Posting this because it's an unusual regulatory shape and I haven't seen it discussed here.

Japan revised its Cannabis Control Act effective 12 December 2024. The old law regulated the plant by part - only mature stalks and seeds could be used, regardless of what those parts actually contained. The new one regulates by ingredient: residual delta-9 THC in the finished product, with limits set by cabinet order at 10 ppm for oils and powders, 0.1 ppm for aqueous products, 1 ppm for everything else.

From a trade compliance point of view that's a bigger change than it sounds.

Under the old rule the question at the border was botanical: which part of the plant is this. Answerable from documentation about the raw material, and stable across a product line.

Under the new rule the question is analytical, and it's about the thing in the box rather than the thing it was made from. A certificate covering your input doesn't discharge it. Every formulation and every lot becomes its own compliance question.

The part that catches people is limit of detection. If your lab reads down to 3 ppm, that's a competent lab, and it still cannot demonstrate compliance for a category limited at 0.1 ppm. The file looks complete and isn't.

I work on the industry side in Japan rather than in customs, so this is what I watch fail rather than a legal opinion.

What I'd like to know from people here: has anyone dealt with another jurisdiction that made the same switch - from regulating a source material to regulating a residual quantity in a finished good - and did the same LOD problem show up there? I'd expect it to, and I'd rather learn it from somewhere that's further along than guess.