What is an Exporter of Record (EOR) in Japan?
For exporting goods from Japan, it is required to designate a Japan Exporter of Record (EOR). The EOR must typically be a Japanese resident person or entity, bearing responsibility for compliance with export-related regulations. Japan Customs mandates that the EOR be based in Japan, disallowing foreign entities from fulfilling this role directly.
What is Japan ACP – Attorney for Customs Procedures
Nevertheless, foreign entities can engage in exporting from Japan by appointing an Attorney for Customs Procedure (ACP). This appointment allows the foreign enties to operate as a Non-Resident Exporter (EOR), enabling them to manage exports independently. The concept is similar for imports. While a non-resident cannot directly become a Japan Importer of Record (IOR), utilizing an ACP enables a foreign entity to assume the role of an IOR equivalently.
Our ACP Service: The Best Solution for the Japan Exporter of Record (EOR)
Attorney for Customs Procedures (ACP) is the best solution for addressing the issue of Japan EOR – Exporter of Record. Below is an outline of our primary services and a diagram illustrating the operational structure of the ACP service. Upon successful ACP registration, a foreign entity can become the Japan EOR – Exporter of Record. Basic Scope of Services:
- Consultation with the Japan Customs Office for successful ACP registration.
- Liaising with stakeholders, including Logistics Forwarding Companies and the Customs Offices, on behalf of non-resident clients (i.e., non-resident Japan IOR) to ensure the secure importation of goods.
- Assistance in preparing the necessary documentation for import clearance.
- Support of calculation of Customs Value (Customs Valuation Formula), in accordance with appropriate compliance under the Japan Tariff Customs Law.
- Security Export Control (Classification for List Control, Examination for Catch-All Control, Application of the license to Ministry of Economy, Trade and Industry)
- Documents keeping, required under article 95 – Japan Customs Law
- Providing professional trade/customs advice if any issues arise.
**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 Procedure) to Japan Customs: This process is generally completed in about two weeks.
- Initiation of First Shipment, Import/Export
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.
- Brink’s
- CEVA Logistics
- Crane Worldwide Logistics
- DHL Express
- DHL Global Forwarding
- Dimerco
- DSV Air & Sea
- FedEx Express
- FERCAM
- Herport
- ICL Logistics
- JAS Forwarding
- Kintetsu Express
- Kokusai Express
- Kuehne + Nagel
- Mitsubishi Logistics
- MOL Logistics
- Nankai Express
- Nippon Express
- PGS
- Röhlig
- Sanyo Logistics
- Scan Global Logistics
- SEKO Logistics
- 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.
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?
Whereas many ACP service providers do not handle regulated items, our company’s competitive advantage stems from our ability to manage such products. We can support regulated items, including cosmetics, PSE-regulated products, foodstuffs, and tableware.
Which regions in Japan are we covering?
Any region in Japan, we can handle.
What is difference between ACP and IOR?
ACP is not the Importer. ACP enables non-resident entities to become IOR (Importer of Record).
What Is a JCT Tax Representative and Why Is It Required?
When a non-resident foreign entity becomes subject to Japan’s Consumption Tax (JCT), it is required to appoint a JCT Tax Representative (Tax Agent). If a non-resident company sells goods to customers in Japan, it typically collects 10% consumption tax on those sales. This collected JCT must be reported and submitted to the Japanese National Tax Office, unless the entity qualifies as a tax-exempt business. (See: “Are we a Tax-Exempt Business?”) If the entity is JCT-liable—or voluntarily registers as a taxable entity, such as by obtaining a Qualified Invoice Issuer Number—it must appoint a JCT Tax Representative to handle all tax-related procedures in Japan, including JCT tax filings. In the JCT tax return process, the paid import JCT can be offset against the collected JCT.
- If the import JCT exceeds the collected amount, the difference may be refunded.
- If the collected JCT exceeds the import amount, the difference must be paid to the tax office.
A JCT Tax Representative is legally required to manage this process on behalf of the foreign entity. Please note: The JCT Tax Representative is distinct from the Attorney for Customs Procedures (ACP), which is appointed for customs clearance purposes.
- ACP = Customs representative
- JCT Tax Representative = Tax representative
Our Japan Consumption Tax (JCT) Representative Services
At SK Advisory Inc., we provide a comprehensive one-stop service that covers both customs procedures through the Attorney for Customs Procedures (ACP) and Japan Consumption Tax (JCT) procedures with the National Tax Agency through a designated JCT Tax Representative.
By working closely with our trusted partner tax accountants, we act as your ACP while maintaining close coordination and information sharing with the tax representative. This collaboration ensures the proper deduction and refund of Japan Consumption Tax paid at the time of importation.