Criteria for being classified as cargo#

First, how are the inspection criteria for each type of use set for cars? They’re determined by government ordinances from the Ministry of Land, Infrastructure, Transport and Tourism (MLIT).
Some of you might be thinking, “Isn’t that set out in the Road Transport Vehicle Act?”, but the Act only covers things in broad strokes, and how to interpret it is laid down separately in ordinances.
The official line is that automotive technology changes so fast that it has to be done this way, but I think it’s really a system for keeping everyone involved happy.
The criteria for passing inspection as a cargo vehicle are roughly as follows. I’ve pulled these from the ordinance and rewritten them in plain language.

• The floor area of the cargo space must be at least 1 m2
• The floor area of the cargo space must be larger than the floor area of the passenger seating
• The load weight must exceed the occupant weight of the passenger seating
• The opening for loading and unloading goods must be at least 800mm*800mm (height and width), with a projected area of at least 0.64 m2
• There must be a protective partition between the occupants and the cargo space

NOTE

“Passenger seating” means the second row and beyond. It doesn’t include the first row, where the driver’s seat is.

Reference: On the Classification of Vehicle Uses, etc. (Directive) (Japanese)

On top of what’s written in the ordinance, NALTEC (the National Agency for Automobile and Land Transport Technology, which carries out vehicle inspections) has its own Examination Procedures Regulations (shinsa jimu kitei), which spell out how to handle points the ordinance doesn’t cover.
You might wonder whether a body that isn’t even the national government gets to interpret laws and ordinances however it likes, but swallow that for the sake of saving money.
Below are the provisions that add extra conditions for cargo registration. I’ve cut the irrelevant parts.

Chapter 4: How examinations related to vehicle inspections, etc. are conducted
4-17 Examination of cargo vehicles
4-17-1 Determination of use
(2) For designated vehicles, etc. with four or more wheels certified as passenger vehicles (limited to those whose body type is box, hood or station wagon), and for parallel-imported vehicles classified as “related to designated vehicles, etc.” with respect to such vehicles, the space for carrying the occupants’ belongings shall not be deemed a goods loading facility under the use classification directive.
However, limited to vehicles whose body type is station wagon (including vehicles other than station wagons that can be classified as station wagons when 6.2.7. of Attachment 3, “Guidelines for Examination of Parallel-Imported Vehicles”, is applied mutatis mutandis, and hood-type vehicles whose hood behind the seats extends to near the rear end of the vehicle), where the rear seats, etc. are removed (including vehicles certified with multiple seating capacity settings that were certified in a state equivalent to having the rear seats, etc. removed) or stowed and fixed to the floor, the resulting floor surface and the space for carrying the occupants’ belongings that is continuous with that floor surface shall be deemed a goods loading facility. Source: Chapter 4: How examinations related to vehicle inspections, etc. are conducted (Japanese)

In short, it comes down to this:

• The luggage space that box-type, hood-type and station wagon bodies come with from the factory is not counted as a goods loading facility under the use classification directive.
• For station wagons, or vehicles that can be classified as station wagons by applying 6.2.7. of the Guidelines for Examination of Parallel-Imported Vehicles, the space created by removing or stowing seats plus the original luggage space together count as the goods loading facility.

What I actually modified#

Here are the modifications I made to meet the requirements above.

• The opening for loading and unloading goods must be at least 800mm*800mm (height and width), with a projected area of at least 0.64 m2

For this one, measure with a tape measure; if it’s 800mm or more, you’re basically fine. Note that it’s the height of the opening that matters, not the height of the cargo area.

• The floor area of the cargo space must be at least 1 m2
• The floor area of the cargo space must be larger than the floor area of the passenger seating
• The load weight must exceed the occupant weight of the passenger seating

This time I decided to fold down the right side of the second-row seat and fix it in that position (the NALTEC procedures say “stowed and fixed”, so it has to be fixed) to increase the cargo area.
As for how to fix it, I put a bolt through the headrest hole, attached a chain to it, and connected the chain to the striker under the seat that holds the seat cushion in place. It’s easy to remove, but I think most people would still call that fixed.
Also, some inspectors will tell you the floor has to be flat, but under the law and the ordinances it doesn’t have to be.
Note 2(2) of the 自動車の用途等の区分について（依命通達） (“On the Classification of Vehicle Uses, etc. (Directive)”) I listed in the references earlier says: タイヤえぐり、蓄電池箱等の占める面積は、物品の積載に支障がない限り物品積載設備の床面積に含めるものとする。 (“The area occupied by wheel wells, battery boxes, etc. shall be included in the floor area of the goods loading facility as long as it does not interfere with loading goods.”)
Reading this, it says that even areas with curved parts such as wheel wells count as loading area as long as they don’t get in the way of loading goods. “Goods” isn’t defined here and could include things like gravel, so I think it’s reasonable to read it as not requiring a flat floor.

• There must be a protective partition between the occupants and the cargo space

I bought one of those wire mesh panels used for shelving at a 100-yen shop, bent it 90 degrees and slid it under the folded seat.
During the inspection, the inspector pointed out that it wasn’t fixed with bolts. I replied, “Even if it were bolted in, you could take it out by turning the bolts, so there’s no meaningful structural difference, right?” The inspector wandered off somewhere muttering to himself, and the inspection passed without a hitch.
Besides, nothing specifies what kind of fixing a protective partition actually needs, so something like the tension rods you see in ordinary vans should be fine too.
As you can see, the safety standards compliance inspection that NALTEC carries out involves a lot of arbitrary judgment by inspectors, so on inspection day it’s best to have a solid understanding of the actual ordinances and the reasoning behind them, enough to win the argument with the inspector.
In the first place, as the Road Transport Vehicle Act states, NALTEC staff are required to report the results of their standards compliance examination in writing to MLIT. In other words, if they write something in the examination results that contradicts the Road Transport Vehicle Act or the procedures drawn up in line with MLIT ordinances, it could constitute the crime of making a false official document bearing a seal. In fact, there has been a case in the past where someone was charged, though prosecution was ultimately suspended.
If even that doesn’t get you anywhere, an inspection decision is, I believe, a form of administrative action, so filing a request for administrative review (shinsa seikyu) is another option.

About the maximum payload#

For cargo registration there’s a provision like the one below. Earlier, you’ll also remember the requirement the load weight must exceed the occupant weight of the passenger seating.
On top of that, the ordinance defines passenger seating as everything except the front seats, and NALTEC’s rules say the payload is calculated in 50 kg increments.
Putting it all together, the payload has to be at least 100 kg and must not push the car past the maximum gross vehicle weight within the same classification.
In my case, I only stowed and fixed the seat, so the car could end up exceeding the maximum gross vehicle weight within the same classification (you can find this out by asking the manufacturer or NALTEC).
That means you’ll need to remove things like the spare tire. If that’s still not enough, try removing the onboard tools, the luggage board, the car navigation system and other interior parts.

(e) For designated vehicles, etc. whose permissible limits for gross vehicle weight and axle load are not clear, it shall be specified within a range not exceeding the maximum gross vehicle weight within the classification of the same model. (f) For vehicles other than those specified in (a) through (e), it shall be specified within a range not exceeding the weight obtained by multiplying the number of occupants for the removed passenger seating by 55 kg. Source: 7-124, 8-124 Maximum payload (Japanese)

Now take a look at the provision below. Based on the wording 産出される物品の積載量のうち最大のものとする (“shall be the largest of the calculated payloads”), NALTEC will tell you to take the largest payload possible within the gross weight.
The problem here is that taking the maximum payload can push the gross vehicle weight over 2 tonnes. Over 2 tonnes, the weight tax goes up, so I think it’s better to keep it as light as you can.
To make it easier to follow, take a car with a spec maximum gross vehicle weight of 2,040 kg, and compare a measured vehicle weight of 1,895 kg + 100 kg = 1,995 kg with 1,890 kg + 150 kg = 2,040 kg.
In that case, making it too light actually increases your weight tax, so it takes some fine-tuning. Usually you can adjust it by leaving in or taking out the luggage board and interior parts.
For these calculations, I’ve put the Excel sheet I made for myself on the web, so use the weight distribution calculator. Enter the front and rear axle weights, the wheelbase, the position of the seats you’re keeping, the payload and the tires’ load index, and it gives you the gross vehicle weight and the maximum payload you can get from the classification (in 50 kg increments). It also checks the front axle load ratio when loaded (it won’t pass below 20%) and the tire load ratio. You can see the verdict without logging in.
I haven’t verified whether it actually works yet, but for cars like one with a maximum gross vehicle weight of 2,090 kg, which ends up over 2 tonnes no matter what you do, I think you could register it once at over 2 tonnes and then get the gross weight to 2 tonnes or less by fully removing the seats and taking out interior parts to lighten it.

(1) The maximum payload of a vehicle shall be the largest of the payloads of goods calculated based on the standards in (2) through (11), as the amount that can be loaded within a range that complies with the provisions of this chapter, ensures safe operation, and prevents pollution.

How to submit#

1. Create an account on this site. You can do it via Log in -> Register account
2. Once you’ve created an account and logged in, click New Inspection Notification
3. Click Create Notification
4. Select and fill in the following, then click Next
   1. Notification method: 個別届出 (“Individual notification”)
   2. Supplementary provision: 技術基準等の審査を要する自動車、自動車予備検査証の交付を受けた自動車又は使用の過程にある自動車若しくは特定の大型特殊自動車 (“Vehicles requiring examination against technical standards, etc., vehicles issued a preliminary vehicle inspection certificate, vehicles in use, or certain large special vehicles”)
   3. Category: 3.2.（1）技術基準等の審査を要する自動車 (“3.2.(1) Vehicles requiring examination against technical standards, etc.”)
   4. Submit to: select the inspection office where you’ll take the inspection
   5. Make, model and chassis number: fill in exactly as on the vehicle inspection certificate
5. Fill in the New Inspection Notification Form (Form No. 1) (Part 1) as follows
   1. Classification number or vehicle specification code: select 類別区分番号 (“Classification number”) and enter the classification number shown on the vehicle inspection certificate in the input field
   2. Structures and equipment changed relative to the designated vehicle of that model and classification number
      1. Structure/equipment changed: select 有 (“Yes”)
      2. Option: select （記入欄のとおり） (“(As described in the entry field)”)
      3. Entry field: enter the following (adjust to match your car’s current specs)

      1
      乗車定員の変更（5人→3人）2列目右側座席固定
      2
      用途変更（乗用→貨物）
      3
      車体形状の変更（ステーションワゴン→バン）
      

      (“Change of seating capacity (5 → 3), right-hand second-row seat fixed / Change of use (passenger → cargo) / Change of body type (station wagon → van)”)
      1. Changes to structures/equipment related to the noise prevention device: 無 (“No”)
      2. Over-revolution prevention device related to the noise prevention device: 無 (“No”)
6. The documents to upload for the New Inspection Notification Form (Form No. 1) (Part 2) can be created with a Windows application that NALTEC distributes. Download the zip file from the link below and run InitPreEntry.exe in the bin folder to launch it.
   • New Inspection Notification Form No. 1, Part 2
   • You can fill in the values by actually measuring the car or by asking the manufacturer for its spec sheet.
   • For the parts that need calculations, some NALTEC offices may give you something called a weight distribution calculation sheet, but this seems to vary from office to office. Just copy over the numbers from the weight distribution calculator mentioned earlier.
7. For the document identifying the vehicle, upload a scan of the Registration Identification Information Notice (toroku shikibetsu joho-to tsuchisho)
8. For the spec sheet or vehicle specification table, upload the specs you got from the manufacturer and the four-view exterior drawing
9. For the document certifying compliance with technical standards, upload the “Document on Compliance with the Technical Requirements of Each Provision of the Safety Standards”. Fill it in with calculations that fit your own car.
   • ※ Update (October 2026): I’ve stopped publishing the Word file with sample inputs that I used to distribute here. Now, on the structural modification screen in Todoroku, you can generate this document and the four-view exterior drawing from the vehicle values you’ve entered in the ledger.
10. Under other documents, upload the following
    • A side-view photo annotated with the overall length
    • A front-view photo annotated with the overall width
    • A rear-view photo annotated with the overall height, the cargo area height and the opening height
    • Photos showing the fixed seat cushion and the partition between the seats and the cargo area