Request to Improve Transaction Practices in the Carton Industry
Overview
The Japan Fair Trade Commission found that manufacturers and sellers of corrugated cardboard products, paper containers, and other goods violated the Subcontract Act before its amendment, and issued two recommendations over the past year. In both cases, businesses required small and medium-sized entrusted businesses to store printing plates and other items for which no orders had been placed for a long time, without paying storage costs. The Commission determined that this constituted a request for the provision of an unfair economic benefit. After an investigation found that free storage was an industry practice, three relevant agencies asked the Japan Carton Box Association to publicize the cases, promote legal compliance among member companies, review the practice, and provide ongoing follow-up.
Key points
- Two recommendations found that requiring free storage constituted a request for the provision of an unfair economic benefit.
- Three relevant agencies asked the industry association to publicize the cases, promote legal compliance, and review business practices.
- An investigation confirmed that free storage of printing plates and other items was an industry practice.
Overview
The Act against Delay in Payment of Subcontract Proceeds, Etc. (Act No. 120 of 1956; hereinafter, the “Subcontract Act”) became the Act on Prevention of Delayed Payment of Transaction Proceeds to Small and Medium-Sized Entrusted Businesses, Etc. (commonly known as the Transaction Appropriateness Act) on January 1, 2026. The Japan Fair Trade Commission issued two recommendations over the past year for violations by manufacturers and sellers of corrugated cardboard products, paper containers, and other goods of Article 4, Paragraph 2, Item 3 of the Subcontract Act before its amendment.
In both cases, businesses did not place orders for a long time for products using loaned printing plates and other items, while requiring small and medium-sized entrusted businesses to store those items without paying storage costs. This was determined to constitute a request for the provision of an unfair economic benefit.
Impact
The Small and Medium Enterprise Agency and the Japan Fair Trade Commission will continue to respond swiftly and strictly to violations of the Transaction Appropriateness Act by manufacturers and sellers of corrugated cardboard products, paper containers, and other goods.
Details
On October 22, 2026, the Small and Medium Enterprise Agency, the Japan Fair Trade Commission, and the Ministry of Economy, Trade and Industry asked the Japan Carton Box Association to publicize within the industry a leaflet describing the recommendation cases and explaining that free storage is problematic; promote legal compliance by member companies to correct and prevent violations of the Transaction Appropriateness Act and ensure appropriate price pass-through; and review the business practice of free storage and provide ongoing follow-up.