GPT-6.1 Sol · Ultra · 2026-10-05

Cold outreach is possible in Japan, including business-to-business (B2B) sales. But there is no blanket B2B exemption from the email rules. The key is whether you have consent or qualify for a specific exception. e-Gov 法令検索

For email, the main law is the Act on Regulation of Transmission of Specified Electronic Mail (特定電子メール法). Promotional email generally requires prior opt-in. A personalized sales pitch does not automatically escape the rules. caa.go.jp

Situation	Position under the email law
A company publicly lists its business email address online, such as `info@company.jp`	Can qualify for the exception allowing unsolicited promotional email.
The published address has “営業メールお断り”, or another clear refusal of advertising email	The public-address exception does not apply. 迷惑メール相談センター
You guess an employee’s address, buy it, or obtain it through enrichment	That alone establishes neither consent nor an exception. You need a separate qualifying basis. e-Gov 法令検索
The recipient directly gives you their email address on a business card	Can qualify for an exception, subject to refusal handling. caa.go.jp
You have an existing transaction relationship	Can qualify. A single past purchase does not necessarily establish the required relationship. caa.go.jp
The recipient tells you to stop	Further promotional email against that request is prohibited, including when your initial email qualified for an exception. e-Gov 法令検索

The public-address exception in the first row is expressly explained by Japan’s official spam consultation center. 迷惑メール相談センター

Even when an exception applies, promotional emails need the responsible sender’s identity, an accessible opt-out email address or URL, clear opt-out wording, and required address/contact information. An unsubscribe link does not, by itself, authorize the first email. Consent-based sending also requires retaining evidence of consent. Overseas promotional emails arriving in Japan are covered too. caa.go.jp

Other channels differ:

B2B cold calls: Genuine business-purpose contracts are generally excluded from the Specified Commercial Transactions Act’s consumer telemarketing provisions. Calling someone at work does not automatically make a consumer sale B2B.
Consumer telemarketing: Disclose the company, caller, product/service type and sales purpose before solicitation. Continuing or repeating solicitation after refusal is prohibited. no-trouble.caa.go.jp
LinkedIn messages: In-platform messaging is generally distinct from conventional email, but platform restrictions apply. LinkedIn expressly treats excessive, irrelevant or repetitive messages as spam. 内閣府

There is also a separate privacy layer: named contacts and identifiable work email addresses can be personal information under the Act on the Protection of Personal Information (APPI), even when publicly available. Public availability does not remove privacy obligations. ppc.go.jp

Japanese companies use several documented approaches:

Approach	Concrete domestic example
Obtain permission before mailing existing contacts	Chiba Television consulted counsel about reusing business-card data. Its December 2021 case study describes approximately 30,000 recorded cards, but initial mailing to approximately 10,000 customers whose permission sales staff had obtained. マーケティングオートメーションツール SATORI
Nurture business-card and customer lists	JoB-up describes weekly emails followed by individualized outreach based on website activity. The case documents its workflow; it does not establish every recipient’s legal basis. bow-now.jp
Combine phone prospecting and contact-form sales	GC Story used Sales Marker’s form submissions and outsourced appointment-setting calls for customer development. 株式会社Sales Marker(セールスマーカー)
Build refusal controls into form outreach	Smart Kaitaku says it excludes forms marked “営業お断り,” includes suppression links, and avoids resending to the same company for one month. That interval is its operating policy, rather than a statutory permission to resend. smartkaitaku.com

Contact-form sales exists commercially, but I found no official blanket ruling that every form submission is lawful. A vendor offering it is not sufficient legal assurance.

For your HubSpot setup, there is an additional constraint: its February 2026 anti-spam policy requires express, verifiable consent through a documented opt-in process, with limited exceptions. An email may qualify under Japan’s public-address exception yet still breach HubSpot’s sending policy. legal.hubspot.com

GPT-6.1 Sol OpenAI · Ultra · Work

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