Certificate of Manufacture (COM) from Japan

COM versus CFS — they are not interchangeable

Buyers new to Japanese sourcing frequently treat Certificate of Manufacture (COM) and Certificate of Free Sale (CFS) as synonyms. They are not.

• CFS attests that the product is freely sold in the Japanese domestic market. Issued by a public body (MHLW, prefectural government, or Chamber of Commerce).
• COM attests that the product was manufactured at a specific Japanese facility. Often issued by the manufacturer itself with optional Chamber of Commerce authentication, sometimes co-signed by a prefectural authority for regulated product categories.
• Destination authorities often request both for cosmetics and supplement registration. The COM proves where it was made; the CFS proves it is legally sold in the origin market.

What a typical Japanese COM contains

Although there is no single national template, the elements most destination authorities expect are:

• Product name (English and Japanese).
• Manufacturer's registered name and full address in Japan.
• Manufacturing licence category and number (cosmetics, food sanitation, quasi-drug, etc.), where applicable.
• Manufacturing date or production run period, sometimes with lot/batch number.
• Country of manufacture (Japan).
• Statement that the product was manufactured in accordance with applicable Japanese laws.
• Authorised signatory — typically the head of the manufacturing site or a director of the Japanese MAH where one exists.

Where the destination authority publishes its own template, use that template; otherwise the destination importer or buyer-side regulatory consultant should agree the wording with the manufacturer ahead of issuance.

Issuance paths

Self-certification by the manufacturer

For destinations that accept manufacturer self-declaration, the Japanese OEM manufacturer issues the COM on company letterhead, signs and stamps it with the company seal (代表者印 or 社印), and delivers a scan or hard copy to the buyer. Fastest path — typically 3–5 business days from request.

Chamber of Commerce authentication

For destinations that want third-party verification of the signature and seal, the manufacturer's COM is submitted to the local Chamber of Commerce (JCCI member) for authentication. Processing is typically 3–10 business days. Many South-East Asia and Middle East destinations request this authentication.

Prefectural co-signature (regulated categories)

For cosmetics and quasi-drugs in some destinations (notably some Middle East and Latin American markets), the destination authority requests prefectural-government co-signature on the COM, confirming the manufacturer's licence is in good standing. Processing 2–6 weeks. The Japanese MAH or the manufacturer's regulatory adviser routes this through the prefectural pharmaceutical affairs division.

Legalisation chain after issuance

Like the CFS, a COM intended for a non-Hague destination typically requires MOFA authentication and consular legalisation (see Apostille and Consular Legalisation for Japanese Documents). For Hague members, apostille from MOFA is typically sufficient.

Common destination patterns

• South-East Asia (Vietnam, Indonesia, Philippines, Thailand). COM commonly requested for cosmetics and food registration. Chamber of Commerce authentication is the standard. Consular legalisation at the local Japanese consulate is normally required.
• Middle East (UAE, Saudi Arabia, Egypt). COM commonly requested, often with apostille plus consular legalisation. Some destinations require co-signature by prefectural authority for cosmetics and quasi-drugs.
• Latin America (Brazil, Mexico, Argentina).COM increasingly requested as part of cosmetic and food registration dossiers. Format varies by destination authority — confirm before issuance.
• European Union and United Kingdom. COM is not part of the standard CPNP / SCPN cosmetic notification process, but is sometimes requested for food, supplements, and quasi-drug registration in some member states.
• United States. Not normally required for FDA registration, but increasingly requested by US-side importers and retailers as part of due-diligence dossiers.

Practical notes for overseas buyers

• Confirm the destination template first. Some destinations specify exact wording. Issuing a free-form COM that the destination later rejects costs another 2–4 weeks.
• Plan for lot-specific versus product-level COMs.Some destinations want a lot-specific COM matching each shipment; others accept a product-level COM that covers all shipments for a year. Lot-specific COMs add per-shipment lead time and cost.
• COM is not a substitute for a quality agreement.The COM attests origin and licence; it does not commit the manufacturer to specifications, OOS handling, or change control. Those belong in the OEM contract and quality agreement (see Japanese OEM Contract Essentials).