IOR Service for Food/Kitchen Tools - ACP JAPAN - Attorney for Customs Procedures

ACP Japan, we help foreign companies smoothly import products regulated under the Food Sanitation Act, such as food items, kitchenware, tumblers, cutlery, and more. Because these products require additional procedures, our experienced team supports you at every step to ensure a smooth and compliant import into Japan.

Importing Tableware into Japan

When importing tableware, utensils used for food, or packaging materials, it is necessary to obtain inspection certificates confirming compliance with the standards set under the Food Sanitation Act of Japan.
Prepare labels and package information that comply with relevant Japanese regulations.
Together with the inspection certificates, submit a “Notification Form for Importation of Foods, etc.” to the Quarantine Station (Import Food Monitoring Division) at the time of importation.
After the quarantine process is completed, proceed with customs clearance procedures, and the import process will be finalized.

*Importing tableware is also subject to other relevant laws, including the Household Goods Quality Labeling Act, Act against Unjustifiable Premiums and Misleading Representations, Intellectual Property-related laws, Container and Packaging Recycling Act, and the Act on the Promotion of Effective Utilization of Resources.
For more details, please refer to JETRO’s guidance on “Import Procedures for Tableware.”

Importing Food Products

Obtain from the manufacturer the product overview, list of ingredients, and production flowchart.
Review these materials to verify compliance with relevant Japanese standards, and consult the Quarantine Station (Import Food Monitoring Division) in advance if any unclear points arise.
Conduct voluntary testing when necessary to ensure that the product meets all regulatory requirements and safety standards.
Prepare food labeling and package information in accordance with applicable Japanese laws and regulations.
Submit the “Notification Form for Importation of Foods, etc.” to the Quarantine Station (Import Food Monitoring Division) at the time of importation.
Once the quarantine procedures are completed, proceed with customs clearance to finalize the import process.

*Importing food products into Japan requires careful review of multiple complex legal and regulatory requirements.
At ACP JAPAN, we take full responsibility as the importer, working closely with food import specialists and professional labeling companies to ensure full legal compliance and a smooth, reliable import operation.

Japanese Customs System Reform: Clarification of Importer Definitions

Starting October 1, 2023, Japanese Customs has instituted a pivotal reform aimed at addressing the issue of foreign sellers improperly designating third parties (such as forwarders or customs agents) as importers.

This revision necessitates foreign corporations to utilize an Attorney for Customs Procedures (ACP) to assume the role of Importer of Record (IOR) directly in many cases. The practice of merely nominally appointing another entity as the importer is no longer feasible.

Notably, foreign corporations that act as importers themselves, through the engagement of ACP, are eligible for Japan Consumption Tax (JCT) benefits. (link: Consumption Tax Treatment and Benefits of Using ACP).

As a dedicated ACP firm, we ensure compliance with the law to facilitate correct import procedures, allowing you to trust us with your importation requirements confidently. We are eager to engage in further discussions with you.

Revisions Effective October 1, 2023:

Definition of the Importer

Regarding a cargo imported under import transaction, an importer is equivalent to “a person who imports a cargo” defined in Article 6-1 (1), General Notification of the Customs Act. ….. This means, the Consignee, etc., in the case of imports conducted through normal transactions between an overseas seller and a Japanese buyer.
In the cases other than above, an importer is a Person Having the Right of Disposal of the import cargo at the time of import declaration. If there is another person who acts on the purpose of the import*, that person is also included :

In case of a cargo imported:
– under lease contracts, a person who rents and uses the cargo.
– for consignment sales, a person who sells the cargo in the name of himself/herself (consignee) by accepting the commission.
– for processing or repairing, a person who processes or repairs the cargo.
– for disposal, a person who disposes the cargo.

Importer Defined as the “Person Having the Right of Disposal”

One of the most notable aspects of the amendment is the clarification that the “person having the right of disposal” is regarded as the importer under Japan Customs law. The term “right of disposal” is similar to ownership, but not identical. Although there is no explicit definition in the customs-related legislation, according to Japan Customs, it refers to the authority to decide how the goods will be handled after being released into Japan—for example, whether to sell the goods or to enter into a sales contract.

For additional information, please refer to the following resources:

Track Record – Attorney for Customs Procedures (ACP) Services

We have supported import and export operations in Japan for over 200 clients across more than 40 countries.

Examples of International Logistics Partners We Have Worked With

We have a proven track record of working with a wide range of logistics providers. As the Attorney for Customs Procedures (ACP), we handle customs-related responsibilities while logistics companies manage transportation and warehousing operations.

Apex International
Brink’s
CEVA Logistics
Coshipper
Crane Worldwide Logistics
DB Schenker
DGX (Dependable Global Express)
DHL Express
DHL Global Forwarding
Dimerco
DSV Air & Sea
Expeditors
FedEx Express
FERCAM
GOTO KAISOTEN Ltd.
Harumigumi
Herport
ICL Logistics
JAS Forwarding
Kintetsu Express
Kokusai Express
Kuehne + Nagel
Mitsubishi Logistics
MOL Logistics
Nankai Express
Nippon Express
OIA Global
PGS
Rhenus Group
Röhlig
Sankyu
Sanyo Logistics
Scan Global Logistics
Seino Schenker
SEKO Logistics
Shin-Ei gumi
Shiproad
Sumitomo Warehouse
UPS
UPS Supply Chain Solutions
Yamato Transport

…and many other logistics providers in Japan and around the world.

Please Be Careful

In cases where foreign corporations (non-residents) without an office in Japan import goods, failure to properly prepare an Importer of Record (IOR) through an Attorney for Customs Procedures (ACP) or similar means can result in goods being held at customs, leading to significant delays and costs. To avoid such risks, please make thorough preparations.

If an ACP is needed, it is crucial to utilize the services of an experienced ACP well-versed in customs-related laws and regulations. The import and export operations of non-residents/foreign corporations using an ACP are treated as unique cases. Many customs brokers are not familiar with these procedures, leading to incidents where goods are detained for extended periods due to unsuccessful explanations to customs. (Customs will not permit the import if the explanations provided by the importer or customs broker are unsatisfactory, resulting in the goods being detained until customs is convinced.)

We highly recommend utilizing our services as professional experts in customs, knowledgeable about customs-related laws and regulations. With a proven track record of resolving numerous issues through direct consultations with customs officers and customs brokers, our clients supported as an ACP now exceed 200 companies. We are committed to delivering industry-leading results with our expertise.

Why choose us?

We specialize in navigating complex issues at the intersection of customs procedures and taxation—an area where our ability to offer practical, comprehensive support from both perspectives sets us apart. Understanding the close relationship between customs duties and national taxes (especially, Japan Consumption Tax – JCT), and addressing both in an integrated manner, is crucial in the context of international trade.

Customs and International Trade Professionals – Led by our CEO, Mr. Sawada—Certified Customs Specialist and former KPMG professional—ACP JAPAN provides expert-level support in Customs and international trade.
Full Compliance with Japanese Customs Law – We ensure full adherence to Japanese Customs Law, including Importer of Record (IOR) structure, HS code classification, and customs valuation. We assist in preparing all essential shipping documents for non-resident entities.
One-Stop Support for ACP and JCT Tax Representative Services – In collaboration with trusted partner tax accountants, we provide comprehensive support for both customs procedures through the Attorney for Customs Procedures (ACP) and Japan Consumption Tax (JCT) filings through the JCT Tax Representative.
Multilingual Communication – Our team communicates fluently in English, Japanese, and Chinese, offering smooth coordination with global clients and authorities in Japan.
Support for Regulated Products – Our ACP/IOR partnership system can manage regulated items, including cosmetics, PSE-products, foodstuffs, and tableware.
Trusted by Global Clients – Serving around 100 ACP clients annually, including many Amazon sellers, we’re a certified provider on Amazon SPN (Service Provider Network) under Trade Compliance.

Our ACP Service: The Best Solution for the Japan Importer of Record (IOR) and Exporter of Record (EOR)

ACP is an effective solution for addressing Importer of Record (IOR) and Exporter of Record (EOR) requirements in Japan. Through our ACP service, non-resident entities located outside Japan are able to import and export goods as Non-Resident IOR and EOR.

Below is an overview of our basic scope of work, together with a diagram illustrating the operational structure of the ACP service. Once ACP registration is completed, the non-resident entity can act as the Importer of Record (IOR) and Exporter of Record (EOR) in Japan.

Scope of Work – How We Can Assist

Consultation with Japan Customs to support successful ACP registration.
Liaison with relevant stakeholders, including freight forwarders and Japan Customs, to ensure the smooth and compliant import and export of goods.
Assistance in preparing and reviewing import and export clearance documentation.
Support in the calculation of customs value, in accordance with the Japan Customs Tariff Act.
Assistance with advance rulings on HS classification, customs valuation, and rules of origin.
Import compliance support for regulated products, including Domestic Administrator (sometimes referred to as “Domestic Representative”) Services under the Product Safety Acts (PSE/PSC) and food-related products regulated under the Food Sanitation Act.
Support for security export control, including list-based classification, catch-all control assessment, and assistance with export license applications to the Ministry of Economy, Trade and Industry (METI).
Record-keeping support in accordance with Article 95 of the Japan Customs Law.
Provision of professional trade and customs advisory services to address and resolve issues that may arise during import or export operations.

**Both import and export activities can benefit from the use of an ACP (Attorney for Customs Procedures). This support is applicable in scenarios where a non-resident acts as the Importer of Record (IOR) for imports and as the Exporter of Record (EOR) for exports.

Three Steps to Initiate Shipments Under the ACP Program:

Quotation Review to Contract Conclusion: Upon receiving your contact details, we will promptly provide a quotation for your review.
Commencing the Registration of ACP (Attorney for Customs Procedures) to Japan Customs: This process is generally completed in about two weeks.
Initiation of First Shipment, Import/Export

FAQ for ACP (Attorney for Customs Procedures)

What is the role of ACP (ACP Japan)?

Representation: ACP (ACP Japan) represents the foreign importer and liaises with Japan Customs and the Forwarding Company/Customs Broker.
Documentation and Compliance: ACP assists in preparing essential import documents (e.g., Invoices) in compliance with Japan Customs Law and formally requests the Customs Broker to proceed with customs clearance.
Expert Consultation and Troubleshooting: We are a team of legal experts in Customs Laws, providing direct consultations with Japan Customs to ensure compliance and address issues, including troubleshooting unique challenges in non-resident imports.

How long time does it require to get ACP’s registration?

It will take approximately 2 weeks until getting an approval from Japan Customs Office.
The breakdown of the task is as follows.

Prepare the necessary documentation between us
Start pre-consultation with Japan Customs Office and proceed initial review
Submit paper-based set of application documents to Japan Customs Office for final review

What kind of documents to be necessary for ACP application?

Not limited, but for instance – Power of Attorney, Company Registry, The calculation method of Customs Valuation, Catalog of the import goods, business/logistic flow

ACP can handle all kinds of goods?

ACP, is not capable to handle all kinds of goods. If the goods are subject to specific regulations requires importer to be resident in Japan, such goods can not be handled under the ACP.