Japan Fair Trade Commission Enforcement Actions in Japan

The Fair Trade Commission issued a recommendation to Iliso Electronics Industry Co., Ltd. for violating the Subcontractor Law by having 34 subcontractors store molds and parts without bearing the costs from June 2024 onward.

The Fair Trade Commission issued a recommendation to HOYA Corporation for violating the Subcontracting Law by providing molds and jigs to 32 subcontractors without charging storage fees, despite not placing long-term orders for parts or prototypes made using those molds.

The Fair Trade Commission issued a recommendation to Diamond Electric Corporation for violating the Subcontract Act by having 23 subcontractors store 650 molds without bearing the storage costs, from August 2024 onward.

The Fair Trade Commission issued a recommendation to Tenryu Kogyo Co., Ltd. for violations of the Subcontracting Law, involving improper reduction of subcontracting payments and unbilled storage costs for molds and parts between November 2024 and September 2025.

The Fair Trade Commission issued a recommendation to Minebea Access Solutions Co., Ltd. on July 10, 2026, under the Subcontractor Payment Delay Prevention Law, regarding violations involving the delegation of transportation and storage costs to subcontractors for automotive parts manufacturing.

The Fair Trade Commission issued a recommendation to Tadano Co., Ltd. for violating the Subcontract Act by requiring subcontractors to store and inventory molds without bearing the associated costs, affecting 50 subcontractors since January 2024.

The Fair Trade Commission issued a recommendation to Noritz Corporation under the old Subcontracting Law, regarding the storage costs of molds for parts supplied to 41 subcontractors.

The Fair Trade Commission issued a recommendation to DAIHEN Corporation for violating the Subcontractor Payment Delay Prevention Law by having 69 subcontractors store 475 molds and related items without bearing the storage costs, from March 2024 onward.

The Fair Trade Commission issued an order to Ogata Construction Co., Ltd. on June 25, 2024, for violating the Anti-Monopoly Act by restricting competition in a public civil engineering project ordered by Kagawa Prefecture.

The Fair Trade Commission issued an order to Shinomiya-gumi Ltd. on June 25, 2024, for restricting competition in a public civil engineering project by colluding with other local businesses to pre-select the winning bidder and manipulate bidding prices.

The Fair Trade Commission issued an order to Murakami-gumi Co., Ltd. on June 25, 2024, for restricting competition in a public civil engineering project in Kagawa Prefecture by colluding with local businesses to pre-select bidders and manipulate bidding prices.

The Fair Trade Commission issued an order to Shibaguchi Corporation on June 25, 2024, for violating the Anti-Monopoly Act by restricting competition in a public civil engineering project ordered by Kagawa Prefecture.

The Fair Trade Commission issued an order to Daiichi Kogyo Co., Ltd. on June 25, 2024, for restricting competition in a public civil engineering project by colluding with local businesses to pre-select bidders and manipulate bidding prices.

YKK Corporation was advised by the Fair Trade Commission for unilaterally setting subcontracting payments lower than the actual work value for 21 subcontractors between July 4, 2023, and November 27, 2025, by using a calculation method that overestimated work capacity, resulting in payments 9% to 72.5% below the appropriate amount, including some below regional minimum wages.

The Fair Trade Commission issued a recommendation to Alps Alpine Corporation for violating the Subcontracting Law prior to its revision, by unilaterally setting contract prices based on mass production quantities despite significant changes in production costs after mass production had ended.

The Fair Trade Commission issued a recommendation to Honda Ibaraki Minami for violating the Subcontract Act by failing to pay transportation costs for vehicle pickup and delivery services performed by subcontractors between September 2024 and September 2025.

The Fair Trade Commission issued a recommendation to Ryukyu Warehouse Transport Co., Ltd. for violating the Subcontractor Law by not using the agreed basic freight rate table to calculate subcontracting payments and instead paying a percentage of the amount received from shippers, resulting in a deduction of approximately 37.77 million yen from subcontractor payments.

The Fair Trade Commission issued a recommendation to Ryukyu Warehouse Transport Co., Ltd. for violating the Subcontract Act by not using the agreed basic freight rate table and deducting 37.77 million yen from payments to 16 subcontractors.

The Fair Trade Commission issued a recommendation to Ryukyu Warehouse Transport Co., Ltd. on May 12, 2024, for violating the Subcontractor Law by deducting 37,776,571 yen from payments to 16 subcontractors without using the agreed basic freight rate table, instead calculating payments based on a fixed percentage of amounts paid by shippers.

The Japan Fair Trade Commission issued an order to eliminate practices to Sumitomo Expressway Corporation for violating the Antimonopoly Act by engaging in bid-rigging related to road cleaning services.

The Fair Trade Commission ordered Subaru Kogyo to pay a surcharge of 5,282,500 yen for involvement in bid-rigging related to road cleaning services, including activities such as determining bidders, selecting cooperators, preparing and providing cost breakdowns, and submitting or withdrawing bids, from at least May 22, 2017.

The Fair Trade Commission has filed a criminal complaint against East Japan Usami Co., Ltd. and four other companies for violating the Anti-Monopoly Act through price cartel activities related to diesel fuel sales.

The Fair Trade Commission has filed a criminal complaint against five companies, including Toho Gas Co., Ltd., for engaging in price cartel activities related to diesel fuel sales, violating the Anti-Monopoly Act.

The Fair Trade Commission has filed a criminal complaint against four companies, including Higashi-Nihon Usami, for violating the Anti-Monopoly Act through price collusion in the diesel fuel sales industry.

The Fair Trade Commission has filed a criminal complaint against five companies, including Higashi-Nihon Usami Corporation, for violating the Anti-Monopoly Act through price collusion in the sale of diesel fuel.

The Fair Trade Commission has filed a criminal complaint against four companies, including Higashi-Nihon Usami Corporation, for violating the Anti-Monopoly Act through price collusion among diesel fuel sellers.

The Fair Trade Commission conducted an investigation into Yazaki Parts Co., Ltd. and found violations of Article 4, Paragraph 2, Item 3 of the Subcontract Act (prohibition of unjust requests for economic benefits). Consequently, on March 30, 2024, the FTC issued a recommendation to the company based on Article 7, Paragraph 3 of the Act.

The Fair Trade Commission issued a recommendation to Tokushima Toyota Motor Corporation for violating the Subcontract Act by requiring six subcontractors to perform free transportation services related to vehicle pickup and delivery between July 2024 and September 2025, adversely affecting their interests.

Fujitsu Frontech was advised by the Fair Trade Commission for unfairly harming subcontractors by having them store 2,577 molds free of charge, despite not placing orders for the related products since May 2024.

The Fair Trade Commission issued a recommendation to Matsuo Manufacturing Co., Ltd. for violating the Subcontracting Law by unjustly requiring subcontractors to store molds without compensation.

The Fair Trade Commission issued a recommendation to Nippon Toka Packaging Co., Ltd. for violating the Subcontracting Law by improperly requiring subcontractors to store printing plates and molds without proper orders, thereby unfairly harming their interests.

The Fair Trade Commission issued a warning to Zagu Zagu Co., Ltd. for requiring suppliers to dispatch employees for store opening and renovation tasks without bearing the usual costs, during the period from August 20, 2022, to December 23, 2023.

The Japan Fair Trade Commission has ordered Dentsu Group Inc. to pay a revised surcharge related to a violation of the Anti-Monopoly Act, following an investigation into bid-rigging concerning Tokyo 2020 Olympic test events.

YKK AP Corporation was advised by the Fair Trade Commission for violating the Subcontract Act by retaining 4,997 molds without charge, despite not placing orders for related products for an extended period.

The Fair Trade Commission issued a recommendation to Ryukyu YKKAP Kogyo Co., Ltd. under the Subcontracting Law on March 10, 2024. The company was found to have stored molds and parts without proper agreement from May 10, 2024, to January 30, 2026, despite not placing orders for products using those molds during that period.

The Fair Trade Commission issued a recommendation to YKK AP Okinawa Co., Ltd. under the Subcontractors Law in March 2024. The company was found to have stored mold② without charge for an extended period despite not placing orders for parts made with that mold from February 2024 to March 2025, after requesting prior approval for mold retrieval or disposal.

The Fair Trade Commission issued a warning to Kamashin Co., Ltd. on March 5, 2024, regarding potential violations of the Anti-Monopoly Act, specifically Article 19 concerning abuse of a superior bargaining position.

The Fair Trade Commission issued a warning to Delicia Co., Ltd. for violating the Anti-Monopoly Act by dispatching suppliers' employees to assist with store openings, renovations, and sales floor changes without bearing the usual costs, during the period from April 1, 2022, to July 6, 2024.

The Fair Trade Commission issued a recommendation to TIRAD Corporation on February 24, 2026, for violating the Subcontracting Law by unjustly requiring subcontractors to store molds and jigs without orders over an extended period.

The Fair Trade Commission issued a recommendation to Nissan Tokyo Sales Co., Ltd. for violations of the Subcontractor Law, involving unpaid transportation work for vehicle pickup and delivery, and parts pickup from subcontractors between August 2024 and July 2025.

The Fair Trade Commission issued a warning to Murakami Trading Co., Ltd. on February 19, 2024, regarding a suspected violation of the Anti-Monopoly Act. The company allegedly continued supplying regular gasoline at prices significantly below the cost of supply at a gas station in Fukuchiyama City, Kyoto Prefecture, during a certain period from July 1 to August 31, 2023, potentially hindering the business activities of other gasoline sellers in the surrounding area.

The Fair Trade Commission issued a recommendation to Nagatoya Co., Ltd. for violating the Subcontracting Law by deducting discounts from subcontracting payments between September 2022 and September 2023, reducing the total payments by approximately 54.75 million yen.

The Fair Trade Commission issued a recommendation to Toshiba Hokuto Electronics Co., Ltd. for violations of the Subcontractors Law, involving the unremunerated storage of molds and related parts despite long-term order suspensions.

The Fair Trade Commission issued a recommendation to Toshiba Industrial Machinery Systems Co., Ltd. for violations of the Subcontract Act related to the unremunerated storage of molds and other manufacturing tools.

The Fair Trade Commission issued a recommendation to Toyo Denso Corporation for violations related to subcontractor payment delays and improper handling of manufacturing processes, including classification of inspection types, transfer of costs for product returns and mold storage, and unauthorized retention of molds. The violations involved unperformed or improperly conducted acceptance inspections, charging subcontractors for return shipping and mold storage, and retaining molds without proper orders.

The Fair Trade Commission issued a recommendation to Makita Corporation for violating the Subcontractor Payment Delay Prevention Law by unjustly harming subcontractors' interests through the free storage of molds used for manufacturing parts, despite not placing orders for extended periods.

The Fair Trade Commission issued a recommendation to Senko Co., Ltd. under the Subcontractor Payment Delay Prevention Law, citing unfair practices involving unpaid loading, unloading, and waiting times for subcontractors in freight transportation operations between December 2022 and November 2025.

The Fair Trade Commission issued a recommendation to Sugimoto Electric Industry Co., Ltd. on December 11, 2025, for violations of the Subcontractor Payment Delay Prevention Law, specifically regarding unjustified deductions from subcontractor payments and the acceptance of returned goods without proper inspection.

The Fair Trade Commission issued a recommendation to Snack Co., Ltd. for violations of the Subcontractor Payment Delay Prevention Law. Snack failed to renegotiate prices with subcontractors after production volume decreased significantly, and improperly required subcontractors to store molds without compensation, adversely affecting their interests.

The Fair Trade Commission issued a recommendation to Nany Nihon Unyu Soko Co., Ltd. under the Subcontractor Payment Delay Prevention Law, for reducing payments to six subcontractors without justifiable reasons between June 2024 and September 2025. The total amount of underpaid funds was approximately 18.96 million yen, involving deductions for management fees and payments made via designated bank accounts.

The Fair Trade Commission issued a recommendation to Fukuoka Daihatsu Sales Co., Ltd. for unfairly harming subcontractors by having them provide a total of 76 vehicles free of charge for use as loaner cars for customers from August 2022 to April 2025.

The Fair Trade Commission issued a recommendation to Mitsubishi Fuso Truck and Bus Corporation on November 13, 2025, regarding violations of the Subcontractor Payment Delay Prevention Law. The company was found to have unreasonably harmed subcontractors by lending molds without charge and requiring annual inventory checks despite not placing orders for the products made with those molds after March 1, 2024. The company also negotiated and paid some costs for these activities to 21 subcontractors.

The Fair Trade Commission issued a recommendation to Nichiko Electric Manufacturing Co., Ltd. for delaying payments to subcontractors and improperly requiring them to store molds without compensation.

Mitsubishi Fuso Truck and Bus Corporation was guided by the Fair Trade Commission for delaying payments to subcontractors from January to December 2024, resulting in delayed interest payments totaling 35,791,671 yen to six subcontractors.

Toyota East Japan Corporation was instructed by the Fair Trade Commission for violating the Subcontractor Payment Delay Prevention Law by unreasonably benefiting from subcontractors through storage practices of bulk production parts.

The Fair Trade Commission issued a recommendation to Toyota Motor East Japan Co., Ltd. for violations related to delaying payments to subcontractors under the Subcontractor Payment Delay Prevention Law. The company was found to have improperly retained 440 molds and tools owned by subcontractors without consent, causing unfair harm to the subcontractors' interests between April 1, 2024, and March 31, 2025, despite not placing orders for the related automotive parts during that period.

The Fair Trade Commission has requested Mitsubishi Mahindra Agricultural Machinery to implement effective measures to ensure compliance with the Subcontractors Law, particularly regarding group companies that may qualify as parent businesses under the law.

The Fair Trade Commission issued a recommendation to Ryonoh Factory Co., Ltd. on October 9, 2025, for violations related to delaying payments to subcontractors under the Subcontractor Payment Delay Prevention Law. The company was found to have entrusted manufacturing of parts for agricultural and construction machinery to subcontractors, including small and medium-sized enterprises, and to have improperly retained molds and jigs without ordering production for extended periods, thereby unfairly harming the interests of the subcontractors.

Olympic Corporation was advised by the Fair Trade Commission for delaying payments to subcontractors under the Subcontractor Payment Delay Prevention Law. Between May 2023 and April 2025, it deducted amounts from subcontractor payments totaling 17,275,530 yen for certain costs.

The Fair Trade Commission issued a recommendation to JTEKT Corporation for violating the Subcontractor Payment Delay Prevention Law by deducting bank transfer fees from subcontractor payments beyond actual costs between December 2022 and November 2024, without just cause.

The Fair Trade Commission issued a recommendation to Shimano Co., Ltd. on September 17, 2025, for violating the Subcontractor Payment Delay Prevention Law. Shimano, a bicycle parts manufacturer, had provided free storage of 4,313 molds and tools to its subcontractors and required biannual inventory checks despite not placing orders for the products made with these molds since December 1, 2023, thereby unfairly harming the subcontractors' interests.

The Fair Trade Commission issued a recommendation to Yodobashi Camera for violating the Subcontractor Payment Delay Prevention Law by reducing payments to subcontractors without justifiable reasons between January 2024 and March 2025, totaling approximately 13.49 million yen across six subcontractors.

The Fair Trade Commission issued a recommendation to Iwaki Die Casting Industry Co., Ltd. on August 7, 2025, for violations of the Subcontractor Payment Delay Prevention Law. The company was found to have unilaterally demanded the return of products from subcontractors based on defects that were immediately detectable in accepted lots, without prior agreement on return conditions, and to have borne the costs related to processing and returns, totaling approximately 8.16 million yen for 16 subcontractors.

The Fair Trade Commission issued a recommendation to Misato Kogyo Co., Ltd. for violations related to delayed payments to subcontractors and improper handling of defective products and molds, under the Subcontractor Payment Delay Prevention Law.

The Fair Trade Commission issued a recommendation to Fuji Sashii Co., Ltd. on July 24, 2025, for violations of the Subcontractors Act related to unfair practices involving subcontractors manufacturing aluminum sash components.

The Fair Trade Commission issued a recommendation to Izumi Kogyo Co., Ltd. for violating the Subcontractor Payment Delay Prevention Law by requiring a subcontractor to store molds and jigs without compensation after completing large orders of automotive parts, resulting in unjust harm to the subcontractor's interests. The company paid approximately 5.8 million yen as compensation for the storage costs.

The Fair Trade Commission issued a recommendation to SMK Corporation under the Subcontractor Payment Delay Prevention Law for unfairly harming subcontractors by having them store 823 molds without orders after January 1, 2024.

The Fair Trade Commission issued a recommendation to Nissei Resin Industry Co., Ltd. for violations of the Subcontractor Law related to delaying payments and other conduct.

The Fair Trade Commission issued a recommendation to Iseki Agricultural Machinery Co., Ltd. for violations related to the management and retention of molds and jigs used in manufacturing agricultural machinery, despite not placing orders for parts over an extended period.

The Fair Trade Commission issued a recommendation to Suzuki Jihan Oita for unfairly harming subcontractors by requiring them to provide 25 vehicles free of charge for car repairs between May 2022 and August 2023.

The Fair Trade Commission issued a recommendation to Kayaba Corporation for violating the Subcontractor Payment Delay Prevention Law by requiring subcontractors to store molds and jigs without orders for extended periods, thereby unfairly harming their interests.

The Fair Trade Commission issued a recommendation to Sato Trading Co., Ltd. on April 21, 2025, for violating the Subcontractor Payment Delay Prevention Law by accepting products from subcontractors without conducting quality inspections and citing defects.

Sato Shoji Corporation was instructed by the Fair Trade Commission for delaying payments to subcontractors, specifically for late payment of interest and delayed payments under the Subcontractor Payment Delay Prevention Law.

The Fair Trade Commission issued a recommendation to Korona Co., Ltd. for violating the Subcontractor Payment Delay Prevention Law by unjustly harming subcontractors' interests through the unrequested long-term storage of molds and jigs used for manufacturing certain products, despite not placing orders using those molds after March 1, 2023.

The Fair Trade Commission issued an order for corrective measures to Tonichi Consultant for violating the Anti-Monopoly Act by coordinating bid prices for specific overpass inspection projects.

The Fair Trade Commission issued an order to Dainichi Consultant on December 19, 2024, for violating the Antimonopoly Act by coordinating bid prices for specific overpass inspection projects since at least February 19, 2021.

The Fair Trade Commission of Japan issued an order to JR Central for violating the Anti-Monopoly Act by coordinating with other bidders and submitting higher bids for specific overpass inspection work from at least February 19, 2021.

The Fair Trade Commission issued an order to Japan Transportation Technology and five other companies for violating the Anti-Monopoly Act by colluding to restrict competition in specific overpass inspection contracts from February 19, 2021.

The Fair Trade Commission issued a warning in December 2024 to three non-branch members involved in petroleum sales for suspected collusion in obtaining and using pricing information from branch members to determine sales prices.

The Fair Trade Commission issued an order for corrective measures to Maruei Chosa Sekkei for violating the Anti-Monopoly Act by coordinating with other bidders and submitting higher bids for specific bridge inspection projects after February 19, 2021.

The Fair Trade Commission issued an order to JR Tokai Consultants for violating the Anti-Monopoly Act by coordinating bidding activities for specific overpass inspection projects, restricting competition.

The Fair Trade Commission issued a request to the Nagano Petroleum Business Association on November 26, 2024, regarding violations of the Anti-Monopoly Act involving price reporting and approval practices.

The Nagano Prefecture Petroleum Business Cooperative Hokushin Branch was ordered to cease practices that involved coordinating the price revisions and timing of sales prices for specific volatile oils among its members, in violation of the Antimonopoly Act.

The Fair Trade Commission issued a recommendation to KADOKAWA Corporation for violating the Subcontract Act by unilaterally reducing order prices for subcontractors without consultation.

The Fair Trade Commission issued a recommendation to KADOKAWA LifeDesign on November 12, 2024, for violating the Subcontractors Act by unilaterally applying pre-determined subcontracting prices without consultation after acquiring the Lettuce Club business on April 1, 2024.

The Fair Trade Commission issued a recommendation to Cover Corporation for violations related to unpaid rework requests from subcontractors during 2022-2023, involving the creation of illustrations and models for online video content.

NICE Corporation was advised by the Fair Trade Commission for reducing subcontract payments without justifiable reasons between November 2022 and May 2024, involving 34 subcontractors and totaling approximately 23.2 million yen.

SANEI Corporation was issued a warning by the Fair Trade Commission for violating the Subcontractor Payment Delay Prevention Law. The violations include deducting 'purchase discounts' from subcontractor payments, lending molds without charge, and conducting inventory checks that unjustly harmed subcontractors' interests. The violations involved 10 subcontractors and 50 mold owners, with some molds being discarded.

The Fair Trade Commission issued a warning to Shinmei Denzai Corporation on September 25, 2024, for suspected violations of the Anti-Monopoly Act related to conduct involving continuous supply of electrical equipment materials and requesting payments under the guise of sales support activities, despite no benefit to the suppliers.

The Fair Trade Commission issued an order for corrective measures to Nihon Trecx on September 24, 2024, for colluding with Toho Vehicles to raise the prices of specific trailers, thereby substantially restricting competition contrary to the Anti-Monopoly Act.

The Fair Trade Commission of Japan issued an cease-and-desist order to Kyokuto Kaihatsu Kogyo Co., Ltd. and ShinMaywa Industries, Ltd. for colluding to raise prices of specialized vehicles, including dust carts and tailgate lifts, due to rising raw material costs, thereby restricting competition in the market.

The Fair Trade Commission issued an corrective order to Harley-Davidson Japan on September 18, 2024, for violating the Anti-Monopoly Act by abusing a superior bargaining position over certain dealers, including unilaterally setting RSO targets and pressuring dealers to meet them.

The Fair Trade Commission issued a recommendation to Pal System Co-op Federation for violating the Subcontractor Payment Delay Prevention Law by deducting certain amounts from subcontract payments without proper authorization, totaling approximately 27.7 million yen.

The Fair Trade Commission has issued a recommendation to Toyota Customizing & Development Co., Ltd. for violations of the Subcontractors Law, specifically regarding the prohibition of return and the prohibition of requesting unjust economic benefits. The violations involved improper storage of molds and parts without orders, adversely affecting subcontractors.

The Northern Shin Branch of the Nagano Prefecture Petroleum Business Association was ordered to pay a surcharge of 11,658,000 yen for violating the Antimonopoly Act by determining and communicating price revisions for specific volatile oils sold by its members.

The Fair Trade Commission issued a recommendation to Osaka Sealing Printing Co., Ltd. under the Subcontractor Payment Delay Prevention Law, for unfairly forcing subcontractors to redo designs without cause and paying approximately 9.84 million yen for these reworks.

The Fair Trade Commission issued a recommendation to Mitsui Food Industry Co., Ltd. for delaying payments to subcontractors. Between May 2022 and August 2023, the company deducted amounts from subcontractor payments without justifiable reasons, totaling 9,886,497 yen for six subcontractors.

The Japan Baseball Organization was warned by the Fair Trade Commission for potentially violating the Anti-Monopoly Act by restricting media activities and adjusting broadcast rights concerning Major League Baseball games during the 2024 Japanese Series.

The Fair Trade Commission conducted an investigation of Co-op Sapporo and found violations of the Subcontract Act regarding the reduction of subcontract payments. A recommendation was issued to the cooperative on May 22, 2024.

The Fair Trade Commission issued an cease-and-desist order to Esbee Foods for collusive agreement to raise the wholesale price of sesame oil.