Selling to the EU from Japan

For most goods, yes. The EU–Japan Economic Partnership Agreement is in force and removes duty on the large majority of tariff lines. The preference still has to be claimed correctly: the product must meet its origin rule, and you need a statement on origin or a claim based on importer’s knowledge.

No. The EPA removes tariffs on most goods; that is the customs side. GPSR, CE marking, REACH and the Responsible Person apply regardless of trade agreement status. Japanese manufacturers with CE for machinery or electronics already meet those directives; the GPSR layer comes separately.

Yes, for consumer products. Your Japanese company cannot take the role; it must sit with an economic operator established inside the EU. Most Japanese exporters appoint a paid service, €200–800 per year.

Food has its own regime; hygiene, traceability, border controls, novel-food authorisations; outside this guide. But the packaging triggers EPR per member state, and certain ingredients fall under specific regulations. Check with a sector specialist before assuming it is simple.

Regulation (EU) 2023/1230 replaces the Machinery Directive 2006/42/EC and applies from 20 January 2027 (Article 54, as corrected by the corrigendum of 4 July 2023); the Directive is repealed with effect from the same date (Article 51(2)). What counts is the date the machine is placed on the EU market, not when it was designed or delivered. Machinery placed on the market before 20 January 2027 in conformity with 2006/42/EC may still be made available afterwards, and EC type-examination certificates stay valid until they expire (Article 52). Today, 2006/42/EC still applies.

Three changes matter to a Japanese builder. First, Annex I lists categories of machinery and related products that must follow one of the conformity assessment procedures of Article 25. It is not a list of 'high-risk machinery'; the Regulation does not use that term, and it covers safety components as well as machines. For the six categories in Part A, Article 25(2) leaves only EU type-examination plus module C, full quality assurance, or unit verification, and all three involve a notified body, so internal production control is not available there. For the nineteen categories in Part B, internal production control is available only where harmonised standards or common specifications covering all relevant essential health and safety requirements were applied; otherwise a notified body is needed as well (Article 25(3)). Second, software performing a safety function, and protection of that software against corruption, are treated as safety matters rather than as an IT question: the machine must be able to display that software in an easily accessible form and to collect evidence of intervention in it (Annex III, 1.1.9). Third, the instructions may be supplied digitally, on four conditions: you mark on the machine, on its packaging or in an accompanying document how to reach them; you present them so the user can print, download and save them, even when they are embedded in the machine's own software; you keep them online for the expected lifetime of the machine and in any case for at least 10 years after it is placed on the market; and you supply a paper version free of charge, within one month, to a user who asks for it at the time of purchase. For machinery intended for non-professional users, or that can foreseeably be used by them, the essential safety information must be supplied on paper regardless.

The conformity assessment itself is the manufacturer's duty, not the importer's. The mirror obligation for your EU importer is Article 13(2): before placing the machine on the market he has to verify that you carried out the right Article 25 procedure, that you drew up the technical documentation of Annex IV, Part A, and that the CE marking is affixed. Article 13(4) adds that he must check the instructions and the Article 10(7) information travel with the machine.

The obligation sits with the authorised CBAM declarant, not with you, but the data has to come from you. That declarant is the importer established in a member state; where the importer is established outside the EU it is his indirect customs representative. The definitive regime applies from 1 January 2026.

Threshold. He is exempt for as long as the net mass he imports in a calendar year, added up over iron and steel, aluminium, cement and fertilisers, does not pass 50 tonnes (Article 2a, with the figure in Annex VII, point 1). Once he passes it in a calendar year, the obligations apply to the embedded emissions of that whole year. The threshold counts per importer, not per shipment and not per supplier. It does not apply to hydrogen or to electricity (Article 2a(4)): for those he is in scope from the first consignment, however small.

Authorisation. The goods may only be released for free circulation by an authorised CBAM declarant, or by his indirect customs representative (Article 4; application under Article 5). Transitional rule: where the application is submitted by 31 March 2026, he may keep importing during 2026 for as long as the competent authority has not decided. If it is refused afterwards, a penalty follows on the emissions imported in the meantime.

Certificates. There are no CBAM certificates on sale in 2026. Sales start on 1 February 2027 (Article 20(1)). For import year 2026 the CBAM declaration is filed and the certificates are surrendered by 30 September 2027 (Article 22). The cost counts in his margin from 2026, but the cash leaves in 2027.

What he will ask you for. Which goods are in scope is decided by the CN code in Annex I: cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. For those he chooses how the embedded emissions are determined: from the actual emissions of the installation, or from default values (Article 7(2)). He is not required to ask you first, and not required to show that actual data cannot be obtained. It is a cost calculation, not a penalty. Default values are set at the average emission intensity of the exporting country, raised by a mark-up fixed in implementing acts; where reliable data for the exporting country is missing, the average emission intensity of the ten exporting countries with the highest emission intensity is used instead. Against that, only actual emissions have to be checked by an accredited verifier (Article 8(1)), so working from default values saves him that verification. Your figures are worth buying when your installation is cleaner than the country average plus mark-up by more than the verification costs; for an installation dirtier than that average, the default value can be the better deal for him.

The provider list or ask for three introductions.