GPT-6.1 Sol · High · 2026-10-05

Japan permits cold business-to-business (B2B) outreach, but email has specific restrictions. The default is prior consent, with exceptions including publicly disclosed business email addresses, business cards, and qualifying existing business relationships. Being a business recipient does not itself exempt an email from the law. caa.go.jp

The key distinction is how you obtained the contact details and which channel you use.

For email, the main law is the Act on Regulation of Transmission of Specified Electronic Mail, commonly called 特定電子メール法.

Situation	Can you send an unsolicited sales email?
A company publishes its contact email on its website, without an accompanying refusal of advertising emails	Generally yes, under the public-address exception.
The published address has “営業メールお断り” or equivalent wording alongside it	You cannot rely on the public-address exception.
Someone directly gives you their business card containing their email	Generally yes, under the written-address-notification exception, subject to subsequent refusals.
You have a qualifying existing business relationship	Generally yes.
You guess an employee’s address or obtain an unpublished address from a prospecting database	Not automatically permitted. You need consent or another applicable exception; possession of the address is insufficient.

These exceptions come from Article 3 and the government’s guidance. A publicly listed company address does not authorize sending to every employee at that domain. caa.go.jp

Even when an exception permits the email, you still need:

The responsible sender’s name or company name.
A clearly explained way to refuse future emails, using an email address or unsubscribe URL.
Sender address and a contact channel for complaints or inquiries.
Accurate sender information, and cessation of promotional emails after a refusal. 迷惑メール相談センター

A personalized, manually sent pitch does not gain an exemption simply because it is one-to-one. Also, “May I send you information about our service?” is not a universal workaround: government guidance treats emails seeking advertising-email consent as covered messages themselves. caa.go.jp

Other channels work differently:

Channel	Regulatory position
Cold telephone calls	Genuine business-purpose transactions are generally excluded from the consumer telephone-sales provisions of the Specified Commercial Transactions Act. Consumer calls have identification requirements and a prohibition on continuing or repeating solicitation after refusal. no-trouble.caa.go.jp
Website contact forms	Japanese providers actively offer フォーム営業. However, a publicly accessible form is not blanket permission: its purpose, terms, and “no sales” wording matter. Providers themselves instruct users to exclude prohibited targets. 株式会社エンカレッジ
LinkedIn and other ordinary in-app messages	These are generally outside the email/SMS regime, but platform restrictions apply. LinkedIn prohibits unauthorized automated messaging and scraping. salt.iajapan.org
Short Message Service (SMS)	Advertising SMS is covered by the email law. It is not an alternative route around consent requirements. caa.go.jp

There is also a separate privacy layer. Under the Act on the Protection of Personal Information (APPI), identifiable employee information remains personal information even when publicly available. Public availability does not remove obligations concerning use purposes and handling. The Personal Information Protection Commission explicitly recognizes ordinary business-card follow-up for the collecting company’s advertising, while requiring compliance with the email law too. ppc.go.jp

How Japanese companies handle it in practice

These are documented examples, rather than evidence that every domestic company follows the same approach:

Approach	Concrete Japanese example
Email publicly listed business addresses, with opt-out controls	B.O.N’s Reachill, launched September 2026, says it restricts recipients to legally eligible addresses, includes sender and opt-out information, and stops after refusal. 株式会社B.O.Nのプレスリリース
Build email lists from business cards and existing contacts	Rakus’s 配配メール support documentation says many customers use business cards, customer lists, and internal databases, while explaining the consent exceptions. 配配メールサポートサイト
Use contact-form outreach with exclusions	Encourage instructs users to remove companies prohibiting sales approaches, previous stop requests, and duplicate targets. 株式会社エンカレッジ
Explicitly refuse unsolicited email as a recipient	Dai-Ichi Tsushinsha, a Kodansha Group company, publishes its contact email alongside a request not to send sales or other specified advertising emails. 講談社グループ

For your outreach, my practical recommendation: record the source and permission basis for each email address, check refusal wording before sending, include a clear opt-out, and maintain a shared suppression list. Public company inboxes provide a clearer basis for cold email than guessed employee addresses. They may, however, require another step to reach the decision-maker. That last trade-off is a practical assessment, not a statutory rule.

GPT-6.1 Sol OpenAI · High · Work

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