Subcontract Act 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 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 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 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 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 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 issued a recommendation by the Ministry of Economy, Trade and Industry for violating the Subcontract Act by requiring subcontractors to store 2,577 molds and other items free of charge over a long period, despite not placing orders using those molds after May 2024.

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 Ministry of Economy, Trade and Industry issued a recommendation to Nippon Toka Packaging Co., Ltd. for violating the Subcontracting Law by requiring subcontractors to store printing plates and molds without compensation, despite not placing orders using those items after April 1, 2026.

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 Small and Medium Enterprise Agency conducted an investigation into TIRAD Corporation and found violations of the Subcontract Act (Article 4, Paragraph 2, Item 3) related to unfair requests for economic benefits. On January 26, 2026, the Agency issued a recommendation to the Fair Trade Commission based on Article 6 of the Act.

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 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.