On October 27, the Ministry of Land, Infrastructure, Transport and Tourism responded to an inquiry from Every WiLL, the company that operates "Toriiku," a service that allows users to pick up their delivered packages at unmanned pickup spots at their convenience, regarding the application of laws and regulations, based on the gray zone resolution system. The response stated that unmanned pickup spots do not fall under the category of "warehousing business."
The reason given for not falling under the category of warehousing is that "Every WiLL states that it is not responsible for theft or damage to goods at unmanned locations, and therefore it is not considered to be a business that accepts goods on deposit and stores them. In addition, the usage fee collected from users is only a few tens to a few hundred yen, or even zero yen, and it is quite possible that the points earned by users depending on their usage of the e-commerce site will exceed the usage fee, so the usage fee is not considered to be a storage fee."
Furthermore, while it is stated that no permits or licenses related to the freight transport business are required if the delivery to the unmanned base is carried out solely by employees of the transport company, if the delivery between the transport company's base and the unmanned base is carried out by employees of the inquirer, the inquirer's act of "transporting goods for a fee in response to the needs of others, using motor vehicles (excluding light motor vehicles with three or more wheels and two-wheeled motor vehicles)" with the transport company constitutes a freight transport business, and therefore, depending on the vehicle used for transport, it is necessary to obtain a permit for a general freight transport business or to register as a light freight transport business.
