What happened
KYB Corporation (カヤバ株式会社), the Tokyo-based hydraulic shock absorber maker with ¥27.65 billion in capital, buys parts from subcontractors with ¥300 million or less in capital. Its suppliers held dies and jigs managed by KYB — including tooling the suppliers had renewed at their own manufacturing expense. From at least April 1, 2023, KYB stopped ordering parts made with that tooling for long stretches, but left it in place: 167 subcontractors warehousing the equivalent of 5,756 part numbers of dies for free.
On April 24, 2025 the Japan Fair Trade Commission found the arrangement extracted unfair economic benefits in violation of the Subcontract Act and issued a recommendation. The rare point, as Nikkei xTECH noted, is ownership: in most mold-storage cases the customer owns the dies, but KYB was the first case where the JFTC flagged tooling owned by the suppliers themselves — the test is who effectively controls whether the tooling can be used or discarded, not whose name is on it.
The recommendation requires KYB to pay storage costs equivalent to what the free warehousing cost suppliers, after JFTC confirmation, plus a board resolution, tooling-focused training for purchasing staff, supplier notification and reporting. KYB has begun procedures to dispose of tooling or pay for its storage. The case sits inside a widening enforcement wave: the JFTC's first mold-storage recommendation came in March 2023, with 2 companies named that year, 6 in 2024 and 20 in 2025.
What it cost
5,756 part numbers of dies and jigs warehoused free at 167 suppliers from April 2023; storage-cost reimbursement now payable after JFTC confirmation
Why it happened
Supplier-funded renewals sharpened the transfer: subcontractors invested their own money updating KYB's tooling, then paid to warehouse it — twice billed for an asset they couldn't use or discard.
Ownership gave no exit because KYB controlled use and disposal, so the JFTC read it as effective control: forbid scrapping, stop ordering, and storage becomes the customer's obligation.
The costs were invisible by structure — racking and handling folded into each supplier's operations, never invoiced — so 167 firms each carried a grievance too small to litigate.
The practice was industry-standard enough to outlive the headlines: recommendations kept climbing because every manufacturer's registry had dormant tooling nobody was paid to clean up.
The lesson
Regulators look at effective control, not title — owning a die protects nothing if the customer forbids scrapping. Without lifecycle rules, dormant tooling piles up until a regulator counts it.
Aftermath
KYB is paying storage-cost equivalents after JFTC confirmation and processing disposal or return of the tooling, alongside board-level confirmation and retraining of procurement. Enforcement has kept escalating — 20 companies were recommended in 2025 alone — and from January 1, 2026 the amended Subcontract Act (renamed the Transactions Appropriateness Act) makes such benefit extraction easier to police.
FOLLOW THE EVIDENCE
The sources
- (令和7年4月24日)カヤバ株式会社に対する勧告について jftc.go.jp
- 公取委、無償保管させたカヤバに下請法違反で勧告 logi-today.com
- トヨタもスズキも違反、公取委が30社に勧告も金型無償保管はやまず xtech.nikkei.com