Tax-Free E-commerce from November 2026: What Sellers Must and Need Not Do Under the Refund Method

November 12, 2026

Key points: For transfers (handovers) on or after November 1, 2026, tax-free shops sell at tax-inclusive prices and refund the tax only after they receive customs check information. The traveler has the purchase checked by customs when leaving Japan within 90 days of the purchase date, and the tax exemption applies once the tax-free shop obtains and stores that information (customs check information).

  • The new rules cover transfers (handovers of goods) from 12:00 a.m. on November 1, 2026. There is no transition period.
  • A place for selling goods set up on a website does not count as a "sales site" (販売場) under the system.
  • The law does not set a refund method. It also does not say who bears the fee when you outsource refunds to an agent, and the government charges no fee for refunds.

Check first: when does the tax exemption fail on the seller's side?

The exemption fails in the following five cases, and the transaction remains a taxable sale.

  1. You did not send the purchase record information immediately. Sending once a day in a batch, or sending several records together, does not meet the "without delay" (遅滞なく) requirement. The sale is not tax-free even if the system accepts the data normally.
  2. The passport number or other details contain errors or omissions. Customs checks are based on the purchase record information, so if customs cannot run the check, the traveler generally cannot have the goods checked.
  3. The traveler does not have the goods checked within 90 days, or is missing even one item. Checks are done per sale (per receipt). If even one item is missing, none of the goods in that purchase record information are tax-free.
  4. You did not store the purchase record information and the customs check information. (Unless you prove that a disaster or other unavoidable circumstance prevented it.)
  5. You refunded before the check, and the traveler then did not have the goods checked. The sale is treated as a taxable sale at the post-refund amount.

Source: National Tax Agency, Q&A on the Refund Method, Q16, Q22, Q37 and Q57

Core duties: purchase record information, customs check information, and explaining to travelers

A tax-free shop's core duties are to provide purchase record information, obtain customs check information and store it for seven years, and explain the rules to travelers. From sale to refund, the steps run in this order.

  1. Have the traveler present a passport or similar document, and confirm that the traveler is an eligible tax-free purchaser (免税購入対象者). This includes the Visit Japan Web QR code.
  2. Explain the required points to the traveler.
  3. Hand over the goods to the traveler in person at the tax-inclusive price. Judge the minimum purchase amount (¥5,000 for the same traveler, at the same sales site, on the same day) on the tax-exclusive price.
  4. Provide the purchase record information to the National Tax Agency's Tax-Free Sales Management System (免税販売管理システム) without delay.
  5. Obtain the customs check information from the Tax-Free Sales Management System.
  6. Store both sets of information for seven years. The period starts on the day two months after the day following the last day of the taxable period that includes the sale date.
  7. Refund the amount equivalent to the consumption tax to the traveler.

You need to explain three things: the traveler must present a passport or similar document and have the goods checked when leaving Japan within 90 days; after the check, the goods must be exported without delay, and if they are not, the amount equivalent to the consumption tax will be collected and penalties may apply; and the check cannot be done after the baggage has been checked in for the flight. You may hand over a written notice in a foreign language or post a notice instead. In that case, you should still ask the traveler verbally to read it.

Source: National Tax Agency, Q&A on the Refund Method, Q16, Q18 and Q44; Q&A on the Refund Method (overview edition), Q8

A website storefront is not a "sales site": how to sell tax-free

A place for selling goods set up on an internet website does not count as a "sales site" under the system. A sales site must physically exist at a fixed location. Permission is granted per sales site to a business subject to consumption tax (課税事業者) by the head of the tax office with jurisdiction over its place for tax payment (納税地).

The tax-free sales procedure takes place at the time the goods are handed over to the traveler at the sales site. If you ship the goods to the traveler's home after they return to their country, this system's tax exemption does not apply. The direct shipping system (直送制度) and exporting the goods yourself fall under a different system: the export exemption (輸出免税) under Article 7 of the Consumption Tax Act (消費税法).

In a model where orders come in online and goods are handed over at a physical location, the seller's scope of work depends on who holds the permission and who carries out the procedure at handover and provides the purchase record information. Under consignment sales (販売委託), the consignor is usually the business that applies for permission. Under sales-based purchasing (消化仕入れ), it is usually the department store or similar retailer.

Source: National Tax Agency, Q&A on the Refund Method, Q1, Q14 and Q19; Q&A on the Refund Method (overview edition), Q5

Two types of sales site: general type and vending-machine type

The current general type and procedure-outsourcing type (手続委託型) are merged into the "general-type export goods sales site" (一般型輸出物品販売場), leaving two types: general type and vending-machine type.

Table 1: Types of export goods sales site (from November 1, 2026)
Item General type Vending-machine type
Definition Any sales site other than the vending-machine type A sales site that carries out the tax-free sales procedure and provides purchase record information only through a designated vending machine (指定自動販売機)
Specific permission requirements Has a system in place to carry out the tax-free sales procedure and provide purchase record information properly (if outsourcing, has signed an outsourcing contract) The sales site has only one designated vending machine installed
Outsourcing the tax-free sales procedure Can be outsourced to an approved tax-free procedure operator (承認免税手続事業者); can be combined with handling it in-house N/A (handled by the vending machine)

Support for Visit Japan Web is not a permission requirement.

Source: National Tax Agency, Q&A on the Refund Method, Q2, Q14 and Q61; Q&A on the Refund Method (overview edition), Q5

Refund methods: the tax-free shop is responsible, and no method is prescribed

The tax-free shop can make refunds itself or outsource them to an approved transmission service provider (承認送受信事業者) or another party. Consumption tax law sets no rules on how refunds must be made.

Table 2: What official materials say about refunds
Topic What official materials say
Method Not prescribed. Examples given are bank transfer, credit card remittance, app-based remittance, and cash at the departure port
Timing Normally after obtaining the customs check information. Refunding before that is not prohibited, but if the traveler does not have the goods checked, the sale is not tax-free, so the business does so at its own risk
Fees Nothing specifies whether the traveler or the tax-free shop bears the fee when refunds are outsourced to an agent. The government charges no fee for refund procedures
If a refund cannot be made The exemption still applies if the customs check information is stored. An amount that unavoidably could not be refunded for reasons on the traveler's side, and that the parties agreed by contract need not be refunded, is recorded as miscellaneous income (雑益) outside the scope of consumption tax (不課税)
Outsourcing partners and other laws The partner need not be an approved operator, but it must register as a funds transfer service provider (資金移動業) and meet requirements under laws such as the Act on Prevention of Transfer of Criminal Proceeds (犯罪収益移転防止法) and the Foreign Exchange and Foreign Trade Act (外為法). A tax-free shop that outsources does not need to register as a funds transfer service provider (registration may be required if it makes refunds itself)

Source: National Tax Agency, Q&A on the Refund Method, Q57 to Q59; Japan Tourism Agency, FAQ for Tax-Free Shops (Refund Method), Q17 to Q21

What can you outsource? Approved transmission service providers vs. approved tax-free procedure operators

Approved transmission service providers handle providing purchase record information and obtaining customs check information. Approved tax-free procedure operators handle the rest of the tax-free sales procedure.

Table 3: Comparing the two types of outsourcing partner
Item Approved transmission service provider Approved tax-free procedure operator
Tasks handled Providing purchase record information, obtaining customs check information Tax-free sales procedure (excluding those two tasks)
Conditions None Done at a tax-free procedure counter (免税手続カウンター) on the same day the goods are transferred at the sales site
What to enter on the permission application The partner's identification code (識別符号) and name (no electronic certificate needed) The partner's name and place for tax payment
What stays with the tax-free shop after outsourcing Storing both sets of information (received from the partner) Confirming that the goods are the same, and taking steps to prevent duplicate procedures

A single business that wants to act as both needs each approval. When you change or add outsourcing partners, submit a "Notification of Changes to Export Goods Sales Site, etc." (輸出物品販売場等変更届出書) without delay.

Source: National Tax Agency, Q&A on the Refund Method, Q25, Q29, Q44, Q47, Q63, Q66 and Q67

Setup checklist

  • We have decided which business will hold the permission and which physical sales site will hand over the goods.
  • We have decided whether to handle the tax-free sales procedure in-house or outsource it (or both).
  • We have decided whether to send and receive purchase record information through our own system, another company's system, or an approved transmission service provider.
  • We have decided how to capture passport details (passport reader or manual entry).
  • Product names are specific enough for customs to identify the goods, and "detailed product information" (商品情報詳細) is set for items priced at ¥1,000,000 or more per unit excluding tax.
  • We have a procedure for explaining the rules to travelers, using a written notice or a posted notice plus a verbal prompt.
  • Our point-of-sale guidance reflects the refund method, what happens if a refund cannot be made, and who bears the fees.
  • We have agreed with accounting on when to reclassify taxable sales as tax-free sales (each time information is obtained, or monthly).

Source: National Tax Agency, Q&A on the Refund Method, Q14, Q25, Q45, Q54, Q93 and Q95

FAQ

Does the Refund Method cover online orders shipped to the traveler's home abroad after they return?

No. The tax-free sales procedure takes place when the goods are handed over at the sales site. (Direct shipping and exporting the goods yourself fall under the export exemption, a separate system.)

If I outsource to an approved transmission service provider, am I still required to store the information?

Yes. You receive both sets of information from the partner and store them. If you have constant direct access to the partner's server and the partner stores the data with the prescribed measures in place, you are treated as storing it, but only for the period during which you can view it.

Can I refund before the customs check?

This is not prohibited. However, if the traveler does not have the goods checked, the sale is not tax-free, so the decision is at your own risk.

Source: National Tax Agency, Q&A on the Refund Method, Q19, Q57 and Q66

Read next

Sources and date checked

  1. National Tax Agency, "Q&A on the Refund Method" (July 2026) (Japanese): https://www.nta.go.jp/publication/pamph/shohi/menzei/201805/pdf/0026006-152_01.pdf
  2. National Tax Agency, "Q&A on the Refund Method (overview edition)" (revised April 2026) (Japanese): https://www.nta.go.jp/publication/pamph/shohi/menzei/201805/pdf/0025012-025_02.pdf
  3. Japan Tourism Agency, "FAQ for Tax-Free Shops (Refund Method)" (Japanese): https://www.mlit.go.jp/kankocho/tax-free/page01_000001_00024.html

By TaxFreeOnline.jp | Sources last checked: October 22, 2026

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