What's the cold outreach regulations in Japan? and how do domestic companies deal with it?
Cold outreach regulations in Japan and domestic company practices
Prompt
A
- Model
- GPT-6.1 Sol
- Effort
- High
- Operator
- OpenAI
- Mode
- Work
- Search type
- Web Search
- Run date
- Oct 5, 2026
- Pack
- None
- Content language
- English
Output
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| You guess an employee’s address or obtain an unpublished address from a prospecting database | Not automatically permitted.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.
B
- Model
- GPT-6.1 Sol
- Effort
- Light
- Operator
- OpenAI
- Mode
- Work
- Search type
- Not recorded
- Run date
- Oct 5, 2026
- Pack
- None
- Content language
- English
Output
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.
- Model
- GPT-6.1 Sol
- Effort
- High
- Operator
- OpenAI
- Mode
- Work
- Search type
- Web Search
- Run date
- Oct 5, 2026
- Pack
- None
- Content language
- English
Output
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.
- Model
- GPT-6.1 Sol
- Effort
- Light
- Operator
- OpenAI
- Mode
- Work
- Search type
- Not recorded
- Run date
- Oct 5, 2026
- Pack
- None
- Content language
- English
Output
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.
- Model
- GPT-6.1 Sol
- Effort
- Ultra
- Operator
- OpenAI
- Mode
- Work
- Search type
- Not recorded
- Run date
- Oct 5, 2026
- Pack
- None
- Content language
- English
Output
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
- Model
- GPT-6.1 Sol
- Effort
- High
- Operator
- OpenAI
- Mode
- Work
- Search type
- Web Search
- Run date
- Oct 5, 2026
- Pack
- None
- Content language
- English
Output
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.
- Model
- GPT-6.1 Sol
- Effort
- Light
- Operator
- OpenAI
- Mode
- Work
- Search type
- Not recorded
- Run date
- Oct 5, 2026
- Pack
- None
- Content language
- English
Output
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.
- Model
- GPT-6.1 Sol
- Effort
- Ultra
- Operator
- OpenAI
- Mode
- Work
- Search type
- Not recorded
- Run date
- Oct 5, 2026
- Pack
- None
- Content language
- English
Output
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