JFTC Recommendation Over Unpaid Storage of Printing Plates; Industry Asked to Review the CustomLeaving things with a supplier for free was found to break the rules
On October 22, 2026 (Reiwa 8), the Japan Fair Trade Commission (JFTC) issued a recommendation to Oji Container Co., Ltd. (capital JPY 10 billion), which manufactures and sells corrugated cardboard and paper container products. The JFTC found that the company had 140 subcontractors store a total of 9,610 printing plates and similar items free of charge, in breach of Article 4(2)(iii) of the Subcontract Act as it stood before the amendment (prohibition of unjust requests for economic benefits), and issued the recommendation under Article 7(3) of the same Act. On the same day it also asked the National Federation of Corrugated Cardboard Industry Associations to review the custom of unpaid storage.
- ○Applies: You pay the costs needed for storage when you ask a supplier to store items
- ○Applies: You review periodically whether storage is still needed, and take back or dispose of items you no longer need
- ○Applies: The storage request and who bears the cost are agreed in writing
- ×Does not apply: You keep having items stored free of charge even though you have not placed orders for a long time
- ×Does not apply: You continue unpaid storage simply because it is the industry custom
Key points
- The conduct ran from June 1, 2024 to November 26, 2025; the company had subcontractors keep the printing plates even during long periods in which it placed no orders
- 140 subcontractors were affected, and the items stored totalled 9,610 printing plates and similar tooling
- Oji Container paid JPY 3,410,355, an amount including part of the disadvantage caused, and had paid 127 of the 140 subcontractors by July 2026 (Reiwa 8); the recommendation requires it to pay the remaining amount promptly after confirmation by the JFTC
- The JFTC has issued two recommendations in the past year for Subcontract Act breaches involving unpaid storage of printing plates, and states that unpaid storage had become a custom in the industry
- The request to the federation has three parts: circulating a leaflet on the violation cases within the industry, urging member companies to correct and prevent breaches of the Act on Appropriate Transactions with SME Contractors and to comply with laws on price pass-through, and reviewing the unpaid storage custom with continuing follow-up
What to do in practice
- Draw up a list of the molds, patterns and printing plates held at suppliers and check whether orders have been placed recently
- For items with no orders for a long time, agree with the supplier whether storage should continue and whether storage costs will be paid
- Record the storage request and who bears the cost in writing, such as a master agreement or a memorandum
Corrugated boxes are printed using tools called plates. An ordering company left its plates with small subcontracting firms and kept them there for a long time without placing orders, and without paying anything for the storage space. Japan's Fair Trade Commission found that this breaks the rules and told the company to fix it. On the same day it asked the industry group to review the custom of free storage.
Points
- Keeping tools such as plates takes storage space and effort
- Making someone keep them for free while no orders come for a long time breaks the rules
- The ordering company was told to pay for the storage it had been given
What the words mean
- Subcontracting
- Taking orders from another company to make goods or do work
- Recommendation
- An official notice from a government body saying the rules were broken and must be fixed
- Japan Fair Trade Commission (JFTC): JFTC: Recommendation to Oji Container Co., Ltd. (October 22, 2026 (Reiwa 8))
- Japan Fair Trade Commission (JFTC): JFTC: Request to the National Federation of Corrugated Cardboard Industry Associations (October 22, 2026 (Reiwa 8))
This article summarizes and explains materials published by government agencies and is not advice on any individual case. Rules can change, so for actual procedures and decisions always check the latest original materials and consult professionals such as tax accountants or labor and social security attorneys. English, Simplified Chinese and Traditional Chinese versions are translations prepared from the Japanese articles for convenience. If anything differs, the Japanese text and the original source take precedence.