ACP Import under VMI – Vendor Managed Inventory

We have experienced a significant increase in requests from new customers, particularly parts and materials manufacturers outside Japan, operating in the automotive and machinery parts industries.

This surge in demand can be attributed to Japanese end-customers, who are manufacturers of finished goods, requesting a transition to VMI (Vendor Managed Inventory). Under the VMI scheme, inventory management responsibilities shift to the vendor (supplier) side.

Previously, in trade between overseas parts and materials manufacturers (sellers) and Japanese finished goods manufacturers (buyers), the buyer would act as the importer, importing the goods and managing them as part of its own inventory.

However, with the implementation of VMI, the parts and materials manufacturer (seller) located outside Japan now imports the goods themselves, manages the inventory near the customer in Japan, and delivers the goods to the buyer’s factory Just-in-Time (JIT) as requested by the finished goods manufacturer (buyer).

This arrangement allows the buyer to eliminate the complexities associated with inventory management while ensuring that the required quantity of goods is delivered at the specified time. Additionally, as the buyer is no longer the importer, it is relieved of various responsibilities imposed on importers, such as the need to maintain import-related documents and books or respond to post-clearance audits conducted by customs authorities.

On the other hand, the foreign parts and materials manufacturer (seller) must engage the services of an Attorney for Customs Procedures (ACP) to act as the importer. Moreover, due to national taxation regulations, sales in Japan (subject to consumption tax under Japanese law) necessitate the appointment of a Tax Representative (JCT – Japan Consumption Tax) to register as a taxable business operator for consumption tax purposes and fulfill periodic tax filing obligations.

Considering Japan’s Qualified Invoice System for consumption tax, the use of a tax representative is essential for B2B transactions, as the seller must be a registered business to enable the deduction of input consumption tax when filing consumption tax returns on the buyer’s side.

Switching to the VMI method (example)

Before the introduction of VMI program:

Foreign parts and materials manufacturer (seller)   → Sales →    Japanese finished goods manufacturer (buyer)

  • Inventory control on the Japanese side: Buyer
  • Importer: Buyer
  • Seller’s sales subject to consumption tax in Japan: No

After the introduction of VMI program:

Foreign parts and materials manufacturer (Seller)   → Sales →   Japanese finished goods manufacturer (Buyer)

  • Inventory control in Japan: Seller
  • Importer: Seller   ACP – Attorney for Customs Procedures is required (for Customs purpose)
  • Sales subject to consumption tax in Japan on the seller’s side: Yes    JCT Tax Representative is required (for National Taxation purpose)

 

 

 

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.

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.

  • American Overseas Transport (AOT)
  • 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
  • Shibusawa Logistics Corporation
  • Shin-Ei gumi
  • Shiproad
  • Sumitomo Warehouse
  • UPS
  • UPS Supply Chain Solutions
  • Yamato Transport

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

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:

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