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Six Things a Japanese Company Misses Before Launching an App Overseas

What is normal practice in Japan can lead to lawsuits or demand letters in the US and the EU. Google Fonts loaded from Google, analytics with no consent banner, launch emails with no postal address, subscriptions that are hard to cancel. Six things to check before you launch an app or service for users abroad, with the primary sources.

When a Japanese company launches an app or service abroad, it puts real time into translation, payments and store review. The legal side tends to get less: "it runs fine in Japan, so it is fine."

In practice, things nobody in Japan worries about can become problems in the US or the EU. None of them need a big redesign. Before launch they are small fixes.

From building products in Tokyo for users abroad, these are the six I see missed most often. I am a designer, not a lawyer, so read this as a checklist that keeps gaps from slipping through.

One: serve Japanese fonts from your own domain too

Loading Noto Sans JP or similar from Google Fonts is standard on Japanese sites. But the moment the page opens, the visitor's browser connects to Google and hands over its IP address, before any consent banner appears.

In January 2022 the Munich Regional Court ruled that this breached the GDPR without consent and awarded the visitor €100 (3 O 17493/20). The amount looks small, but a wave of demand letters on the same grounds followed in Germany.

The fix is to host the font files on your own domain. Japanese fonts cover so many characters that a full file runs to several megabytes, so subset them, convert them to woff2 and serve them in slices, which is what Google Fonts does behind the scenes. Check the landing pages, campaign pages and blog templates as well as the app itself.

Two: put a consent banner in front of analytics

Japanese sites usually run analytics without asking. In the EU and the UK, any cookie or device storage that is not strictly necessary needs consent first, and analytics and advertising cookies do not count as strictly necessary.

For visitors from the EU, show a banner where declining takes the same effort as accepting, and keep analytics scripts from running until someone accepts.

Session replay tools such as Microsoft Clarity, Hotjar and FullStory need even more care. In the US they are the target of ongoing class actions under California's wiretapping law (CIPA), on the claim that they record what visitors type without consent. For services aimed abroad, I recommend leaving them off by default, and if you do use one, turning it on only after consent with every input masked.

Three: put a postal address and an unsubscribe link in every announcement

Here the logic runs the opposite way from Japan. Japan's Act on Specified Electronic Mail is opt in: consent comes first. The US CAN-SPAM Act lets you send without prior consent, and in exchange requires two things in every commercial email:

  • a valid postal address
  • a way to opt out, honored within 10 business days

Even with consent collected the Japanese way, a footer with no address breaks US law, and penalties can exceed $50,000 per email. Check every template: launch announcements, drip sequences, follow ups after events. If you send more than 5,000 messages a day to Gmail addresses, you also need one click unsubscribe headers.

Four: make canceling a subscription as easy as starting one

Since the 2022 amendment to the Act on Specified Commercial Transactions, Japanese companies are used to listing price and cancellation terms on the final confirmation screen. That habit carries straight over to the US.

Where the US differs is cancellation. The FTC's "click to cancel" rule was struck down by a federal appeals court in July 2025, but the FTC started a new rulemaking in March 2026 and keeps enforcing existing law. And California's automatic renewal law already requires, for contracts from July 2025:

  • people who signed up online can cancel online
  • if you offer a discount to keep someone, a "click to cancel" link stays prominent the whole time
  • records of consent to automatic renewal are kept for three years, or one year after the contract ends if that is longer

Cancellation only by phone, or only through a contact form that asks for a reason, is a common pattern in Japan. It does not work for the US.

Five: put the age check at the start of signup

In the US, COPPA requires parental consent and more from services that handle personal information from children under 13, and the amended rule has applied in full since April 22, 2026. In the EU the age of digital consent is 16 by default, and member states can lower it to 13.

Japan is moving the same way: the APPI amendment promulgated on July 17, 2026 adds rules for under 16s, taking effect within two years. Every market points in one direction. Put a birth year or age check before the email field on signup, and stop the signup or move to a parental consent flow for anyone under the age.

Six: if users can upload, register a DMCA agent

If users can post images, audio, files in chat or community posts, copyright complaints can arrive from the US. The DMCA offers a safe harbor that limits a service's liability for what users upload, and Japanese companies can use it.

The conditions: designate an agent with the US Copyright Office, publish the agent's contact details on your site and renew every three years. It costs $6. Let it lapse and you risk losing the safe harbor. If every piece of content in your service is your own, skip this one.

At the first meeting before launch

Laid out together, the six are a font change, a consent banner, an email footer, a cancel flow, an age question and a $6 registration. Each takes half a day to a day. Found after launch, they come with demand letters or lawsuits, another round of store review and explanations to users.

If you are preparing an app or service for users abroad, tell me three things at the first meeting: the countries and regions you are targeting, how you charge (in app purchase or payment on your own site), and the list of outside tools currently running in your site or app.

If you do not have that list, that is fine. We can start by building it together.

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