JUMVEA vs. Port Unions: The Future of Used Car Exports Amid Radiation Inspection Disputes

I. Executive Summary

Japan’s used car export industry is facing a serious impasse regarding the radiation inspection requirements that have been in place since the 2011 Fukushima Daiichi nuclear disaster. Despite more than a decade having passed, and despite scientific evidence and judicial rulings denying the necessity of such inspections, they continue based on agreements between port operators and labor unions. This situation has escalated into a high-stakes confrontation—described as a “game of chicken”—between the Japan Used Motor Vehicle Exporters Association (JUMVEA) and port labor unions.

JUMVEA has decided that, starting from July 2025, it will take legal action—including claims for damages and civil lawsuits—if customs brokers or port operators (including labor unions) refuse to accept or transport uninspected vehicles. This firm stance reflects JUMVEA’s strong determination to eliminate what it considers an unjust burden, especially in light of the government’s request for a “de facto abolition” of the inspections, which lacks legal enforceability. The implementation of these legal measures could lead to widespread operational disruptions and unforeseen circumstances at ports across Japan after July, raising serious concerns about the smooth operation of the country’s vital used car export industry.

II. Historical Background: The Origins of Radiation Inspections

Impact of the Fukushima Daiichi Nuclear Power Plant Accident on Used Car Exports

The Great East Japan Earthquake and tsunami that struck on March 11, 2011, triggered an accident at the Tokyo Electric Power Company’s Fukushima Daiichi Nuclear Power Plant, releasing radioactive materials into the environment. This radioactive contamination had a wide-ranging impact on various Japanese products exported overseas, including food and transportation equipment such as automobiles.

A particularly decisive incident occurred on June 29, 2011, when a high radiation level of 62.60 microsieverts per hour (μSv/h) was detected from a used vehicle scheduled for export at the cargo handling area of the Kawasaki Port Higashi-Ogishima international terminal. The vehicle in question is believed to have been contaminated in Fukushima and happened to be discovered at the port by chance. This event directly triggered the implementation of radiation inspections. Within Japan, high levels of radiation were also detected from vehicles deregistered in Fukushima Prefecture, raising concerns about their circulation within the domestic market as well.

Establishment of Mandatory Inspections by Port Operators and Labor Unions

Following the detection of high radiation levels at Kawasaki Port, the Japan Harbor Transportation Association (JHTA) effectively mandated radiation inspections by requesting that exporters carry them out. This requirement was driven more by the need to ensure safety at ports—especially Kawasaki Port—than by demands from importing countries.

In August 2011, an “Interim Confirmation Document” was signed between the JHTA, the All Japan Dockworkers' Union (Zenkanwan), and the Japan Federation of Harbor Transportation Workers' Unions (Koun Domei). This agreement stipulated that all used cars and used construction equipment for export would be subject to full-scale radiation inspections, with the inspection costs to be borne by the consignors. By September of the same year, this measure was extended to used vehicles shipped domestically as well.

The introduction of these inspections was a response to the immediate sense of crisis at the time and concerns for the health and safety of port workers. However, what was initially described as a “temporary” measure has continued for more than a decade. The emergency inspections introduced during the crisis became entrenched as an industry practice in the port sector, despite subsequent changes in circumstances. This reflects a broader issue in policymaking, where emergency measures introduced during crises are not adjusted or discontinued in response to evolving conditions, instead persisting as permanent policies.

Initial Compensation Mechanism by TEPCO

Initially, Tokyo Electric Power Company Holdings (TEPCO HD) compensated radiation inspection costs for export vehicles upon application. This compensation was based on guidance issued by the Ministry of Economy, Trade and Industry (METI) at the time.

However, the compensation system had its flaws. Companies that entered the used car export business after the accident were excluded from eligibility, resulting in an unfair situation. Furthermore, land transport companies shipping vehicles for domestic use received no compensation from TEPCO. For example, Zero Co., Ltd., Japan’s largest vehicle transport company, bore annual costs of approximately 200 million yen.

JUMVEA also negotiated with TEPCO in cases where vehicles exported to Russia were returned to Japan due to radiation levels, and succeeded in securing compensation for shipping fees, reinspection costs, and lost profits.

While TEPCO’s compensation functioned as a temporary relief measure for the direct effects of the disaster, its limited scope and lack of clear legal foundation led to market distortions in the long term. Since compensation was available only to some businesses, the economic burden of inspection costs effectively became an “invisible tax” borne by the entire industry. This created a barrier to entry for new participants in particular.

III. Current Situation: Stakeholder Positions and the Changing Reality

Reduced Risk: Scientific Consensus on Current Radiation Detection Rates and Health Risks

More than 13 years have passed since the Fukushima nuclear accident, and the radiation detection status of used cars subject to inspection has changed significantly. At major ports—particularly Kawasaki Port—the detection of high radiation levels (5.0 μSv/h or more) has dramatically decreased. Since July 2014, despite 3,000 to 4,000 used cars being inspected weekly at Kawasaki Port, there have been no detections exceeding the reporting threshold. Furthermore, the publication of high-radiation vehicle cases at ports nationwide has ceased since 2019.

From a scientific perspective, exposure to radiation at 20 mSv/year does not cause immediate health effects, and radiation doses below 100 mSv/year are not statistically associated with increased cancer mortality risk. The estimated annual exposure dose for port inspectors is as low as 0.6 mSv/year. As of December 2011, the courts ruled that port workers were not exposed to radiation at levels that would affect their health, and that the necessity and reasonableness of inspecting all used vehicles for radiation had significantly diminished.

Despite such objective data and scientific findings, the continued insistence by port labor unions on maintaining inspections suggests a large gap between objective scientific risk assessment and subjective risk perception. The unions’ stance is believed to be rooted not only in current low-risk data, but also in concerns about long-term health effects similar to asbestos exposure, and a strong sense of responsibility for ensuring worker safety. This situation highlights the complexity of trust and anxiety, which cannot be resolved by presenting data and facts alone.

JUMVEA’s Position: Calls for Abolishing the Inspections

Led by Chairman Hiroshi Sato, JUMVEA strongly argues that continued radiation inspections are “meaningless” and calls for their abolition. Their key assertions are as follows:

• Lack of Health Risk: In past court rulings, it was determined that the radiation levels of export vehicles did not pose health risks to port workers. Based on this and the current low detection rates, JUMVEA asserts that inspections are unnecessary.
• Absence of Foreign Demand: JUMVEA clearly states that most major importing countries of used vehicles from Japan do not require radiation inspections or certificates. As international trends show, the European Union completely lifted import restrictions on Japanese food products last year, indicating a decline in global concern over Japan’s radiation issues. However, there are still countries like Egypt, where despite regulatory easing, vehicles with high radiation levels are effectively non-exportable.
• Unfair Cost Burden: Inspection costs vary between 700 and 1,500 yen per vehicle, and with approximately 1.7 million vehicles exported annually, the total cost is estimated to reach around 2.5 billion yen. JUMVEA argues that this cost—amounting to several billion yen per year—is an unfair burden imposed solely on the industry. Based on the Ministry of Land, Infrastructure, Transport and Tourism’s guideline stating that “those who require the inspections should bear the cost,” JUMVEA contends that if inspections are to continue, the labor unions or employing companies should be responsible for the expenses.
• Misconception That Inspections Are Mandatory: Although it is legally possible to export used vehicles without conducting radiation inspections, a widespread misunderstanding persists that inspections are a required precondition for export.
• Claim of Antitrust Violation: JUMVEA, through its legal representatives, has conveyed that the refusal by port operators influenced by labor unions to transport uninspected vehicles constitutes a violation of Japan’s Antimonopoly Act.

JUMVEA’s claims are deeply rooted in economic rationality and legal legitimacy. They view the current situation—where inspections are no longer scientifically necessary nor aligned with international trade practices, yet continue to impose a multi-billion-yen burden on the industry—as a major factor hindering competitiveness. This financial burden is a central motivation behind JUMVEA’s decision to resort to strong legal measures.

Position of the Port Labor Unions: Justification for Continued Inspections

The All Japan Dockworkers' Union (Zenkanwan) strongly insists on the continuation of radiation inspections for used cars, firmly maintaining its stance of prioritizing the safety of its members.

• Ensuring Worker Safety: The union clearly states that “the safety of union members takes precedence over cost or inconvenience” and asserts that inspections should continue until the Fukushima Daiichi nuclear plant is fully decommissioned and evacuation zones are completely lifted, eliminating related societal concerns.
• Long-Term Health Concerns: The union expresses concern that the effects of radiation exposure may take a long time to manifest and could become “the second asbestos,” likening it to the damage caused by asbestos exposure. Thus, inspections are positioned as a “self-defense measure” for union members.
• Unchanging Policy: Despite the government’s request for “de facto abolition” and repeated petitions from JUMVEA, the labor unions have shown no intention of changing their position, stating clearly that “the basic policy remains unchanged.”

This unwavering stance by the labor unions is believed to be driven by deep concerns for workers’ health and safety, going beyond current scientific data or judicial decisions. For the unions, radiation inspections are not merely procedural requirements but an essential safeguard for protecting the future health of their members. This belief serves as the source of their resistance to economic rationality and external demands. Their position underscores the complex challenge of balancing objective risk assessments with subjective anxieties and the lessons of past industrial disasters.

Government’s Role: Request for “De Facto Abolition” and Limited Legal Enforcement

The Japanese government, through the Ministry of Economy, Trade and Industry (METI) and the Ministry of Land, Infrastructure, Transport and Tourism (MLIT), has taken steps toward the “de facto abolition” of radiation inspections for used vehicles scheduled for shipment. In January 2025, both ministries issued a “notification request” to related organizations regarding the handling of these inspections.

This request by the government is based on two main justifications:

• No Detection of High-Radiation Used Vehicles: Recent radiation measurement data at ports has not confirmed the presence of used vehicles with high radiation levels.
• Civil Court Ruling: A finalized ruling by the Tokyo High Court in September 2017 stated that, from a scientific perspective, health risks to port workers were unlikely and that “there is no need to inspect all used vehicles for radiation.”

However, this government request has a critical limitation: it is not based on any specific legal statute. Instead, it was issued in line with the “Basic Policy for Reconstruction” approved by the Cabinet in March 2024, which includes efforts to dispel reputational damage. As such, it lacks direct legal enforceability. Since the inspections originally began as a private agreement between port operators and labor unions, the government faces difficulty in unilaterally enforcing their abolition.

As a result, the government currently remains a bystander in what has become a “game of chicken.” Nevertheless, if this situation is left unresolved and widespread disruption occurs at the ports, the government—including the MLIT, which oversees port operations—may ultimately be held responsible. This indirect intervention reflects a cautious approach aimed at avoiding direct confrontation with powerful labor unions while supporting the industry's stance, but it also reveals the limits of governmental authority.

IV. Legal Framework and Judicial Precedents

Judicial Rulings: Key Court Decisions on the Necessity and Reasonableness of Inspections to Ensure Worker Safety

Judicial decisions regarding the necessity of radiation inspections for used cars have served as important precedents. In a lawsuit filed by Zero Co., Ltd., Japan’s largest land vehicle transporter, against Tokyo Electric Power Company Holdings (TEPCO HD), the Tokyo District Court (March 2017) and Tokyo High Court (September 2017, finalized) rendered significant judgments on the necessity of the inspections.

Although Zero’s claim for compensation was dismissed, the courts clearly stated that, based on scientific knowledge, “it cannot be recognized that port workers are exposed to radiation at levels that affect their health, and it is not possible to acknowledge the necessity or reasonableness of inspecting all vehicles.” Furthermore, the courts pointed out that by December 2011, the justification for inspecting all used vehicles destined for maritime transport—namely, to alleviate concerns about health risks—had already largely diminished, and that the very nature of the inspection system should be reconsidered.

This finalized ruling provides a highly compelling legal basis for JUMVEA’s demand for the abolition of inspections. The fact that the court, based on scientific evidence, denied the necessity of the inspections serves as an objective counterargument to the labor unions’ justification of “protecting worker safety.” This judgment poses a significant challenge to the unions’ claims for the legitimacy of continuing inspections and is expected to play a central role in any future lawsuits brought by JUMVEA arguing that port operators’ refusal to transport uninspected vehicles is unlawful. In effect, this ruling legally validates the industry’s position and increases the legal risks for port-side actors who continue inspections contrary to the court’s findings.

Implications Under Competition Law: JUMVEA’s Assertion of Antitrust Violations by Port Operators and Labor Unions

JUMVEA argues that the refusal by port operators—under the influence of labor unions—to transport uninspected vehicles violates Japan’s Antimonopoly Act. This claim centers on the restriction of competition in port transport services.

The Antimonopoly Act mainly prohibits (1) private monopolization, (2) unreasonable restraint of trade (including cartels and bid-rigging), (3) unfair trade practices, and (4) restrictive conduct by trade associations. JUMVEA’s assertions may fall under the following provisions:

• Unreasonable Restraint of Trade: The law prohibits acts by enterprises or members of a trade association that substantially restrict competition through mutual coordination. If port transport operators uniformly require inspections and refuse to transport uninspected vehicles, this could be interpreted as a restriction of competition in the used car export market and as a barrier to new market entrants. Especially if there is an agreement to limit inspections to “designated institutions,” this could further constrain competition.
• Abuse of Superior Bargaining Position: Port transport services are public in nature and are provided by a limited number of operators, who may be viewed as holding a superior bargaining position over exporters. Forcing inspections that lack scientific justification and imposing the costs on exporters may constitute an unfair trade practice—specifically, an abuse of superior bargaining position.
• Regulations on Trade Associations: Article 8 of the Antimonopoly Act prohibits trade associations from substantially restricting competition or unfairly limiting the activities of their members. The agreement between port associations and labor unions may be in violation of these regulations.
  

In the past, Japan’s port transport industry has faced antitrust concerns over entry restrictions and price-setting. Therefore, there is precedent that supports JUMVEA’s position. By asserting antitrust violations, JUMVEA is not merely contesting the necessity of inspections, but is strategically addressing the structural issues of the port transport market, thereby challenging the legal legitimacy of the inspection system itself. As a result, this dispute extends beyond the issue of cost burden and evolves into a broader legal and policy issue—namely, ensuring a fair competitive environment.

Port Transportation Business Act: Provisions on Refusal of Transport and Their Applicability

In the port transportation business, the terms and conditions of carriage contracts specify the conditions under which transport operators may refuse to accept cargo. For example, in the standard transportation terms used by companies like Nippon Express and Sumitomo Warehouse, transport may generally be refused under the following circumstances:

• When the application does not conform to the transportation terms and conditions
• When the consignor demands an extraordinary burden
• When the transport violates laws and regulations, public order, or good morals

If, starting in July, JUMVEA refuses to pay inspection fees and the port side declines to transport uninspected vehicles, the legal validity of this "refusal of transport" will be brought into question. Port labor unions may argue that transporting uninspected vehicles contradicts “worker safety” or “public order.” However, in light of the 2017 finalized Tokyo High Court ruling, which denied the necessity of inspections from a scientific standpoint, it is highly doubtful whether such claims by the unions would be recognized as “just cause.”

This legal issue raises fundamental questions about the scope of safety assurance in port transportation and the extent to which private agreements can influence public judicial decisions and economic activity. The court will be required to assess, from multiple perspectives, the legitimacy of ensuring worker safety, the reasonableness and necessity of obligations imposed for that purpose, and whether such requirements might violate the Antimonopoly Act. This dispute presents a broader question within the legal framework of port transportation: how to balance the rights of labor with the need for operational efficiency in the industry.

Table 3: Summary of Key Court Rulings on the Necessity of Inspections and Worker Safety

Court / Date	Case / Parties Involved	Main Judgment on the Necessity of Inspections	Basis for Judgment (Scientific Evidence, Detection Rates, etc.)
Tokyo District Court (Mar 2017) / Tokyo High Court (Sep 2017, Final Ruling)	Zero Co., Ltd. vs. TEPCO Holdings	The court ruled: “It cannot be recognized that port workers are exposed to radiation levels affecting health. Therefore, the necessity and reasonableness of inspecting all used vehicles cannot be acknowledged.”	Based on scientific knowledge: exposure of 20 mSv/year is unlikely to cause immediate health effects; under 100 mSv/year, no statistically significant increase in cancer mortality risk. High-radiation vehicle detection at major ports was extremely rare.
Tokyo High Court (Sep 2017, Final Ruling)	Zero Co., Ltd. vs. TEPCO Holdings	The court noted that as of December 2011, the necessity and reasonableness of full inspections aimed at eliminating health concerns had "to a considerable extent already been lost." It implied that the inspection system itself should have been reconsidered.	About four months after inspections began, it became clear that port workers were not being exposed to harmful levels of radiation.

V. JUMVEA’s Imminent Legal Action: Damage Claims and Litigation Starting from July

Nature of the Legal Action: Details of Civil Lawsuits and Damage Claims

The Japan Used Motor Vehicle Exporters Association (JUMVEA), at its board meeting on May 28, 2025, officially resolved that it would seek damages and, if necessary, file civil lawsuits if, starting in July, customs brokers or port operators (including labor unions) refuse to accept or transport uninspected vehicles. Notification of this decision has already begun to be sent to relevant parties.

This legal escalation is a direct countermeasure against the continued insistence by port labor unions on maintaining inspections, despite JUMVEA and the Japan Land Transport Association having declared their refusal to pay inspection fees from July onward. It reflects JUMVEA’s determination to resolve the issue through legal means, after negotiations and appeals to the government proved ineffective. This move goes beyond the scope of negotiation, escalating the dispute into a direct legal confrontation.

Legal Grounds for Claims: Breach of Contract, Business Interference, and Unfair Trade Practices

JUMVEA's legal claims are expected to be based on multiple legal theories:

• Breach of Contract: If port or customs operators refuse to transport or accept vehicles due to unpaid inspection fees, this may be argued as a breach of existing transport or storage contracts.
• Business Interference (Tort): Refusal to transport vehicles at ports may be considered an act of unjustly obstructing the business activities of used car exporters, thus providing grounds for damage claims based on tortious interference. The declaration by customs brokers that they would refuse to accept uninspected vehicles into bonded warehouses is a direct cause of such interference.
• Damages Based on Antimonopoly Law Violations: As previously mentioned, JUMVEA claims that the actions of the port side violate the Antimonopoly Act. If this claim is upheld, JUMVEA may also seek damages resulting from such violations. This argument targets not only the necessity of the inspections but also the restrictive conduct in the port transportation market itself.

By combining these multiple legal bases into one comprehensive lawsuit, JUMVEA likely aims to maximize pressure on the port side and push for a swift resolution to the dispute.

Types of Damages: Lost Profits, Re-inspection Costs, Additional Transport Costs, and More

The types of damages JUMVEA may claim through litigation are wide-ranging. Drawing reference from past compensation cases involving TEPCO, the following categories are anticipated:

• Lost Profits: Profits lost due to refusal or delays in transport, such as export cancellations or missed sales opportunities.
• Re-inspection Costs: Costs incurred for re-inspecting or decontaminating vehicles that were refused transport.
• Additional Transport Costs: Additional expenses to move vehicles stranded at ports to alternative facilities or to arrange substitute transportation.
• Storage Fees and Demurrage: Charges resulting from vehicles remaining at the port or bonded warehouses, or costs due to delays in vessel departure.
• Other Related Expenses: Legal fees for dispute resolution, administrative costs, and related expenditures.

These damages demonstrate the direct and wide-ranging economic impact that transport refusal can have on used car exporters’ business operations. JUMVEA intends to quantify these damages and establish causation in court to win appropriate compensation.

Comparison with Past Compensation Cases: Differences from TEPCO’s Post-Accident Damages

The damages that JUMVEA is now seeking differ significantly in nature from the compensation provided by Tokyo Electric Power Company (TEPCO) immediately following the Fukushima nuclear accident.

• TEPCO Compensation: The compensation TEPCO previously provided was primarily for direct damages resulting from the nuclear accident itself. These included the loss of property value for vehicles within the designated exclusion zones, shipping costs for export vehicles returned due to exceeding radiation limits, re-inspection expenses, and lost profits. These claims were typically resolved through settlements and addressed damages caused by a single, identifiable incident.
• JUMVEA’s Current Claims: In contrast, JUMVEA’s current legal action targets not direct damage from the nuclear accident, but rather the ongoing commercial losses caused by the continuation of what it views as an unjust and competition-restricting inspection system—and by the resulting refusal to transport vehicles. This represents a fundamental shift in the nature of the dispute—from disaster-related compensation to a commercial legal conflict over contractual breaches, tortious interference, and competition law violations in ongoing business operations. The lawsuit takes on broader implications, challenging long-standing practices in port logistics and questioning their legal and economic legitimacy.

VI. Economic and International Impact

Economic Burden: Annual Inspection Costs and Their Impact on the Export Industry

The ongoing radiation inspections impose a massive economic burden on Japan’s used car export industry, totaling several billions of yen annually.

• Scale of Inspection Costs: Inspection fees range from approximately 700 to 1,500 yen per vehicle. Given that about 1.7 million used vehicles are exported annually, the total annual cost is estimated at roughly 2.5 billion yen.
• Burden Bearers: These costs are primarily borne by used car exporters and land transport companies. For instance, major transport company Zero reportedly bears 200 million yen in annual expenses.
• Unfair Compensation: Although there is a TEPCO-funded reimbursement program for inspection fees, it does not apply to companies that entered the used car export business after the disaster, creating an unfair situation.

These substantial costs persist despite the dramatic decline in high-radiation vehicle detection rates and judicial rulings questioning the necessity of inspections. As such, they are squeezing profit margins and undermining the international competitiveness of the industry. This financial burden is a major motivation for JUMVEA’s legal action and highlights how the inspection regime effectively functions as a de facto “export tax.”

Operational Disruption: Risk of Port Chaos, Delays, and Logistical Complications

With JUMVEA and the Japan Land Transport Association publicly refusing to pay inspection fees from July onward, and labor unions showing no sign of backing down, the likelihood of severe operational disruptions at ports across Japan is extremely high.

• Refusal of Transport and Entry into Bonded Warehouses: If the union's stance remains unchanged, most customs brokers involved in export processing have stated they will refuse to allow vehicles into bonded warehouses unless inspection fees are paid. As a result, vehicles without “inspection completed” stickers will be stranded at ports.
• Emergence of “Unforeseen Circumstances”: It is now considered inevitable that “unforeseen incidents will occur across the country” starting in July, potentially leading to widespread port disruptions and logistical paralysis.
• Expansion of Economic Losses: Vehicle congestion may result in storage fees, export delays, breach of contracts, and even a loss of international credibility—creating a chain reaction of economic damage.

This "game of chicken" goes far beyond a mere industry conflict and poses a potential crisis that could affect Japan’s entire trade logistics infrastructure. The paralysis of port functions would not only impact the used car export industry, but also related sectors such as land transport, customs clearance, and the broader international supply chain.

International Trade Perspective: Radiation Regulations in Major Used Car Importing Countries and Relevant WTO Dispute Cases

While JUMVEA asserts that most importing countries do not require radiation inspections for used vehicle imports from Japan, the reality of international radiation regulations is more nuanced, with certain countries maintaining independent standards or expressing continued concern.

• General Trend:
  Many major importing countries of used Japanese vehicles do not mandate radiation inspections. Regulations typically focus on vehicle year, steering wheel position, emissions standards, and odometer tampering prevention.
• Country-Specific Examples:
  Egypt: Though Egypt implemented an import ban on Japanese products in April 2011, it has since relaxed these restrictions. However, used vehicles with high radiation levels are effectively unexportable to the country.
  Russia: In 2013, Russia refused entry to more than 130 used vehicles from Japan due to radiation concerns and stated in 2014 that strict monitoring would continue. Russia’s radiation threshold is 0.3 μSv. Nevertheless, Russia remains a key market with strong demand for Japanese used vehicles.
  Mongolia: Mongolia explicitly mandates radiation testing for imported used cars from Japan, with a threshold set at 0.25 μSv—stricter than Russia’s standard.
  New Zealand: As of May 2021, New Zealand simplified quarantine inspections for used Japanese vehicles from full inspection to sampling. However, it has not explicitly referenced radiation-related import restrictions.
  African Nations (e.g., Kenya, South Africa): Kenya’s regulations focus on emissions standards and odometer verification, with no explicit radiation controls. South Africa effectively bans used vehicle imports for commercial use, with most imports intended for re-export to third countries.
• WTO Dispute Resolution Case:
  Korea’s Import Restrictions on Japanese Seafood (DS495): A relevant precedent is the WTO dispute involving Korea’s import restrictions on Japanese seafood following the Fukushima accident. Although the WTO Appellate Body did not issue a definitive ruling on the WTO-consistency of Korea’s measures, the panel’s finding—that radiation levels in Japanese food were below international standards—was left uncontested. This case highlights the international expectation that trade barriers justified on health and safety grounds must be scientifically substantiated.

From an international standpoint, JUMVEA’s argument that “importing countries do not require inspections” should be understood in the context of Japan’s domestic practice of “mandatory full inspection.” This does not contradict the fact that some countries have independently implemented radiation-related import controls. Additionally, there is growing concern that this domestic dispute may damage Japan’s trade credibility and international reputation. The government’s “hands-off” stance could also impact how the international community evaluates Japan’s regulatory and crisis management posture.

Table 4: Overview of Radiation-Related Import Regulations in Major Used Car Importing Countries

Importing Country	Radiation-Related Regulations / Concerns (if any)	Other Relevant Import Regulations (e.g., model year, steering wheel position)	Import Status from Japan
Egypt	Enforced a ban on Japanese products in April 2011 (currently relaxed). Vehicles with high radiation levels remain effectively unexportable.	Multiple requirements (see Annex Tables 2 and 3).	Even after deregulation, exporting high-radiation vehicles remains difficult.
Russia	Over 130 vehicles were denied entry in 2013 due to radiation; strict monitoring continued in 2014. Radiation limit set at 0.3 μSv.	Left-hand drive; no official age limit (under 60 months recommended).	Strong and persistent demand continues.
Mongolia	Radiation inspection is explicitly required for used vehicles imported from Japan. Limit set at 0.25 μSv.	Primarily right-hand drive; recommended engine size under 2500cc.	Over 3,000 units exported monthly.
New Zealand	No explicit mention of radiation-related restrictions.	Safety and emissions standards, proof of ownership, odometer tampering prohibition; no age limit.	As of May 2021, quarantine inspection shifted from full to sample testing.
Kenya	No explicit mention of radiation-related restrictions.	Age limit (within 15 years), right-hand drive, odometer verification, emissions standards.	Imports remain stable.
South Africa	No explicit mention of radiation-related restrictions.	Commercial used car imports effectively banned (exceptions for personal use and re-export); left-hand drive vehicles prohibited.	Mainly for re-export to third countries.

Table 5: Estimated Annual Cost of Radiation Inspections for Used Vehicles

Cost Item	Estimated Amount (JPY)	Basis / Notes
Inspection Fee per Vehicle	¥700 – ¥1,500	Varies by region.
Total Annual Inspection Cost	Approx. ¥2.5 billion	Based on 1.7 million exported used vehicles annually at ¥1,500 each.
Annual Cost Burden for Major Transporter (e.g., Zero Co., Ltd.)	¥200 million	Inspection costs for used vehicles shipped domestically. No compensation from TEPCO.
Total Annual Industry Burden	Several billion yen	Includes indirect costs; concerns raised about burden being covered by taxpayers and electricity charges.

VII. Future Outlook and Strategic Recommendations

Analysis of the “Game of Chicken” and Potential Legal Outcomes

The current “game of chicken” surrounding radiation inspections for used vehicles may develop into several possible scenarios after July:

• Scenario 1: Port Disruptions and Escalation of Litigation
  If JUMVEA refuses to pay inspection fees and labor unions continue to refuse transport, widespread paralysis of port operations is highly likely. JUMVEA would proceed with the damage claims and civil lawsuits it has declared. In court, the legitimacy of the unions’ refusal to transport uninspected vehicles will be assessed in light of the 2017 High Court ruling and antitrust law principles. This scenario could result in immediate economic losses and prolonged conflict.
• Scenario 2: Forced Compromise or Renegotiation
  The realistic risk posed by legal action and operational paralysis may pressure the unions to reconsider their position and engage in more constructive negotiations. This could lead to a phased reduction in inspections or a new cost-sharing agreement.
• Scenario 3: Stronger Government Intervention
  Since the government’s current “de facto abolition” request carries no legal force, escalation of the conflict and widespread economic disruption could compel the government to intervene more decisively—possibly through legislative action. This may involve legally mandating the abolition of inspections or introducing new financial support measures to address union concerns.

The current situation is unsustainable, and JUMVEA’s legal action will inevitably lead to some form of resolution. Whether this resolution comes through judicial ruling, renegotiation, or government intervention remains to be seen, but the current “distortion” will not persist indefinitely. The key question is at what cost and over what timeframe the resolution will occur.

Strategic Recommendations Toward Risk Mitigation and Sustainable Resolution

To resolve this complex dispute and ensure the stable growth of Japan’s used vehicle export industry, all stakeholders must cooperate and adopt a multifaceted approach.

Recommendations for JUMVEA and Exporters:

• Thorough Damage Documentation: Carefully record all damages—transport refusals, delays, additional costs, and lost profits—to strengthen the legal basis of claims.
• Business Continuity Preparedness: Prepare for potential port disruptions by securing alternative transport routes (where feasible), temporary storage facilities, and communication strategies for international buyers.
• Maintain Industry Unity: Maintain close coordination with related associations such as the Japan Land Transport Association to present a unified industry front, thereby maximizing negotiating and legal leverage.

Recommendations for Port Labor Unions:

• Reevaluation of Risk: Collaborate with independent and trusted scientific experts to objectively reassess the long-term health risks of current radiation levels. Acknowledging judicial rulings and scientific consensus is essential.
• Consideration of Alternative Safety Measures: Even if safety concerns persist, unions should propose more effective and cost-efficient safety alternatives that do not impose mandatory inspection burdens on the entire industry—such as more targeted monitoring, enhanced worker education, or continued compensation/support from the government or TEPCO.
• Return to Good-Faith Negotiations: Re-engage in sincere negotiations with JUMVEA and government agencies to find mutually acceptable solutions that address both worker concerns and industry needs. Dialogue is critical to avoiding long-term litigation and reputational damage to port operations.

Recommendations for Government Agencies (METI, MLIT):

• Strengthening the Legal Framework: Consider legislative measures to support the “de facto abolition” of unnecessary inspections. This could include revising the Port Transportation Business Act or enacting specific regulations to eliminate ambiguity and clarify enforcement authority.
• Proactive Mediation: Take a more active role in mediating negotiations between JUMVEA and labor unions. Judicial rulings and scientific consensus should serve as the basis for guiding negotiations toward practical and sustainable solutions.
• Monitoring International Impact: Closely monitor the dispute’s effect on Japan’s international trade relations and reputation. Be prepared to respond diplomatically or through WTO mechanisms if necessary.

Shared Recommendations for All Stakeholders:

• Prioritize Dialogue: Even as legal proceedings unfold, it is vital to maintain channels of communication and continue seeking practical resolutions.
• Focus on Long-Term Sustainability: With approximately 1.6 million used vehicles exported annually, stakeholders should pursue solutions that ensure the industry’s long-term competitiveness and stability while addressing legitimate worker safety concerns based on verifiable data.