Can a warehouse be registered even if it is a "warehouse that does not operate as a warehouse" or "does not have a completion inspection certificate"?

Updated: July 2024, 7

When registering as a warehouse business, the most important documents to be attached are the ``building confirmation certificate'' and ``completion inspection certificate'' for the commercial warehouse building.

　

The building confirmation certificate is a set of pages 1 to 5 of the building confirmation application form, so please prepare this.

　

What is a commercial warehouse?

A commercial warehouse is a warehouse owned for business purposes to store cargo entrusted to it by third parties and to carry out logistics operations.
In order to protect the interests of cargo owners, the facility is operated in accordance with the Warehousing Business Act established by the Ministry of Land, Infrastructure, Transport and Tourism.
In order to operate a commercial warehouse, you must apply for registration as a warehousing business with the Ministry of Land, Infrastructure, Transport and Tourism; operating without registration is a violation of the law.

The difference between commercial warehouses and private warehouses lies mainly in the purpose of use and the strictness of regulations.
Commercial warehouses must meet conditions deemed sufficient for the safe storage of third-party goods.
In addition, specific standards have been established beyond the requirements for the building itself, such as "appointing a management officer" and "establishing warehouse deposit terms and conditions."
On the other hand, a private warehouse is a warehouse for storing the owner's own belongings and is not subject to the same regulations as a commercial warehouse.
　
There are nine types of commercial warehouses (including storage rooms).

What is a Building Confirmation Certificate and Completion Inspection Certificate?

A Building Confirmation Certificate (Confirmation Certificate under the provisions of Article 6-2 Paragraph 1 of the Building Standards Act) is a certificate that is issued when the plan for a building is examined before construction work begins to see whether it complies with the Building Standards Act and the contents are confirmed.
The building confirmation certificate includes the construction site (installation location or construction location), name of the building, main use, etc.
This is a confirmation of the contents of the building plan, and does not constitute a judgment on the contents of the actual construction.

On the other hand, a completion inspection certificate (inspection certificate under the provisions of Article 7-2, Paragraph 5 of the Building Standards Act) is a certificate issued when the construction work passes an inspection to determine whether it complies with the Building Standards Act at the time of intermediate inspection during construction and completion inspection upon completion of the construction.

To apply for warehousing business registration at a commercial warehouse, you must submit this building confirmation certificate and completion inspection certificate together to the Transportation Bureau.

What is the main use of a building?

The principal use of a building describes the manner in which the building will be used as constructed.
When building a structure, the "principal use of the building" must comply with applicable building codes.

A list of the main uses of buildings isclick hereYou can check it out here (external link).

Can a warehouse that does not operate as a warehouse be registered as a warehouse business?

When applying for registration as a warehousing business, the "Main use of the building" column on the Building Confirmation Certificate must, as a general rule, be marked "Warehouse operating a warehousing business" (code number 08510).

If you check the building confirmation certificate and it says "warehouse operating a warehousing business," then the requirements for the building's main use are met.

On the other hand, if the warehouse is classified differently, such as a "warehouse not engaged in warehousing business" (code number 08520) or a "factory" (code number 08340), the warehouse was built without the intention of using it as a commercial warehouse (for example, to be used as a company warehouse), and therefore an application for warehousing business registration will generally not be approved.
　
However, even if a warehouse was constructed as something other than a "warehouse operating a warehousing business," there are cases where it meets the facility standards required by the Warehouse Business Act.
In this case, it may be possible to register as a warehouse business by changing the use and confirming the opinion of the local government.

Can I register as a warehouse operator even if I don't have a "Completion Inspection Certificate"?

When we receive consultations regarding warehousing business registration, we often come across warehouses that were built during the Showa or early Heisei era that have a building confirmation certificate but no completion inspection certificate.
　
If you have received a completion inspection but have lost your certificate, a certificate may be issued in place of the completion inspection certificate if the municipality has a record of it. , it becomes possible to register as a warehouse business.

However, we often see cases in which warehouses from the same period have not undergone a final inspection in the first place. In this case, if applied strictly, it would be treated as an illegal building, and the Transportation Bureau will not accept registration for warehousing business.
　
Completion inspections can only be applied for within a certain period of time after construction is completed, so it is not possible to undergo a completion inspection as an afterthought when applying for warehousing business registration, and the illegal status of the building cannot be cured.

If it is a warehouse that has not undergone a final inspection, it may be difficult to simply consult with the local government or the transportation bureau, as doing so may lead to the building being recognized as illegal. Masu.

Our track record

We have had cases where our company was ultimately able to register as a warehousing business even in cases where the "Completion Inspection Certificate" described above had been lost, or where the "Completion Inspection" had never been conducted in the first place.

In particular, in the case of the latter, a warehouse that has not undergone a final inspection, consultation with the local government's building inspection department and an architect will be required, and the response will take a long time.

If you are having trouble in such a case, please feel free to contact us.

For applications for warehousing business, please contact Support Administrative Scrivener Corporation

Support Administrative Scrivener Corporation provides application support and consulting services related to the Warehouse Business Act to both those newly registering for warehouse businesses and those who are already registered.

Our staff has a track record of applying in all prefectures across the country. Please contact us by all means.