A Certificate of Free Sale (CFS) is one of the most commonly requested documents when a Japan-made supplement crosses a border, and one of the most misunderstood: it says nothing about the safety of a specific batch, only that the product is a legitimate, freely sold Japanese food.
This guide explains what Japan’s CFS actually certifies, who issues it today, the conditions a product must meet, which importing markets typically ask for it, and what legalisation involves once you have one.
💬 Planning to export a Japan-made supplement and need to know whether a Certificate of Free Sale applies to your case? See Japan-made supplement OEM.
What a Japanese Certificate of Free Sale certifies
A Japanese CFS confirms that a food was manufactured or processed in Japan and is sold, or can lawfully be sold, within Japan — it does not certify the safety of the individual shipment.
Japan’s official CFS issuance guideline states its purpose plainly: the certificate is a document for submission to an importing country’s customs authorities to show that the product is a food manufactured in Japan that can circulate in the domestic market without problem — and explicitly that it is not a certificate of safety for that specific export consignment.
To qualify, a food must meet all of the following:
| Condition | What it means |
|---|---|
| Manufactured or processed in Japan | The product must genuinely be made domestically, not merely repackaged there |
| Sold, or capable of being sold, in Japan | The product (or one substantively the same) is on the Japanese market, or legally could be |
| Manufacturer in good standing | The manufacturer has not been subject to an improvement order, licence revocation or business suspension under the Food Sanitation Act and related rules (unless the issue has since been resolved) |
| Handled properly since leaving the manufacturer | The product has not been opened or mishandled after shipment, and any expiry date allows for realistic consumption after export |
An export-only product that has no equivalent ever sold domestically in Japan can complicate this: the exporter must be able to show the manufacturer’s domestic track record and explain any difference between the export version and a domestically sold equivalent.
Who issues it, and how the process works
Certificates of Free Sale for exported food, including health foods and supplements, are issued by the Ministry of Agriculture, Forestry and Fisheries (MAFF) through its regional agricultural administration bureaus — a role transferred from the Ministry of Health, Labour and Welfare’s Regional Bureaus of Health and Welfare on 1 April 2020.
Before that date, an exporter applied to the food sanitation division of the MHLW Regional Bureau of Health and Welfare covering the exporter’s address. Since the Act on Promotion of Export of Agricultural, Forestry and Fisheries Products and Food took effect on 1 April 2020, the application point for a food CFS moved to the relevant regional agricultural administration bureau (or the Hokkaido agricultural office or the Okinawa General Bureau’s agriculture, forestry and fisheries department, depending on the exporter’s location), applied for through a dedicated online export-certificate system or Japan’s customs-related NACCS system. MAFF’s own guidance notes that health-food and supplement applications in particular draw frequent corrections, since labels and formulas in this category are more often incomplete or inconsistent on first submission than for simpler food categories.
| Step | What it involves |
|---|---|
| Manufacturer registration | The manufacturing or processing facility is registered in the relevant online system before a certificate application can be made |
| Application | The exporter applies through the regional agricultural bureau covering their address, submitting evidence of the product’s manufacture in Japan and its domestic sale (or saleability) |
| Supporting documents | Typically include the business licence, invoice, packing list, product packaging, and documents evidencing the product’s supply chain |
| Issuance | The certificate is issued once the application and conditions are confirmed; it can be collected at various offices or posted |
A separate certificate — a health or sanitary certificate for a specific product category — may still sit with a different authority in narrower cases; a CFS is the general-purpose “freely sold in Japan” document, not a substitute for a category-specific certificate if an importing country asks for one by name.
💬 Not sure whether your target market asks for a Certificate of Free Sale, a sanitary certificate, or something else? Tell us the country and product and we will help you work out which document applies.
Which importing markets ask for it
Whether an importing country requires a CFS depends on that country’s own import or product-registration rules, not on a fixed Japanese list — but it is a routine request for health foods and supplements across much of Asia, the Middle East and elsewhere.
A CFS is not a document Japan volunteers automatically; it exists because a given importing country’s customs or health-registration authority asks for it as part of clearing the product or registering it for sale. Many of the countries that commonly import Japan-made supplements include a CFS, or an equivalent free-sale document, among the papers a local importer or licence holder must submit when registering a product — but the exact requirement, and who must hold the licence, is set by that country’s own regulator, not by Japan. A brand should confirm the requirement with the destination country’s own import rules or with its local importer, rather than assume a CFS is always needed or always sufficient on its own.
Legalisation: apostille or consular authentication
A CFS issued in Japan is a public document, so many importing countries also require it to be legalised before their authorities will accept it — either by apostille or by consular authentication, depending on whether the destination country belongs to the Hague Apostille Convention.
Japan is a party to the Hague Apostille Convention, so a public document such as a CFS destined for another convention member country can carry an apostille issued by Japan’s Ministry of Foreign Affairs, which stands in for consular legalisation between convention members. For a destination country that is not a convention member, the document instead needs full consular legalisation: authentication by Japan’s Ministry of Foreign Affairs followed by the destination country’s embassy or consulate in Japan. Which route applies, and whether it is required at all, depends entirely on the destination country and its own import authority’s requirements — confirm this with your importer or the destination country’s regulator before assuming either path applies.
Before you ask for a quotation
Confirm the document itself, and its onward legalisation, before it becomes a bottleneck at export time.
- Whether your destination country’s import or product-registration rules actually require a Certificate of Free Sale, and for which product
- Whether the product you plan to export has a domestically sold equivalent in Japan, or is export-only
- Who will apply for the certificate — you, your Japanese manufacturing partner, or a customs broker — and to which regional agricultural bureau
- Whether the destination country requires apostille or consular legalisation on top of the certificate itself
- Lead time for both the certificate and any legalisation step, planned against your shipment date
💬 Ready to plan the export documents for a Japan-made supplement? Send us your target country and product and we will map out what is needed.
Frequently asked questions
1. Does a Certificate of Free Sale prove my specific shipment is safe?
No. Japan’s own CFS guideline states explicitly that the certificate does not certify the safety of an individual export shipment; it confirms the product is manufactured in Japan and is sold, or saleable, domestically.
2. Who issues a Japanese Certificate of Free Sale today?
For food, including health foods and supplements, it is the Ministry of Agriculture, Forestry and Fisheries, through its regional agricultural administration bureaus, following a transfer of this function from the Ministry of Health, Labour and Welfare’s Regional Bureaus of Health and Welfare on 1 April 2020.
3. Can I get a Certificate of Free Sale for a product that has never been sold in Japan?
It is harder, but not automatically impossible — the exporter needs to show the manufacturer’s genuine domestic manufacturing and, where the export product differs from anything sold domestically, explain that difference and why it does not raise a food-safety issue under Japanese law.
4. Does every country I export to require this certificate?
No. It depends on that country’s own import or registration rules. Many markets that commonly import Japan-made supplements do ask for it, but confirm with the destination country’s regulator or your local importer rather than assuming.
5. Do I always need an apostille on a Japanese Certificate of Free Sale?
Only if the destination country requires it and is a member of the Hague Apostille Convention; otherwise, full consular legalisation through Japan’s Ministry of Foreign Affairs and the destination country’s embassy or consulate may be needed instead — confirm which applies with your importer or the destination country’s regulator.
Sources: Ministry of Health, Labour and Welfare, “自由販売証明書発行要領” (Certificate of Free Sale issuance guideline) (mhlw.go.jp/file/06-Seisakujouhou-11130500-Shokuhinanzenbu/betten.pdf and kouseikyoku.mhlw.go.jp/kantoshinetsu/shokuhin/documents/170713_youryou_attachment_cfs.pdf), setting out purpose, scope and the five issuance conditions; Ministry of Agriculture, Forestry and Fisheries, “輸出食品に関する自由販売証明書の発行申請について” (maff.go.jp/j/shokusan/hq/i-4/jiyuhanbai-hakkoushinsei.html); MAFF notice on the 1 April 2020 transfer of food Certificate of Free Sale applications from MHLW Regional Bureaus of Health and Welfare to MAFF regional agricultural bureaus under the Act on Promotion of Export of Agricultural, Forestry and Fisheries Products and Food (mhlw.go.jp/content/11130500/000595369.pdf); Ministry of Foreign Affairs of Japan, guidance on apostille and consular legalisation for public documents and Japan’s status as a Hague Apostille Convention member (mofa.go.jp/mofaj/toko/page22_000553.html). Checked on 25 September 2026.