by 31 March 2027 |
Breach of the duty to appoint or notify carries a penalty (a fine of up to 1 million yen). The training fee and schedule are a matter for the registered training body's guidance. A new operator completes the training, appoints the safety manager and notifies. Within the scope of administrative-scrivener work, Yotsuba Administrative Scrivener Office supports preparing the notification documents and the safety-manager appointment notification. The acceptance of any individual notification and the necessity of documents are a matter for the Transport Branch Office with jurisdiction.
Who should I consult when hiring people or leasing a property?
Light-vehicle freight transport is not completed by the notification alone; property, labour, registration and tax are involved. The roles divide as follows.
- Preparing the light-vehicle freight transport operation notification, the business-vehicle liaison note and the safety-manager appointment notification → Yotsuba Administrative Scrivener Office (administrative scrivener)
- Searching for the office and garage property, checking use and title, and the lease → Yotsuba Real Estate Co., Ltd. (licensed real estate broker)
- Where drivers are hired, enrolment in labour and social insurance, working hours (the improvement-standard notice), work rules and the Article 36 agreement → a certified social insurance labour consultant
- Registration such as company incorporation and change of officers → a judicial scrivener
- Consultation and filing for income tax, consumption tax and other tax matters → a tax accountant
Yotsuba Administrative Scrivener Office and Yotsuba Real Estate Co., Ltd. are separate businesses. Each field is on the premise that you contract separately with each qualified professional as an independent business, and our office receives no referral fee. For the flow of engagement, see Engagement Flow; for fees, see Fee Schedule; and for the whole picture, see Permits and Applications. For the property-side requirements of the office and garage, also see Property requirements for a transport office and garage, compiled by Yotsuba Real Estate Co., Ltd., a separate business.
FAQ
Q. Can I file the notification with just one light van?
A. Light-vehicle freight transport can be started with one business vehicle. There is no minimum-five-vehicle requirement as in general freight motor vehicle transport. Whether it is a business plan falling under the notification (Article 36, paragraph 1 of the Motor Truck Transport Business Act) depends on the vehicles used and the content of the transport. The acceptance of any individual notification is a matter for the Transport Branch Office with jurisdiction.
Q. Where do I get the black number plate?
A. First file the light-vehicle freight transport operation notification with the Transport Branch Office, then take the business-vehicle liaison note bearing its confirmation stamp to the Light Motor Vehicle Inspection Organization to register the business-use (black-plate) vehicle. The notification and the vehicle registration are at separate desks, so proceed in the right order.
Q. Must I appoint the safety manager introduced in 2025?
A. From 1 April 2025, light-vehicle freight transport operators must appoint a light-vehicle freight safety manager at each office (Article 36-2 of the Motor Truck Transport Business Act). A new operator completes the training and then appoints and notifies. Existing operators that filed by 31 March 2025 have a transitional measure allowing appointment by 31 March 2027.
Q. How do I choose between this and general freight (green plates)?
A. If you transport with light vehicles of three or more wheels or two-wheeled vehicles, it is light-vehicle freight transport (notification, black plates); if you transport with ordinary vehicles or small trucks, it is general freight motor vehicle transport (permit, green plates, at least five vehicles and an operation manager). Which applies depends on the vehicles used and the business plan. For details of the permit system, see Office and garage requirements for general freight motor vehicle transport.
Sources (Primary Information)
- e-Gov Law Search, "Motor Truck Transport Business Act" (Act No. 83 of 1989), Article 2, paragraph 4; Article 3; Article 36, paragraph 1; and Article 36-2 (accessed 2026-08-30)
- Ministry of Land, Infrastructure, Transport and Tourism, "We have made an institutional reform to strengthen safety measures in the light-vehicle freight transport business" (Act No. 23 of 2024, promulgated 15 May 2024, appointment of the light-vehicle freight safety manager, effective 1 April 2025, transitional measure until 31 March 2027 for existing operators) (accessed 2026-08-30)
- Ministry of Land, Infrastructure, Transport and Tourism and the Transport Branch Offices, forms and procedures for the "light-vehicle freight transport operation notification" and "business-vehicle liaison note" (office, garage and vehicle registration) (accessed 2026-08-30)
- Light Motor Vehicle Inspection Organization, "Procedures for business use (black number plates)" (accessed 2026-08-30)
This article is general information and does not guarantee the acceptance of any individual notification, the required documents or the treatment of the garage or office. The notification forms, the guideline for the garage distance, and the schedule and fee of the safety-manager training differ by Transport Branch Office, registered training body and Light Motor Vehicle Inspection Organization, so check the latest guidance of the authority to which you apply. Searching for and leasing the office and garage property is handled by Yotsuba Real Estate Co., Ltd. (licensed real estate broker); drivers' labour and social insurance by a certified social insurance labour consultant; registration such as company incorporation and change of officers by a judicial scrivener; and tax matters by a tax accountant, each as an independent business under a separate contract. Our office receives no referral fee. Individual judgements are made by a qualified professional after a meeting. Written by Joji Uramatsu, administrative scrivener and licensed real estate broker.
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