For more than half a century, Japan regulated cannabis based on the part of the plant from which a product was derived. Hemp seeds and stalks were legal; leaves, flowers, and roots were not. This framework — functional for a pre-CBD world — had been straining under the weight of the modern cannabinoid industry for years. On December 12, 2024, it was replaced.
The Core Shift: Plant-Part to Component-Based Regulation
The revised Cannabis Control Act moves from asking "which part of the plant is this?" to asking "what compounds does this product contain, and at what levels?" This is a conceptually significant change, and in practice it means that compliance is now determined by laboratory testing rather than botanical origin documentation.
The most important practical consequence: CBD products with Δ9-THC below 0.3% by dry weight are now legally defined as lawful. This is explicit statutory text for the first time. Previously, the legal status of CBD products depended on a series of administrative guidance documents and MHLW opinions that were technically not binding law.
The New Δ9-THC Residue Limits
The revision introduced mandatory product-specific Δ9-THC residue limits, which came into force immediately on December 12, 2024:
| Product Type | THC Limit | Status |
|---|---|---|
| Oils and powders | ≤ 10 ppm (10 mg/kg) | In force |
| Aqueous / water-soluble solutions | ≤ 0.1 ppm (0.10 mg/kg) | In force |
| All other forms (capsules, gummies, topicals) | ≤ 1 ppm (1 mg/kg) | In force |
Enforcement note: These limits are actively enforced. Japan Customs is conducting THC residue screening on CBD product shipments. Non-compliant products are being seized and destroyed. Overseas CoA documentation is not accepted — Japan-accredited laboratory testing is required.
What Is Now Explicitly Legal
- CBD isolate products (essentially zero THC risk)
- Broad-spectrum CBD products confirmed THC-compliant by Japan-accredited lab
- Full-spectrum CBD products confirmed THC ≤ 10 ppm for oils (or applicable category limit)
- CBD topicals and cosmetics (different regulatory pathway; historically lower barrier)
- CBG products (currently unscheduled; same import pathway as CBD)
What Remains Prohibited
- Δ9-THC as a cannabinoid ingredient above residue limits
- Delta-8 THC products (isomerized THC; considered controlled under revised act)
- CBN products (effective prohibition due to pending designated substance status)
- Products relying solely on overseas laboratory CoA documentation
- Any import without prior MHLW import notification and approval
The Cultivation Licensing System
Effective March 1, 2025 — a second phase of the revision — new cultivation licensing categories were introduced:
- Type 1 License: Cultivation for product raw material (hemp for CBD, fiber, seed)
- Type 2 License: Cultivation for pharmaceutical raw material only (restricted research context)
For international brands importing finished CBD products, the cultivation licensing framework has limited direct relevance — your raw material is cultivated outside Japan. However, brands considering future vertical integration or domestic Japanese cultivation partnerships should understand the Type 1 framework.
Penalties
The revision also increased criminal penalties for THC-related offenses. Possession penalties were increased from a maximum of 5 years to 7 years imprisonment. Import violations involving scheduled cannabinoids (THC above limits, CBN when designated) carry penalties up to 7 years plus significant fines.
Implications for Existing Import Agreements
Brands with existing MHLW import notification approvals issued before December 12, 2024 may need to re-confirm compliance under the new framework. Import notifications approved under the old plant-part framework should be reviewed by a qualified party to confirm they remain valid under component-based regulation. Contact us if you have a pre-existing import notification and are uncertain about its current status.