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Licensing Procedures (From the Practice of an Administrative Scrivener)

Retail tobacco sales licence: the distance standard, the expected-volume standard, and the flow of application

Watercolor illustration of a stack of application forms on a service counter
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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To sell manufactured tobacco at retail as a business in Japan, you need a licence from the Minister of Finance for each place of business (Article 22, paragraph 1 of the Tobacco Business Act). The review centres on the location of the place of business (distance from the nearest existing shop) and the expected volume of tobacco handled. This article organises the requirements and the flow.

In short: to sell manufactured tobacco at retail as a business, you need a licence from the Minister of Finance for each place of business (Article 22, paragraph 1 of the Tobacco Business Act). The review centres on the location of the place of business (the distance from the nearest existing shop = the distance standard) and the expected volume of manufactured tobacco handled (the expected-volume standard) (Article 23 of the same Act). The application is submitted to the branch of Japan Tobacco Inc. (JT) nearest the planned place of business, and the standard processing period is within two months from the last day of the month in which the application is accepted. This article is general information organising the requirements and the flow; it does not judge whether a specific licence will be granted.

Who grants the retail tobacco sales licence, and what is reviewed?

Anyone who intends to sell manufactured tobacco (such as cigarettes and heated tobacco) at retail as a business must obtain a licence from the Minister of Finance for each place of business where the tobacco is sold at retail (Article 22, paragraph 1 of the Tobacco Business Act). The counter for consultation is the Local Finance Bureau (or branch) with jurisdiction over the planned place of business, and the application is submitted to the branch of Japan Tobacco Inc. (JT) nearest the planned place of business (guidance of the Ministry of Finance, accessed 2026-10-30).

The review takes the form of checking whether the case falls under the "grounds on which the licence may be refused" set out in Article 23 of the Tobacco Business Act. The main points are as follows.

PointOrganisation in the provisions
Location (distance standard)Whether the location does not fall under a case prescribed by Ministry of Finance ordinance as unsuitable for conducting retail sales as a business (Article 23, item 3 of the Tobacco Business Act; Article 20 of the Enforcement Regulation)
Expected volume (volume standard)Whether the expected volume of manufactured tobacco handled reaches the standard prescribed by Ministry of Finance ordinance (Article 23 of the Tobacco Business Act; Article 21 of the Enforcement Regulation)
Grounds of personal disqualificationSuch as having been sentenced to a fine or heavier for violating the Tobacco Business Act without a set period having passed, or having had a licence revoked in the past without a set period having passed (Article 23 of the same Act)

Conditions or a time limit may be attached to the licence (Article 24 of the same Act), and even after the licence, certain violations may lead to revocation of the licence or suspension of business (Article 31 of the same Act). The final application of which standard fits is judged by the Local Finance Bureau with jurisdiction after its review.

What exactly do the "distance standard" and the "expected-volume standard" look at?

The distance standard looks at the distance between the planned place of business and the place of business of the nearest existing retail seller. Article 20 of the Enforcement Regulation of the Tobacco Business Act sets, as one of the cases in which the location is unsuitable, the case where that distance does not reach "the distance determined by the Minister of Finance within the range of 25 metres to 300 metres." The actual standard distance for each category is in a notification of the Minister of Finance (an appended table), and it is determined by a combination of the area category (designated city, city-system area, town-and-village-system area, and the like) and the environment category (downtown, urban area, residential area, and the like); the distance is measured along the road on which people and vehicles ordinarily pass. Because categories are applied and exceptions exist, confirm the specific standard distance with the Local Finance Bureau and JT branch with jurisdiction.

The expected-volume standard looks at the expected volume of manufactured tobacco handled at that place of business. Article 21 of the Enforcement Regulation sets its standard at "40,000 units per month" (except where the Minister of Finance determines otherwise). The expected volume is calculated from such factors as the number of households in the area where supply is expected or the number of users of a facility, and if it is not expected to reach the standard it may become a ground for refusal.

StandardBasisWhat is looked at
Distance standardArticle 23, item 3 of the Tobacco Business Act; Article 20 of the Enforcement RegulationDistance from the nearest existing place of business (whether it reaches the distance determined by the Minister of Finance within the range of 25 to 300 metres)
Expected-volume standardArticle 23 of the Tobacco Business Act; Article 21 of the Enforcement RegulationThe expected volume handled (the standard is 40,000 units per month)

Both the distance and the expected volume can change the conclusion through the application of categories and exceptions. This article stays with information on the framework of the system and does not apply any specific figure.

How does the licence change for vending machines or a convenience-store combination?

When you sell tobacco over the counter of a convenience store or an individual shop, a licence is still needed for each place of business. Because opening a new shop near an existing shop readily hits the distance standard, confirming this before deciding the location is the key.

When you place a vending machine, the principle is to install it at the licensed place of business, and the application requires a drawing that clearly shows the positional relationship between the vending machine and the shop. When a vending machine is installed at a place operated or managed by someone other than the licence applicant, a written pledge concerning the prevention of smoking by persons under the age of twenty is required (guidance of the Ministry of Finance, accessed 2026-10-30). When you conduct mail-order sales via the internet or the like, a separate attachment of licence conditions is required.

The category of selling within a facility such as a theatre, inn, restaurant, or large store to the users of that facility (specific retail sales business) is treated differently from general retail sales as to the application of distance under Article 20 of the Enforcement Regulation. Because the required documents and the viewpoint of the review change depending on which category applies, it is safer to confirm with the Local Finance Bureau and JT branch with jurisdiction once the form of the shop is decided.

How long does it take for the licence to be granted, and what documents are needed?

The standard processing period is within two months from the last day of the month in which the application is accepted (guidance of the Ministry of Finance, accessed 2026-10-30). If there is correction of documents or the like, it may take further days. When the licence is granted, payment of a registration and licence tax (15,000 yen) is required.

ItemContent
Submission destinationThe branch of Japan Tobacco Inc. (JT) nearest the planned place of business
Consultation counterThe Local Finance Bureau (or branch) with jurisdiction over the planned place of business
Standard processing periodWithin two months from the last day of the month in which the application is accepted
Cost after the licenceRegistration and licence tax of 15,000 yen

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The required documents are the licence application, plus a location map and floor plan of the place of business, and, where a vending machine is placed, a drawing showing its position. Because additional documents are required depending on the category and the form of the shop, the Ministry of Finance advises that you first consult the JT branch nearest the planned shop about how to fill in the application. Confirm the latest required documents and the standard distance for each category with the Local Finance Bureau and JT branch with jurisdiction immediately before you act.

Whom should you consult about the shop premises and company formation?

A retail tobacco sales licence proceeds in parallel with other procedures such as premises, interior work, registration, and tax. The roles are divided as follows.

  • The retail tobacco sales licence application (preparing the application and drawings, supporting exchanges with the Local Finance Bureau and JT) → Yotsuba Administrative Scrivener Office (administrative scrivener). We provide materials and information only and do not make specific legal judgements
  • Selection of the shop premises and brokerage of the lease → Yotsuba Real Estate Co., Ltd. (licensed real estate broker), a separate business. It handles this under a separate contract as an independent business
  • Interior design of the shop and work requiring a building confirmation → an architect and contractor
  • Formation registration where you set up a company to operate → a judicial scrivener
  • Bookkeeping and tax filing after opening → a tax accountant
  • Procedures for labour and social insurance when you hire employees → a labour and social security attorney

Consultation on the shop premises is handled by Yotsuba Real Estate Co., Ltd., a separate business from Yotsuba Administrative Scrivener Office, under a separate contract as an independent business. Formation registration is for a judicial scrivener, tax for a tax accountant, and labour for a labour and social security attorney, each contracting separately as an independent business. Each field is on the premise that you contract separately with each counter or qualified professional, and our office receives no referral fee. Even at a stage when you are unsure whether a licence is needed or how the distance standard will come out, consult us before you decide the location. For the flow of engagement, see Engagement Flow; for fees, see Fee Schedule; and for the scope of work, see Scope of Services. For related licences, see also Shop and premises requirements for a retail liquor sales licence, Equipment standards for a restaurant business permit, and Notification for a late-night liquor-serving restaurant business.

FAQ

Q. Whose licence do I need to sell tobacco at retail?
A. To sell manufactured tobacco at retail as a business, you need a licence from the Minister of Finance for each place of business (Article 22, paragraph 1 of the Tobacco Business Act). The application is submitted to the branch of Japan Tobacco Inc. (JT) nearest the planned place of business, and consultation on the licence is received at the Local Finance Bureau (or branch) with jurisdiction over the planned place of business. A licence per place of business is needed whether it is a convenience-store combination or an individual shop.

Q. Will the licence be refused if there is another tobacco shop nearby?
A. There is a distance standard: if the distance between the planned place of business and the nearest existing place of business does not reach the distance determined by the Minister of Finance within the range of 25 metres to 300 metres, the location may become a ground for refusal as unsuitable (Article 23, item 3 of the Tobacco Business Act; Article 20 of the Enforcement Regulation). Because the standard distance for each category and exceptions exist, confirm with the Local Finance Bureau and JT branch with jurisdiction before deciding the location.

Q. How many units is the "standard" of the expected-volume standard?
A. Article 21 of the Enforcement Regulation of the Tobacco Business Act sets the standard of the expected volume handled at 40,000 units per month (except where the Minister of Finance determines otherwise). The expected volume is calculated from such factors as the number of households in the area where supply is expected or the number of users of a facility, and if it is not expected to reach the standard it may become a ground for refusal. The specific calculation is confirmed with the Local Finance Bureau and JT branch with jurisdiction.

Q. How long does it take for the licence to come down?
A. The standard processing period is within two months from the last day of the month in which the application is accepted (guidance of the Ministry of Finance, accessed 2026-10-30). If there is correction of documents or the like, it may take further days. When the licence is granted, payment of a registration and licence tax of 15,000 yen is required. Confirm the latest period and required documents with the Local Finance Bureau and JT branch with jurisdiction immediately before you act.

Sources (Primary Information)

  • e-Gov Law Search, "Tobacco Business Act" (Act No. 68 of 1984), Article 22, paragraph 1 (retail sales business licence; the Minister of Finance's licence), Article 23 (standards for the licence = grounds for refusal; the location of the place of business, the expected volume handled, personal disqualification), Article 24 (conditions of the licence), and Article 31 (revocation of the licence, etc.) (accessed 2026-10-30)
  • e-Gov Law Search, "Enforcement Regulation of the Tobacco Business Act" (Ministry of Finance Ordinance No. 5 of 1985), Article 20 (cases where the location of the place of business is unsuitable = the distance from the nearest place of business does not reach the distance determined by the Minister of Finance within the range of 25 metres to 300 metres) and Article 21 (the standard of the expected volume handled = 40,000 units per month) (accessed 2026-10-30)
  • Ministry of Finance, "Licence for the Retail Sales Business of Manufactured Tobacco" (the consultation counter = the Local Finance Bureau or branch; the submission destination of the application = the nearest JT branch; the standard processing period = within two months from the last day of the month in which the application is accepted; registration and licence tax of 15,000 yen; drawing of the vending machine and the written pledge on preventing smoking by persons under twenty; licence conditions for mail-order sales) (accessed 2026-10-30)

This article is general information and does not guarantee or judge whether a specific licence will be granted, the standard distance for each category, the result of calculating the expected volume, or the sufficiency of the required documents. Because the application of categories and exceptions differs by case and notifications and the handling guidelines are amended, always confirm with the latest provisions and notifications and the guidance of the Local Finance Bureau and JT branch with jurisdiction. Selection and brokerage of the shop premises are for Yotsuba Real Estate Co., Ltd. (licensed real estate broker), a separate business, formation registration for a judicial scrivener, tax for a tax accountant, and labour for a labour and social security attorney, each as an independent business under separate contracts and procedures. Our office receives no referral fee. Specific legal judgements are made by a qualified professional such as an administrative scrivener after a meeting. Written by Joji Uramatsu, administrative scrivener and licensed real estate broker.

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