Introduction
At ACP Japan, we specialize in helping foreign businesses—particularly those without a physical presence in Japan—navigate the often complex landscape of Japanese import and export procedures.
Drawing from our extensive experience, this article highlights some of the key challenges international companies face, and how our services as an Attorney for Customs Procedures (ACP) and JCT Tax Representative can provide strategic, compliant, and practical solutions. These solutions enable foreign companies (non-residents) without a local entity to successfully import to and export from Japan.
.
.
1. Lack of a Local Importer or Exporter in Japan
Under Japanese Customs Law, foreign companies without a registered address in Japan are not permitted to act as the Importer of Record (IOR) or Exporter of Record (EOR).
However, by appointing an Attorney for Customs Procedures (ACP)—also known as a Customs Procedures Agent (CPA)—foreign businesses can legally take on the role of importer or exporter in Japan.
Traditionally, a Japanese buyer would serve as the importer. But in today’s evolving trade environment, we are seeing an increasing number of cases where no Japanese entity is involved in the import/export process. Common examples include:
- Cross-border e-commerce sellers (e.g., Amazon FBA, Rakuten) importing goods into Japanese warehouses
- Temporary imports for international shows, exhibitions or expo
- Equipment or servers imported for internal use (e.g., in data centers)
In such cases, there is no designated local importer at the time of customs clearance, often resulting in the goods being held at Japan Customs. While we regularly assist in resolving these urgent situations, we strongly recommend that companies appoint an ACP before shipping to avoid unnecessary delays, storage costs, or compliance issues.
🔗 Learn more about ACP service (Import) / (Export)
.
.
Recap:
You have No Japan Importer?
→ Appoint an Attorney for Customs Procedures (ACP) so that your company can legally act as the Importer of Record (IOR) in Japan.
You have No Japan Exporter?
→ Likewise, appoint an ACP so that your company can act as the Exporter of Record (EOR), even without a physical presence in Japan.
.
.
2. Evolving Importer Requirements in Japan: What You Need to Know
Since the update to Japan’s Customs Law in October 2023, the criteria for becoming an importer have become more stringent. One of the most notable changes is that foreign companies can no longer import goods using the name of an unrelated Japanese company.
Many of our clients retain ownership of their goods at the time of import. In such cases, the foreign entity itself must be recognized as the Importer of Record (IOR)—which requires appointing an Attorney for Customs Procedures (ACP) to legally act on its behalf in Japan.
**
The ACP also plays a critical role in tax matters. To be eligible for a refund or deduction of the 10% Japan Import Consumption Tax (JCT), the importer must be officially listed as the Importer of Record (IOR) on the Import Permit document.
🔗 Who Can Be an Importer in Japan
.
.
.
.
3. Understanding Import Taxes in Japan: Customs Duties and JCT
Importing into Japan generally involves two types of taxes:
- Customs Duty: While tariff rates differ based on the HS code classification, the majority of industrial goods imported into Japan are either exempt from duties or taxed at relatively low rates.
- Japan Consumption Tax (JCT): A flat 10% tax applied to the CIF value + duty at the time of import.
Tax Filing and Payment to the Tax Office
After importing goods, you are allowed to collect 10% Japan Consumption Tax (JCT) from customers upon domestic sales. If you are a JCT-exempt entity, no further action is required.
If you are a JCT-taxable entity, you must file a JCT tax return with the local tax office and pay the collected sales JCT. During this process, you may deduct or claim a refund of the JCT paid at the time of import.
Only the Importer of Record Can Claim Input Tax Credit
The right to claim an input tax credit for import JCT belongs exclusively to the Importer of Record (IOR). This is why appointing an Attorney for Customs Procedures (ACP) is critical. If the foreign company does not act as the importer—such as when a third party is listed as the IOR—the company may lose the right to reclaim the import JCT, resulting in a significant financial loss.
Compliance with the Japanese Invoice System
Since October 2023, Japan has implemented a new JCT Invoice System, similar to the European VAT compliance framework. Foreign sellers must consider whether to register as a Qualified Invoice Issuer, particularly when selling to JCT-registered buyers in Japan. If a foreign seller is not registered as a Qualified Invoice Issuer, the buyer may be unable to fully claim input JCT through their JCT tax return.
To maintain good business relationships, it is often advisable to register proactively. However, once registered as a Qualified Invoice Issuer, you can no longer be treated as a tax-exempt entity and must begin filing and paying JCT accordingly.
Necessary to Appoint a Tax Representative
To complete this process—registration and JCT filing—a Tax Representative (usually a certified Japanese tax accountant) must be appointed separately from the ACP.
We work closely with trusted tax professionals to provide comprehensive, one-stop support for both ACP and JCT Tax Representative services.
🔗 Import Duty and JCT Overview
.
.
4. Customs Valuation: Getting the Import Value Right
One of the more intricate aspects of Japanese import procedures is determining the correct import value for customs declaration—also known as Customs Valuation. In most cases, the CIF-based transaction value between an unrelated foreign seller and a Japanese buyer is used as the basis.
However, a common question we receive from foreign clients is whether they can use a cost-based value between their overseas affiliates and suppliers. Unfortunately, under Japanese Customs rules, the answer is generally no. The transaction value method can only be applied when the seller is outside Japan and the buyer is a Japanese-based entity.
When a valid transaction price is not available, customs authorities require an alternative valuation method. If it is apparent that the goods will be sold in Japan, the domestic selling price—adjusted for local logistics and distribution costs—is typically used as the basis for customs valuation.
That said, Japan’s relatively low tariff rates mean that this valuation process often has a greater impact on Import JCT than on Customs Duty. And if your company is properly set up as the Importer of Record (IOR) and has appointed a JCT Tax Representative, the JCT is recoverable, not an added cost. So, there’s no need to be overly concerned about a slightly higher declared import value.
🔗 How to Determine Import Value for Amazon FBA
🔗 Q&A for Customs Value (Japan Customs Website)
.
.
.
.
5. Export Procedures: Compliance and Tax Benefits
Foreign companies can also export from Japan by appointing an ACP to act as their Exporter of Record (EOR).
However, export controls in Japan—particularly those concerning sensitive technologies like semiconductors—have become increasingly strict. Exporters must perform product classification, determine whether an export license is required, and in some cases, seek approval from the Ministry of Economy, Trade and Industry (METI). At ACP Japan, we support our clients through these regulatory steps as part of our ACP service.
In addition to regulatory compliance, foreign exporters may benefit from a JCT exemption. When properly registered, they can claim a refund of input JCT paid on goods or services purchased in Japan for export purposes.
However, only the official EOR can apply for this exemption. This is why it is crucial to appoint an ACP and be properly recognized as the Exporter of Record.
🔗 Export Success Case Using ACP
🔗 Japan Security Export Control
.
.
Conclusion: Building a Compliant and Scalable Presence in Japan
Importing and exporting in Japan involves more than logistics. It requires careful compliance with customs and tax regulations, along with a clear understanding of legal requirements for foreign businesses.
By partnering with a qualified Attorney for Customs Procedures (ACP) and a JCT Tax Representative, international companies can confidently expand their operations into the Japanese market—knowing that every step is legally compliant and strategically supported.
If you have any questions or would like to discuss your specific case, please feel free to reach out to us at ACP Japan.
.
.
.
.
Our Customers – Japan IOR / Attorney for Customs Procedures (ACP) Service
All our clients have successfully become Japan Importer of Record (IOR) and imported goods into Japan under our guidance.
Logistics Companies with Collaboration Experience
Here is a list of our partner logistics and forwarding companies with whom we have had successful collaborations. Please note that this list is not exhaustive, as we are open to working with any logistics or forwarding companies. As Attorneys for Customs Procedures (ACP), we represent non-resident clients (IOR) and coordinate with these logistics companies, who manage the transportation of goods to and from Japan.
