Fundamentals of Calculating Import Declaration Values Based on Japan’s Customs Tariff Law
or the imported goods, adjusted to a CIF basis. This is referred to as the principal method of determination under Article 4, Paragraph 1 of the Customs Tariff Act of Japan.
However, this method can be used only where there is an “import transaction” under the Customs Tariff Act. In general, an “import transaction” requires both of the following conditions:
- There is a sale/purchase transaction for the goods being imported into Japan; and
- The buyer is located in Japan.
For example, where goods are sold by an overseas seller to a Japanese buyer/importer, and the Japanese buyer imports the goods into Japan, the CIF-adjusted sales price may generally be used as the declared customs value.
On the other hand, if a foreign importer purchases goods from an overseas supplier before importing them into Japan, that overseas purchase price cannot normally be used as the customs value for the Japanese import declaration. This is because there is no import transaction involving a buyer located in Japan.
This issue commonly arises in Amazon FBA import cases. Amazon International Sellers typically bring their own goods into Amazon FC warehouses in Japan while retaining ownership of the goods at the time of import. Therefore, the principal method under Article 4, Paragraph 1 cannot normally be applied.
In such cases, the customs value must be determined using one of the alternative valuation methods provided under Article 4-2 and the following provisions of the Customs Tariff Act.
For Amazon FBA shipments, the import declaration value is most commonly determined using an alternative method under Article 4-4 of the Customs Tariff Act, by applying, on a mutatis mutandis basis, the domestic sales price method set out in Article 4-3. Under this approach, certain domestic costs, such as import duties, import consumption tax, Amazon referral fees, Amazon FBA fees, and domestic transportation costs, are deducted from the domestic sales price in Japan.
This calculation approach is commonly referred to as the Deductive Method.
Deductive Valuation Technique
The calculation method under the deductive valuation method is as follows:
Step 1: Deduct domestic expenses from the selling price in Japan
From the domestic selling price, deduct Amazon selling fees, fulfillment costs (FBA fees), and any other deductible domestic expenses (such as customs clearance fees and domestic transportation costs).
Example:
JPY 77,000 (Domestic Selling Price)
− [JPY 11,550 (Amazon Selling Fee) + JPY 1,100 (Fulfillment Cost)]
= JPY 64,350
Step 2: Back-calculate the import value by removing duties and taxes
The amount calculated in Step 1 is then divided by a factor reflecting the applicable customs duty and consumption tax rates.
Please note that the applicable customs duty rate depends on the HS code and can only be confirmed once the HS classification has been determined.
Example:
JPY 64,350 ÷ 110%
= JPY 58,500
Assumption: Customs duty rate 0% and Japanese Consumption Tax rate 10%.
In this example, JPY 58,500 represents the customs declaration value per unit. This value is derived by deducting domestic expenses and taxes from the selling price in Japan to determine the appropriate import declaration value.
As noted above, determining the appropriate customs value for import declaration purposes requires confirmation of the applicable customs duty rate. Since customs duty rates vary depending on the HS classification of the imported goods, accurate HS classification is also a critical consideration.
We assist clients with HS classification reviews, customs duty rate verification, and, where necessary, prior consultations and advance rulings with Japan Customs. Through this process, we help ensure that import declarations are accurate, compliant, and appropriately supported from customs perspectives.
Required Screenshots as Evidence of Sales Price and Fees
Japan Customs requires sellers to provide clear evidence of the sales price and any deducted fees. The following documents are typically requested:
Evidence of Sales Price:
1. Screenshot of the Amazon.JP Sales Website at [www.amazon.co.jp/dp/ASIN NUMBER] 
2. Screenshot from Inventory Management at the Amazon Seller Central
Evidence of Amazon Fees (Referral Fees, Fulfillment Costs, etc.):
1. Screenshot of the Revenue and Cost Simulator 
2. Cost Report:
In some cases, you may also be required to submit the Fulfillment by Amazon Cost Report 
As your trusted Attorney for Customs Procedures (ACP), also known as a Customs Procedure Agent or CPA, in Japan, ACP JAPAN is committed to meticulously preparing all required documentation and supporting screenshots for the import declaration process. You can rely on our professional guidance for your customs-related needs.
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
- Preparation and filing of all required documents for ACP registration with Japan Customs.
- Coordination and communication with relevant stakeholders, including Japan Customs, logistics providers, and customs brokers to ensure smooth and compliant export and import procedures.
- Preparation and review of export and import documentation, including commercial invoices and shipping documents.
Proper customs clearance requires accurate identification and statement of the shipper, consignee / Exporter of Record (EOR), and Importer of Record (IOR) on B/L, AWB, and Commercial Invoice. We provide practical guidance on correct documentation practices. - Advisory on customs valuation (export and import declaration value) and supporting documentation, HS classification, duty rates, and country of origin (including advance rulings), to ensure compliance with Japanese customs requirements.
- 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.
- Export Control / Security Trade Control Support (assistance in preparing non-applicability certificates for items the exporter has determined to be non-controlled, and transaction screening, including catch-all controls, etc.)
- Maintenance and retention of records required under the Japan Customs Law.
- Provision of professional trade and customs advisory services to address and resolve issues that may arise during export or import 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 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 300 clients across more than 40 countries.
