Do You Need a License to Sell Pickles? How to Get the Pickle-Manufacturing License, Whose Grace Period Ended in June 2024

In short: to make pickles (asazuke, kimchi, umeboshi, takuan, etc.) sold at a farm stand, roadside station or online, you in principle need a "pickle-manufacturing business" license. This is a category newly added when licensed business categories were revised by the Act partially amending the Food Sanitation Act and other laws (Act No. 46 of 2018); it is set in Article 35, Item 29 of the Enforcement Order of the Food Sanitation Act, and the license is granted by the public health center (the prefectural governor, etc.) under Article 55 of the Act. Operators who were already in business before the Enforcement Order took effect (1 June 2021, Reiwa 3) had a three-year transitional measure, but it ended on 31 May 2024 (Reiwa 6), so from 1 June 2024 you can no longer make pickles for sale without a license. The license requires conformity to the facility standards set by prefectural ordinance (Article 54), sanitation control along HACCP (Article 51) and the placement of a food-sanitation supervisor, and a home kitchen as-is will not get a license. This article is general information and does not make the final judgment on whether a given facility meets the standards. The administrative scrivener of the Yotsuba group handles, as an independent business, support for the license-application documents and for putting a sanitation-control plan in order. The conformity review and license are for the public health center; the construction of the production room is for an architect and equipment contractor; sales tax is for a tax accountant; employees' labor matters are for a labor and social-security attorney; and finding premises is for a real-estate agent, a separate business, each contracted separately.

Why did selling pickles come to need a business license in the first place?

For a long time pickles remained subject only to a "notification" under prefectural ordinance, and in many areas no license under the Food Sanitation Act was needed. However, against the background of food poisoning caused by asazuke and the like, the 2018 reform of the Food Sanitation Act (Act No. 46 of 2018) revised licensed categories across the board, and pickle manufacturing was newly positioned as a licensed category. The basis is Article 35, Item 29 of the Enforcement Order of the Food Sanitation Act, which lists it as a category requiring a license.

Item	Content (basis)
Addition of the category	Revision of licensed categories by the Act partially amending the Food Sanitation Act and other laws (Act No. 46 of 2018)
Position	"Pickle-manufacturing business," Article 35, Item 29 of the Enforcement Order
Basis of the license	Article 55 of the Food Sanitation Act (license by the prefectural governor, etc.)
Effective date of the Enforcement Order	1 June 2021 (Reiwa 3)

Many local governments explain that pickle manufacturing includes making umeboshi, takuan, asazuke, kimchi and pickles, as well as making foods whose main ingredient is pickles; the exact scope differs by public health center. The relationship with other food-related licenses is organised in Food-manufacturing licenses and the standards for premises and equipment. Please also see our Permit and license services.

From June 2024, what happens if you sell pickles without a license?

Operators who had been making pickles before the Enforcement Order took effect (1 June 2021, Reiwa 3) were given a three-year transitional measure. That period ended on 31 May 2024 (Reiwa 6), so from 1 June 2024 you cannot make pickles for sale without a license.

Time	Treatment
In business before 1 June 2021	Needed to obtain a license by 31 May 2024 (transitional measure)
From 1 June 2024	Cannot make pickles for sale without a license; new entrants need a license before starting

Operating without a license (a violation of Article 55, paragraph 1 of the Food Sanitation Act) is subject, under Article 82 of the same Act, to imprisonment for up to two years or a fine of up to 2 million yen, and under the dual-liability provision of Article 88 a corporation may also face a fine of the same amount. Making pickles for your own consumption, or giving them away for free, usually does not amount to manufacturing or selling "as a business," but once you sell repeatedly and continuously a license is required. If you are unsure whether you fall under this, rather than assuming, confirm directly with the public health center.

How far do the facility standards for a production room (handwashing, partitioning, water supply and drainage) go?

A license is granted only once the facility conforms to the facility standards set by prefectural ordinance (Article 54 of the Food Sanitation Act; set with reference to the Ministry's standards). A home kitchen that is one space with the living quarters will, as a rule, not get a license. Typical points of confirmation are as follows, but the specific figures and specifications must always be confirmed in the ordinance and guidelines of the competent public health center.

Category	Main points of confirmation (differs by ordinance)
Partitioning	Partition the production room from living and other rooms with walls, and separate work zones
Handwashing	Provide handwashing facilities that can wash and disinfect in the production room and toilet
Water supply and drainage	Secure water (fit for drinking), appropriate drainage, and washing facilities
Structure and materials	Floors, walls and ceilings easy to clean; utensils of impermeable, easy-to-clean materials
Zones and ventilation	Changing area, storage, ventilation, lighting, and pest-control measures

Construction and interior work of the production room is a field for an architect and equipment contractor, and whether the use and equipment are possible at the stage of renting premises is a matter for real-estate confirmation. Because fixing the layout and plumbing afterwards runs up costs, it is practice to have the public health center review the drawings in a prior consultation before you secure the premises. The way of thinking about equipment for food premises is also touched on in Food-manufacturing licenses and the standards for premises and equipment.

As sanitation control along HACCP, what should a small operator record?

From 1 June 2020 (Reiwa 2), and fully in force from 1 June 2021 after the transitional period, "sanitation control along HACCP" is in principle required of all food business operators (Article 51 of the Food Sanitation Act). Pickle manufacturing is no exception. That said, small operators and the like are allowed "sanitation control incorporating the idea of HACCP" according to the characteristics of the food handled, proceeding along the sector-specific guidelines published by the Ministry of Health, Labour and Welfare.

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Category	Required efforts (Article 51 of the Food Sanitation Act)
General sanitation control	Keeping the inside and outside clean, pest control, management of water and utensils, etc.
Control of important processes	Efforts to control processes especially important to prevent hazards (washing, salt and temperature control, etc.)
Small operators and the like	Efforts according to the characteristics of the food (make a plan along the guidelines and keep records)

For a small operator, the core of "what to write" is to make a sanitation-control plan along the model in the guidelines, and to check and record daily the receipt of ingredients, the water used, handwashing, temperature control and so on. Keep the records in a form that can later explain your sanitation control. An administrative scrivener can support putting the plan and forms in order, but the final review of whether the plan conforms to the standards is done by the public health center. Confirm the latest guidelines on the Ministry's official page rather than assuming.

Where and to whom is it sure to entrust the application?

The place of application is the public health center with jurisdiction over the location of the production facility (the license of the prefectural governor, the mayor of a city with a public health center, etc.). Because the professionals involved differ, the basis is that you contract with each as an independent business, separately. The administrative scrivener of the Yotsuba group handles, as an independent business, preparing and submitting the license-application documents, support for putting a sanitation-control plan in order, and confirmation of the food-sanitation supervisor.

Who to ask	Main role
Administrative scrivener (our office)	Preparing and submitting the license-application documents; support for the sanitation-control plan
Public health center	Review of conformity to facility standards, on-site check, and the decision to license
Architect and equipment contractor	Construction of the production room, plumbing and interior work
Tax accountant	Bookkeeping of sales and purchases, and tax filing
Labor and social-security attorney	Labor and social insurance and work rules when hiring employees
Real-estate agent (our company, a separate business)	Introduction to, and contract for, premises usable for manufacturing

Whether a given facility meets the standards, and under which category to apply, is in the end the review field of the public health center; an administrative scrivener does not guarantee the license on your behalf. At the stage of finding premises usable for manufacturing, a separate-business real-estate agent can help. Please also see our Engagement Flow and Fee Schedule. You contract with each professional as an independent business, and we receive no referral fee from one another.

FAQ

Q. Can I sell umeboshi I made in my home kitchen at a roadside station?
A. If you make them for sale repeatedly and continuously, you in principle need a pickle-manufacturing license. A home kitchen that is one space with the living quarters usually does not meet the facility standards and will not get a license; you need equipment such as a production room partitioned from the living quarters. Whether you fall under this should be confirmed with the competent public health center.

Q. I have sold pickles for years. Do I still need a license now?
A. Yes. The three-year transitional measure for operators in business before the Enforcement Order took effect ended on 31 May 2024 (Reiwa 6). From 1 June 2024 you cannot make pickles for sale without a license. If you have continued without one, consult the public health center promptly.

Q. Even for a small operation, is HACCP compliance necessary?
A. Yes. However, small operators and the like are allowed "sanitation control incorporating the idea of HACCP" according to the characteristics of the food, and it suffices to make a sanitation-control plan along the Ministry's sector-specific guidelines and record daily practice (Article 51 of the Food Sanitation Act).

Q. What happens if I sell without getting a license?
A. Operating without a license violates Article 55, paragraph 1 of the Food Sanitation Act and is subject, under Article 82, to imprisonment for up to two years or a fine of up to 2 million yen. Under the dual-liability provision (Article 88), a corporation may also face a fine. The individual judgment on applicability is a field for the public health center and investigative authorities.

Sources (Primary Information)

• e-Gov Law Search / Ministry of Health, Labour and Welfare, "Food Sanitation Act", Article 51 (standard of measures operators must take: general sanitation control, and efforts to control processes especially important to prevent hazards; small operators and the like use efforts according to the characteristics of the food), Article 54 (facility standards set by prefectural ordinance), Article 55 (license by the prefectural governor, etc.), Article 82 (a violation of Article 55, paragraph 1 is imprisonment for up to two years or a fine of up to 2 million yen) and Article 88 (dual-liability provision) (accessed 2026-10-08)
• e-Gov Law Search, "Enforcement Order of the Food Sanitation Act", Article 35, Item 29 ("pickle-manufacturing business" as a category requiring a license) (accessed 2026-10-08)
• Ministry of Health, Labour and Welfare, "On the amendment of the Food Sanitation Act (review of the license system and institutionalisation of sanitation control along HACCP)" (the Act partially amending the Food Sanitation Act and other laws, Act No. 46 of 2018; newly licensed categories such as pickle manufacturing, the Enforcement Order's effective date of 1 June 2021 (Reiwa 3), the three-year transitional measure for existing operators ending on 31 May 2024 (Reiwa 6), and sanitation control along HACCP and the guidelines for small operators) (accessed 2026-10-08)

This article is general information and does not make the final judgment on whether a given facility meets the ordinance's facility standards or under which category to apply, nor does it guarantee that a license will be granted. The facility standards are set by the prefectural ordinance based on Article 54 of the Food Sanitation Act, and sanitation control along HACCP is set by Article 51. Preparing and submitting the license-application documents and support for the sanitation-control plan are handled by the administrative scrivener of the Yotsuba group as an independent business; the conformity review and license are by the public health center; construction of the production room is by an architect and equipment contractor; tax is by a tax accountant; employees' labor matters are by a labor and social-security attorney; and introduction to and contract for premises usable for manufacturing is by Yotsuba Real Estate Co., Ltd., a separate business, each contracted separately. Our office receives no referral fee. Individual judgements are made by a qualified professional and the public health center after a meeting. Written by Joji Uramatsu, administrative scrivener and licensed real estate broker.