Source Facts
What happened
On September 29, 2026, the Japan Fair Trade Commission issued a recommendation to Fuji Seisakusho Co., Ltd. (株式会社不二製作所) under the Act on Ensuring Proper Transactions Involving Small and Medium-Sized Subcontractors. The case involved manufacturing work outsourced to 44 small subcontractors and transportation work outsourced to two others. The JFTC identified delayed payment, payment by promissory notes, and the use of electronic recorded monetary claims that did not provide the required economic effect by the payment due date.
Why it matters
The case gives companies operating in Japan a concrete compliance signal on supplier payment practices. The JFTC identified ¥74,973,998 in delayed payments affecting 46 small subcontractors and cited Article 5(1)(ii), which prohibits delayed payment. Companies using Japanese suppliers or subcontractors should therefore review not only contractual payment dates, but also whether the payment method delivers the required economic effect by the statutory deadline.
Who is affected
The recommendation directly concerns Fuji Seisakusho and 46 small subcontractors: 44 engaged for manufacturing work and two engaged for transportation work. It is also relevant to companies that outsource manufacturing or transportation in Japan, particularly those reviewing supplier-payment controls and subcontracting compliance.
What to watch next
Watch Fuji Seisakusho’s implementation of the recommendation, including payment of the remaining delayed amounts and statutory late-payment interest after JFTC confirmation. The case also provides a useful reference point for how the JFTC applies payment-delay rules to promissory notes and electronic recorded monetary claims.
Japan Watchdesk Interpretation
For overseas companies, the practical signal is broader than a single enforcement case. Japan-side supplier due diligence should examine how counterparties actually pay subcontractors, not only what their contracts say. Payment timing, promissory-note use, electronic payment instruments, and controls over the 60-day payment requirement can all become relevant indicators of regulatory and counterparty risk.
Primary Source
- Source organization
- Japan Fair Trade Commission (JFTC)
- Source publication date
- September 29, 2026
- Last verified
- October 2, 2026
- AI summary status
- Human Edited
- Original source
- Open primary source