Warehouse-business registration: what property requirements must you meet?

In short: to run a "commercial warehouse" that stores another party's goods for a fee as a business, you need registration by the Minister of Land, Infrastructure, Transport and Tourism under Article 3 of the Warehouse Business Act (Act No. 121 of 1956; hereafter the "Warehouse Business Act"). Whether you can register turns on whether the target property meets the facility standards set for each type of warehouse (Class 1, 2 and 3, open-yard, storage-tank, dangerous-goods, refrigerated, water-surface and trunk-room), according to the goods you store. These standards rest on Article 6, paragraph 1, item 4 of the Warehouse Business Act, with the details placed in Article 3-4 of the Regulation for Enforcement of the Warehouse Business Act. You must also appoint a warehouse management supervisor for each warehouse (Article 11). This article is general information organising whether registration is required, the facility standards, the supervisor and the division of roles; it does not judge whether any individual property meets the registration standards.

When does storage require warehouse-business registration?

A warehouse business means the business of storing, in a warehouse, goods received on deposit, and to run it you must obtain registration from the Minister of Land, Infrastructure, Transport and Tourism (in practice, through each District Transport Bureau) under Article 3 of the Warehouse Business Act. Operating without registration carries penalties. The dividing line is "whether you receive another party's goods for a fee and bear responsibility for their safekeeping."

Category	Registration	Example
Commercial warehouse (storage on deposit)	Required	Receiving and storing goods for a fee from a shipper
Own-use warehouse (storing your own goods)	Not required	Storing your own products or materials in your own warehouse
Leasing space (rental warehouse, rental container, etc.)	Often not a warehouse business	Merely lending space without bearing safekeeping responsibility for deposited goods

Whether you re-register an existing warehouse as a commercial warehouse or start a new one, the framework of the procedure is the same. When converting an existing warehouse into a commercial warehouse, the key is to confirm before contract or construction whether the building meets the facility standards below and whether it can be used as a commercial warehouse in terms of zoning and the Building Standards Act and Fire Service Act. Within the scope of administrative-scrivener work, Yotsuba Administrative Scrivener Office supports confirming whether registration is required, organising the requirements, preparing the application documents (the registration application under Article 4) and acting as agent. The outcome of any individual registration is a matter for the District Transport Bureau's examination.

How do the facility standards change by type of warehouse?

The facility standards for a commercial warehouse rest on Article 6, paragraph 1, item 4 of the Warehouse Business Act (registration is refused if a property does not meet them), with the details set in Article 3-4 of the Regulation for Enforcement of the Warehouse Business Act. Which goods may be stored in which warehouse is organised in Articles 3-3 to 3-11 and an appended table of the same regulation, and the standards required change with the type of warehouse.

Type of warehouse	Example of goods stored	Tendency of the standards
Class 1 warehouse	A wide range of general cargo	The broadest set of items: right of use, conformity with related laws, fixity to the land, strength of the frame, outer walls and floor, waterproofing, moisture-proofing, heat-shielding, fire resistance or fire prevention, fire extinguishers, crime prevention, rodent prevention, lighting, etc.
Class 2 and 3 warehouses	Less-flammable or lower-risk goods	Part of the Class 1 items (such as fire resistance/prevention and moisture-proofing) is relaxed
Open-yard warehouse	Minerals, timber, vehicles and other goods that withstand outdoor storage	Surrounding walls or fences, lighting, drainage
Storage-tank warehouse (silo, tank)	Bulk grain, liquids, etc.	Structure and airtightness of the tank
Dangerous-goods warehouse	Hazardous materials and high-pressure gas under the Fire Service Act, etc.	Standards on top of conformity with separate regulations such as the Fire Service Act and Building Standards Act
Refrigerated warehouse	Perishables and frozen goods stored at 10 degrees or below	Structure and equipment that keep a set temperature

Thus, even in the same building, the type and standards required change with "what you store." Because meeting the standards concerns the building's structure and its fire, water and other performance, design and the building-confirmation application are the domain of an architect and a designated confirmation and inspection body, and fire-fighting equipment and the handling of dangerous goods are the domain of the fire department and fire-equipment engineers. Yotsuba Real Estate Co., Ltd., a separate business from Yotsuba Administrative Scrivener Office, handles the zoning check, selection and lease of candidate properties usable as a commercial warehouse under a separate contract as an independent business. Our office receives no referral fee.

Who can be appointed as the warehouse management supervisor?

Under Article 11 of the Warehouse Business Act, a warehouse operator must appoint a warehouse management supervisor for each warehouse and have the warehouse management conducted properly. Who can be appointed is set by the requirements in Article 9 of the Regulation for Enforcement of the Warehouse Business Act.

Eligible person (any one)	Content
Practical experience (supervisory)	A person with two or more years of supervisory practical experience in warehouse management
Practical experience	A person with three or more years of practical experience in warehouse management
Completion of a course	A person who has completed the course on warehouse management designated by the Minister of Land, Infrastructure, Transport and Tourism

The practical experience here means experience in a commercial warehouse; experience in an own-use warehouse is not counted. A warehouse management supervisor is in principle appointed for each warehouse, but for warehouses on the same site that are regarded as functionally integrated, or for several warehouses directly managed and supervised by the same business office or other establishment, the same person may be appointed. If there is no one in the company who meets the requirements, there is a way to meet them by completing the course. Check the latest guidance of the running body for the course schedule and its handling.

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How do you divide property selection and the registration application among professionals?

Launching a commercial warehouse involves separate fields: the property, the building, registration, incorporation, tax and labour affairs. The roles are as follows.

• Confirming whether registration is required, organising requirements, preparing the registration documents and acting as agent → Yotsuba Administrative Scrivener Office (administrative scrivener)
• Zoning check, selection and lease of candidate properties that may meet the facility standards → Yotsuba Real Estate Co., Ltd. (licensed real estate broker)
• Structural design of the building, the building-confirmation application and confirmation of a change of use → an architect and a designated confirmation and inspection body
• Confirmation of fire matters such as fire-fighting equipment and the handling of dangerous goods → the fire department and fire-equipment engineers
• Registration such as company incorporation and change of officers → a judicial scrivener
• Tax on capital investment, depreciation and consumption tax → a certified public tax accountant
• Employees' labour insurance and work rules → a certified social insurance labour consultant

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 of our services, see Permits and Applications.

FAQ

Q. Do I need registration even for a warehouse that only stores my own products?
A. In principle, no. Warehouse-business registration is required for a commercial warehouse that receives and stores another party's goods on deposit (Article 3). An own-use warehouse, where you store your own products or materials in your own warehouse, is not a warehouse business. However, if you come to receive goods from another company for a fee, it may amount to a commercial warehouse, so it is judged by the substance of the business.

Q. Is registration required for a business that lends rental warehouses or rental space?
A. A lease that merely lends space without bearing safekeeping responsibility for deposited goods is often not a warehouse business. On the other hand, if there is substance of receiving goods and bearing responsibility for their safekeeping, it may amount to a commercial warehouse. Because it is judged by the contract and the substance of safekeeping rather than the name, confirm with the District Transport Bureau in advance where the line is subtle.

Q. Can I register an existing building as a commercial warehouse?
A. You can register it if that building meets the facility standards for the type of warehouse matching the goods you store (Article 6, paragraph 1, item 4, and Article 3-4 of the Enforcement Regulation). The key is to confirm, before contract or renovation, its fire, water, moisture and fire-resistance performance and its relation to zoning, the Building Standards Act and the Fire Service Act. Whether it conforms is a matter for the examination.

Q. Can the warehouse management supervisor be an outside person?
A. Anyone who meets the requirements of Article 9 of the Enforcement Regulation (two or more years of supervisory practical experience, three or more years of practical experience, or completion of the course designated by the Minister of Land, Infrastructure, Transport and Tourism) can be appointed. If no one in the company meets the requirements, there is a way to meet them by completing the course. Practical experience in a commercial warehouse is what counts; experience in an own-use warehouse is not included.

Sources (Primary Information)

• e-Gov Law Search, "Warehouse Business Act" (Act No. 121 of 1956), Article 3 (registration), Article 4 (application for registration), Article 6, paragraph 1, item 4 (conformity with the facility standards), Article 11 (warehouse management supervisor) (accessed 2026-09-22)
• e-Gov Law Search, "Regulation for Enforcement of the Warehouse Business Act" (Ministry of Transport Ordinance No. 59 of 1956), Articles 3-3 to 3-11 and the appended table (types of goods and warehouses that may store them), Article 3-4 (details of the facility standards), Article 9 (requirements for the warehouse management supervisor) (accessed 2026-09-22)
• Ministry of Land, Infrastructure, Transport and Tourism, "Warehouse Business Act" (overview of the registration system, types of warehouse and the warehouse management supervisor) (accessed 2026-09-22)
• Ministry of Land, Infrastructure, Transport and Tourism, "Facility standards for commercial warehouses (Article 6, paragraph 1, item 4 of the Warehouse Business Act)" (list of standard items by type of warehouse) (accessed 2026-09-22)
• Ministry of Land, Infrastructure, Transport and Tourism, "Warehouse Management Supervisor Manual" (requirements under Article 9 of the Enforcement Regulation and the approach to appointment) (accessed 2026-09-22)

This article is general information and does not guarantee whether any individual property meets the facility standards, the outcome of registration, the applicable type of warehouse, or the examination period. The outcome and examination of registration are matters for the District Transport Bureau. The zoning check, selection and lease of candidate properties are handled by Yotsuba Real Estate Co., Ltd. (licensed real estate broker); the structural design, building-confirmation application and confirmation of a change of use by an architect and a designated confirmation and inspection body; fire-fighting equipment and the handling of dangerous goods by the fire department and fire-equipment engineers; registration such as company incorporation and change of officers by a judicial scrivener; tax such as capital investment and consumption tax by a certified public tax accountant; and employees' labour affairs by a certified social insurance labour consultant, 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.