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# Japan's Resource Recycling Act: Design and Marking Obligations for Electronics Makers

Japan has one of the world's most developed product lifecycle and recycling regulatory frameworks. The Act on the Promotion of Effective Utilization of Resources (資源の有効な利用の促進に関する法律, AURRA) — Act No. 48 of 1991, substantially revised in 2000 and 2013 — establishes obligations for manufacturers and importers of covered product categories to implement the 3R principles: Reduce (resource consumption), Reuse (product and component life extension), and Recycle (material recovery). For electronics companies, AURRA creates specific obligations around product design for disassembly, resin marking on plastics, and in some categories, recycled content targets. AURRA operates alongside sector-specific recycling laws — the Home Appliance Recycling Act (HARA), the Small Household Appliance Recycling Act (SHARA), and the PC Recycling Law — and understanding how these interact is essential for electronics companies entering Japan.

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At a glance

Governing law

AURRA (Act No. 48 of 1991)

Administering body

METI

Resin marking threshold

25g plastic components

Related laws

HARA, SHARA, PC Recycling

## AURRA obligations for electronics manufacturers and importers

### AURRA's scope for electronics

AURRA designates 'specified business operators' — manufacturers and importers above certain size thresholds — and 'specified product categories' where obligations apply. Electronics covered by AURRA include computers and peripherals, mobile phones (covered separately by voluntary JEITA schemes), audio/visual equipment, and office machines. The specific designated category and applicable obligations vary — refer to METI's AURRA implementing regulations for the current product schedule.

### Resin marking (plastic component labeling)

AURRA requires resin identification marks on plastic components weighing 25 grams or more in designated product categories. The mark identifies the plastic type using JIS K 6999 resin codes — similar to the triangular resin codes on US/EU plastics but using Japan-specific codes for polymer identification. For electronics with plastic housings and enclosures, these marks must be applied to each significant plastic component. The obligation is on the manufacturer or importer.

### Design for disassembly

For designated product categories, AURRA requires that products be designed for ease of disassembly to facilitate recycling. METI guidelines specify disassembly targets — typically that major recyclable components can be separated within a specified time using standard tools. Design-for-disassembly documentation is reviewed as part of METI's assessment of compliance plans submitted by specified business operators.

### Business reporting obligations for specified operators

Companies that exceed the AURRA threshold for 'specified business operators' — typically manufacturers/importers with annual sales above JPY 1 billion for their covered product categories — must submit periodic compliance plans and reports to METI on their 3R implementation measures. Smaller companies and importers below the threshold are not exempt from the resin marking and design obligations but are not required to file plans.

### Interaction with HARA, SHARA, and PC Recycling Law

The Home Appliance Recycling Act (HARA) covers large home appliances (TVs, refrigerators, air conditioners, washing machines) with specific retailer take-back and manufacturer recycling obligations. SHARA covers small household appliances — a broad category of consumer electronics — with municipal collection and manufacturer recycling targets. The PC Recycling Law mandates PC manufacturers to operate take-back and recycling programs. These sector-specific laws have obligations that go beyond AURRA's general framework.

## How to implement AURRA compliance for your product

01

Identify your product's category under AURRA's designated product schedule. METI's AURRA product list (available on METI's website) identifies designated categories and their applicable obligations. Confirm whether your product is in a designated category and which obligations apply.

02

Apply resin identification marks to all plastic components weighing 25 grams or more in your product — using the JIS K 6999 codes for the polymer type. For imported products, confirm with your manufacturer that marks are applied at the factory; for domestically assembled products, establish a marking process.

03

Assess whether your product falls under a sector-specific recycling law (HARA for large appliances, SHARA for small electronics, PC Recycling Law for computers). If so, understand the additional obligations under that law — typically retailer take-back cooperation and manufacturer recycling fee obligations.

04

If you are a 'specified business operator' (large manufacturer/importer above the threshold), prepare a 3R promotion plan covering your product design, manufacturing process, and recycled material usage targets, and submit it to METI in accordance with the AURRA reporting schedule.

05

Maintain records of resin marking compliance and 3R design measures. METI conducts compliance monitoring and can request documentation from operators in designated product categories.

## Frequently asked questions

### Does AURRA apply to small importers of electronics into Japan?

The full business reporting obligation (compliance plan submission to METI) only applies to 'specified business operators' above the sales threshold. However, the product-level obligations — resin marking on plastic components — apply to all importers of designated product categories regardless of size. A small importer of consumer electronics must ensure resin marks are present on 25g+ plastic components even if they are not required to file METI compliance reports.

### How does SHARA (Small Household Appliance Recycling Act) interact with AURRA for consumer electronics?

SHARA (Act No. 57 of 2012) covers a broad range of small household appliances — consumer electronics, small IT equipment, portable batteries — and requires municipal governments to provide collection points and manufacturers/importers to participate in recycling. SHARA registration with the Ministry of the Environment is required for covered product categories. AURRA and SHARA both apply to many consumer electronics — AURRA sets design/marking obligations, SHARA sets recycling system participation obligations.

### What resin codes does Japan use, and are they the same as EU resin codes?

Japan uses JIS K 6999 resin identification codes, which are broadly similar to the ISO 11469 codes used in the EU but have Japan-specific extensions. Common codes are the same (PP, PE, PS, PVC, PET) but some Japan-specific polymers and blends have JIS-unique codes. For products sold in both the EU and Japan, verify that the resin marks applied meet both JIS K 6999 and EU requirements — in practice, the codes are compatible for common polymers but should be verified for polymer types outside the common set.

### What happens if resin marks are absent from a product on the Japanese market?

METI can issue improvement recommendations to manufacturers and importers of non-compliant products. Persistent non-compliance can result in public identification of non-compliant operators and formal orders. While the direct penalties for AURRA resin marking violations are not as severe as for DENAN (PSE) electrical safety violations, the reputational impact of public naming by METI is significant in the Japanese market.

**Disclaimer:** Educational resource only. Regulatory requirements change and vary by product category. Consult an accredited test laboratory or qualified compliance engineer before making certification decisions.

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