GPT-6.1 Sol · Light · 2026-10-05

Cold outreach is allowed in Japan, but cold email is generally subject to prior consent, with important exceptions for business contacts. There is no blanket exemption simply because your message is business-to-business (B2B). Japan’s main email law is the Act on Regulation of Transmission of Specified Electronic Mail (特定電子メール法). e-Gov 法令検索

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

Outreach situation	Position in Japan	Practical implication
Email to a company address published on its website	An exception generally permits advertising emails to addresses published by organizations or individuals conducting business, unless a refusal notice accompanies the address.	A published `info@company.jp` can be usable. Check for wording such as 「営業メールお断り」 before sending.
Email after receiving a business card	Providing an address directly can fall within an exception to prior consent. The privacy regulator also recognizes that company advertising may be an apparent purpose of business-card exchange.	Follow-up after a genuine exchange is generally possible, but stop if the recipient refuses.
Email to an existing business contact	A transaction relationship is another statutory exception.	An existing relationship can support outreach, but does not override a subsequent refusal.
Guessed, enriched or purchased email address	Finding an address does not itself establish consent or an exception.	Do not assume a verified address from a database is legally sendable. Establish its source and your sending basis.
Advertising SMS	SMS is also covered by the anti-spam framework.	It is not a workaround for email consent rules.

Sources: the statutory exceptions, the Japan Data Communications Association’s explanation, the Personal Information Protection Commission’s business-card guidance, and its SMS reporting guidance. e-Gov 法令検索

Even when an exception permits the email, other requirements still apply. Commercial emails must identify the sender, provide a clear refusal mechanism, include the sender’s address and a complaints/contact channel, and use truthful sender information. Once someone refuses advertising emails, further advertising sends are generally prohibited. Consent-based sending also requires retaining evidence of consent. An unsubscribe option alone does not make an otherwise unauthorized first email lawful. 迷惑メール相談センター

Other channels have different rules:

Channel	What matters
Cold telephone calls	Genuine business-purpose transactions are generally outside the consumer telephone-sales provisions of the Act on Specified Commercial Transactions. Consumer calls face requirements including identifying the caller and sales purpose, and prohibitions on continuing or repeating solicitation after refusal. Merely calling someone a “business customer” does not automatically establish the exemption.
LinkedIn messages	Treat platform rules as an additional constraint. LinkedIn prohibits spam and can restrict accounts for policy violations. A connection acceptance should not be treated as permission to add someone to an external email campaign.
Website contact forms	Follow the recipient’s stated purpose and restrictions. Some companies provide a separate supplier-proposal form. The existence of a form does not establish that sales submissions are welcome.

Personal-data rules are a separate layer. A named employee’s details can remain protected personal information even when publicly available. If you collect them into a prospect database, you must address the applicable requirements, including specifying and notifying or publishing the purpose of use. Public availability is not a general exemption from Japan’s Act on the Protection of Personal Information. ppc.go.jp

How domestic companies deal with it

The evidence supports several approaches, but does not establish what percentage of Japanese companies use each:

Documented approach	Concrete example	Advantage and limitation
Create a contact through exhibitions, then follow up	Writeup’s August 2026 exhibition-follow-up service combines business-card capture, same-day email and next-day telephone follow-up. It explicitly limits emails to people who provided contact details and includes unsubscribe instructions.	Provides a clearer contact basis and conversation context; requires event participation and follow-up resources.
Use dedicated channels for incoming sales proposals	SALES ROBOTICS instructs sellers to use its separate proposal form.	Gives suppliers an accepted route; the seller must respect the recipient’s routing rules.
Reject unsolicited email explicitly	The Japan Data Communications Association recommends displaying a refusal notice alongside a public address.	Removes the public-address exception for unsolicited advertising to that address.

For your B2B outreach, my practical recommendation is to record where each address came from, the consent or exception supporting contact, and any refusal in your customer relationship management (CRM) system. Published business addresses without refusal notices and genuine business-card contacts offer clearer grounds than guessed employee addresses. Keep messages relevant, identify your company fully, provide an easy opt-out, and suppress refusals across future campaigns. This recommendation follows the rules above; it is not evidence that every domestic company operates this way.

GPT-6.1 Sol OpenAI · Light · Work

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