Amazon won’t become an IOR

Amazon won’t become an IOR

In fact, many Amazon FBA sellers make a mistake by appointing Amazon as the IOR (Importer of Record) for their shipment…
FBA sellers export by writing Amazon’s name in the IOR or Consignee in the shipping documents including the invoice.
This is the most frequent mistake we observe in practice.
Please be careful, Amazon officially states that they won’t become an IOR in Japan.

Can logistics providers (DHL, FEDEX, UPS etc…) be IOR?

No, they can’t.

What should I do?

If you want to be IOR, you have to appoint an ACP (Attorney For Customs Procedure) who can handle the customs clearance on behalf of the non-resident entity. 

We observe many cases where goods are stuck in Japan Customs because of the lack of IOR. If your goods are held in Customs, we can help to clear the goods by acting ACP.

Please visit our ACP service page, or contact us. We’re happy to help you.

Our service of ACP – Attorney for Customs Procedure


You can also check with our YouTube – “Do not appoint Amazon Japan as an IOR for your shipment!”

What would happen if Amazon sellers appoint Amazon Japan as the IOR

Let’s look at the scenario if Amazon sellers ship their inventory to Japan by appointing Amazon Japan as the IOR. In the country where you’re making a shipment, the logistics providers do not know well about the trade restrictions in Japan side. Therefore, the logistics providers the Amazon sellers use don’t stop your export procedure, even if you write Amazon Japan as IOR in the invoice. However, most logistics providers in Japan know that Amazon Japan won’t be the IOR.

So, after the goods arrive in Japan, the logistics providers on the Japanese side, start saying that your goods can’t proceed with import clearance. In many cases, the logistics providers are trying to ship back the goods to your place. And you need to pay for the unnecessary shipping fees. If your designated logistics provider is kind, they would instruct you that you need to find an ACP or another IOR. But they can store your goods only for a short period.

We can support your urgent request, but better to prepare beforehand

In this way, our company often receives an urgent requests from Amazon FBA sellers. The sellers often tell us that the inventories are stuck in Japan Customs because of the wrong information of IOR. Our company can help such a situation, by promptly proceeding with ACP registration as well as making communication with the logistics provider to wait for the registration process to ensure that they won’t ship back the goods to sellers. But of course, it’s better to properly appoint an ACP or IOR before shipment, so that you don’t have to worry about the ship back issues.

ACP Service, Attorney for Customs Procedure


Amazon’s Frequently Asked Questions from Overseas Sellers

Q1: Can I register as an importer of record when I export my products? A: No. Amazon cannot be an importer of record for FBA shipments. Please contact Attorney for Customs Procedure (ACP). We have a list of 3rd party service providers who can help you with FBA shipments.

Our strengths

  • Professional of Customs and International Trade – The CEO, as a Certified Customs Specialist in Japan – Mr. Sawada has been providing consulting services in the Trade & Customs area for many years. He was in a management position at KPMG, then started with his own company – SK Advisory to continue the customs-related services to the international clients.
  • Fully compliance in accordance with Japanese Customs Law – Maintaining the service quality with full compliance with Japanese Customs Law. ACP Japan is capable to manage all the necessary import compliance issues, including the classification of HS code, and setting of the appropriate Customs Valuation of the import goods to Japan.
  • Experienced and credible partner – As ACP Japan has been providing ACP services to many clients as demand has increased, you can totally rely on us as a credible partner. We registers 40+ ACP customers every year, the customers from around the world. In this way, all customers successfully became non-resident IOR – Importer of Record in Japan. You can see a list of our customers in here “Experiences”.
  • Qualified ACP service provider in Amazon SPN (Service Provider Network) – ACP Japan has officially become a qualified ACP service provider in Amazon’s Service Provider Network (SPN) under the Compliance category.


Our Customers


How does the Japanese New Invoice System affect?  – Advantage of using ACP –

Recently, many companies register JCT (Japanese Consumption Tax) because the new invoice system for JCT will start in October 2023. The concept of the new invoice system is very similar to the EU’s VAT invoice system.

Your Japanese customer can’t claim input tax credits unless the sellers(suppliers) issue a qualified invoice that is written a JCT number. To issue a qualified invoice, sellers(suppliers) need to be a taxable entity and get a JCT number.

Before the Invoice system is introduced (before Oct 2023):

  • A company that paid consideration of goods or services (=Company-B) is able to deduct Input JCT of the consideration regardless of whether the vendor (issuer of invoice, =Company-A) is a JCT-taxable or Non JCT-taxable company.
  • There is no way to confirm whether the vendor (=Company-A) is JCT-taxable or Non JCT-taxable company.

After the Invoice system is introduced (after Oct 2023):

  • A company that paid consideration of goods or services (=Company-B) is able to deduct Input JCT of the consideration only if the vendor (Company-A) has its invoice registration number.
  • Company-B requests Company-A to issue the qualified invoice. If Company-A cannot submit qualified invoice, Company-B will no longer want to buy from Company-A.

**If Company-A only sells to consumers (not business entities), it may not require for Company-A to issuethe qualified invoice since normally consumers would not tend to do tax return. 


Once the Comapny-A (Seller/Supplier) obtains the JCT invoice registration number, which means this company becomes a taxable entity that is obligated to file JCT tax returns on a regular basis.

For the case of a non-resident entity (Company-A), when Company-A imports and sells to customers in Japan, following 3 steps are the standard procedure.

(1) Pay import JCT to a customs office, 10% of the import customs value when Company-A imports.
(2) Obtain JCT from a customer in Japan, 10% of the sales price when Company-A sells
(3) Submit JCT tax return
   (3-1) If you paid (1) as IOR = Importer, which means you appoint ACP, then you’re required to pay only the difference amount (2) – (1)
   (3-2) If you paid (1) but you were not IOR = Importer, then you’re required to pay all the amount of (2). You can’t deduct (1).


Please be careful that only the IMPORTER can deduct the input JCT (import consumption tax) at the time of tax filing mentioned above (3). In other words, if another IOR service provider became the IMPORTER when you import, basically it would not be possible for the non-resident entity to deduct the input JCT (import consumption tax). Therefore, you have to pay all the amount of (2) to a tax office (mentioned above (3-2).

On the other hand, if you import with ACP, means that you became an IMPORTER thus you can deduct the input JCT (import consumption tax), when you do JCT tax return mentioned above (3). Therefore, you only need to pay the difference amount (2) – (1) to a tax office (mentioned above (3-1).

This is one of the significant advantages to use ACP service, not IOR service.

For this reason, we strongly recommend using ACP so that you can become IOR.




[Our Service]

Our ACP Service


[Knowledge Pages]

What is ACP? – Attorney for Customs Procedures

Steps of using ACP, how foreign entity can import into Japan by ACP

What is IOR? – Importer of Record

Amazon won’t become an IOR

Customs Valuation System in Japan

Customs Valuation When You Import By ACP

Consumption Tax in Japan


ACP’s Limitation

ACP’s Qualification

ACP’s registration


[Recent Updates]

ACP Japan Became Amazon’s SPN Provider as Qualified ACP Service Provider

IOR Service


Import into Japan by ACP – Atorney for Customs Procedure