Hand-Carry Imports to Japan – For Non-Resident Businesses

Foreign businesses without a physical presence in Japan (non-residents) can hand-carry goods into the country, but customs procedures vary depending on value and volume. Below are the two main options:

 

1. Simplified Customs Clearance (Traveler’s Baggage)

If you’re carrying a small quantity of goods (generally up to 3 units per item) with a taxable value below approximately JPY 300,000, the items may be processed as traveler’s baggage under simplified clearance.
This method is quick, straightforward, and often does not require a customs broker.

 

2. Commercial (Formal) Customs Clearance

For shipments exceeding the simplified clearance limits in quantity or value, formal customs clearance is required.

In principle, a non-resident entity cannot independently complete Japanese customs procedures as the Importer of Record (IOR). However, by appointing SK Advisory Inc. as its Attorney for Customs Procedures (ACP), also known as a Customs Procedure Agent or CPA, the non-resident entity can legally complete the import process under its own company name.

 

✅ Our Role

• We introduce reliable customs brokers experienced in hand-carry shipments
• We act as your ACP (so that you can legally act as Importer of Record (IOR) in Japan and manage all related customs procedures)
• We ensure full legal compliance and seamless importation

Planning to hand-carry goods into Japan? Let our experienced team support your import process.

 

🔗 Resources

• Japan Customs – Traveler’s Baggage Guidelines

• JETRO – Import Procedures for Hand-Carried Items

 

 

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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.

ACP Japan is honored to support international companies and government organizations participating in EXPO 2025 Osaka, Japan, by serving as their Attorney for Customs Procedures (ACP), also known as a Customs Procedure Agent or CPA, to ensure smooth and compliant import and export operations.

Even without a physical address in Japan, overseas exhibitors can import goods under their own name by appointing an authorized ACP such as ACP Japan, allowing them to act as the Importer of Record (IOR).
Without a properly designated IOR, general customs clearance in Japan cannot be completed.

We’ve received numerous urgent inquiries from exhibitors whose goods have already arrived in Japan without prior ACP arrangements — often due to a lack of awareness about the ACP requirement.
(Considering how common this situation has become, we believe the EXPO organizers should have provided clearer communication on this matter to international participants.)

If you or your affiliated exhibitors are in need of ACP support or are encountering import-related challenges in Japan, feel free to reach out to us. Our team is prepared to respond quickly and reliably.

As a trusted ACP provider, ACP Japan is proud to play a small yet meaningful role in this once-in-a-generation global event. We remain committed to helping international exhibitors navigate Japanese import and export procedures with confidence and peace of mind.

 

 

Track Record – Attorney for Customs Procedures (ACP) / Customs Procedure Agent (CPA) Services

We have supported import and export operations in Japan for over 300 clients across more than 40 countries.

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:

1. There is a sale/purchase transaction for the goods being imported into Japan; and
2. 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%.

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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:

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 Procedure) to Japan Customs: This process is generally completed in about two weeks.
3. 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.

    

Exporters shipping goods from Japan are responsible for ensuring compliance with applicable security export control regulations. This includes conducting list-control classifications and transaction reviews under catch-all controls and, where necessary, obtaining an export license from the Ministry of Economy, Trade and Industry (METI).

ACP Japan supports foreign corporations acting as non-resident Exporters of Record (EORs) by serving as their Attorney for Customs Procedures (ACP), also known as a Customs Procedure Agent or CPA. The foreign corporation acting as the EOR remains responsible for export control compliance, while ACP Japan supports the coordination of customs procedures and provides practical assistance with export control documentation for items confirmed by the EOR as not subject to list controls.

Reference: Ministry of Economy, Trade and Industry, Security Trade Control Guidance (Link)

     

Various Laws to Consider When Exporting

Customs Law Related:

  – Customs Law: Prohibited items (narcotics, child pornography, items infringing intellectual property rights, copies, imitations, etc.).

Security Trade Control (Export Control) Related:

  – Export Trade Control Order: Goods
  – Foreign Exchange Order: Services (technology)

Other Laws Related:

  – Cultural Property Protection Law
  – Wildlife Protection and Hunting Law
  – Livestock Infectious Disease Prevention Law
  – Rabies Prevention Law
  – Plant Quarantine Law
  – Road Transport Vehicle Law
  – Narcotics and Psychotropic Drugs Control Law, Cannabis Control Law, Opium Law, Stimulants Control Law

Framework of Security Trade Control Regulations

1) List Control:

Prohibited goods and technologies that should not be exported (advanced technology, dual-use risks):
  – Goods: Items 1 to 15 in Schedule 1 of the Export Trade Control Order.
  – Services: Items 1 to 15 in Schedule of the Foreign Exchange Order.

2) Catch-All Controls:

Prohibited export recipients (UN arms embargo countries or concerning individuals/organizations):
  – Goods: Item 16 in Schedule 1 of the Export Trade Control Order “All except food and wood.”
  – Services: Item 16 in Schedule of the Foreign Exchange Order “Technologies related to all except food and wood.”

Penalties Related to Export Control

Criminal Penalties (Maximum):

  – Up to 10 years imprisonment
  – Fine up to 1 billion yen (for corporations)
  – Fine up to 30 million yen (for individuals)

Administrative Penalties:

  – Prohibition on exporting goods or providing technology for up to 3 years
  – Prohibition from taking executive positions in other companies

Export Control Procedures

Step-1: Yes-No Determination

Determine whether the goods or technology to be exported falls under the “List Control” goods etc.

  – Specific items are listed in “Schedule 1 of the Export Order” or “Schedule of the Foreign Exchange Order”, and their specific specifications are confirmed in “Goods etc. Ministerial Ordinance”.

  – Item verification: Match export items against the contents of Schedule 1 of the Export Order or the Foreign Exchange Order. 

  – Specification verification: Match against the Goods etc. Ministerial Ordinance. The “Goods & Technology Matrix Table” on the Ministry of Economy, Trade and Industry website is helpful for matching export item specifications.

  – Using the “Item-by-Item Comparison Table” or “Parameter Sheet” can be more efficient. Available for purchase from the CISTEC website.

  – If not applicable, a non-applicable certificate is created.

Step-2: Transaction Examination

Check who the counterpart is (inquirer, end-user), and what the uses are to decide whether to proceed with the transaction.

(1) “End-Use & End-User” verification and decision.
(2) Decision on the applicability of “Exception Provisions” (such as gratuitous exception, small amount exception).
(3) Decision on the applicability of “General Permit”.
(4) Check concerning Catch-All Controls.
  → If necessary, apply for individual permission from the Ministry of Economy, Trade and Industry.

Step-3: Shipping Management, Export

  – Ensure that the Yes-No Determination and Transaction Examination are properly completed.
  – Verify that the goods or technology to be exported is the same as what was determined and examined.
  – If a permit is required for export, ensure it is obtained.

Export Permit Application

When exporting goods or providing technology that falls under regulation, it is necessary to obtain prior permission from the Ministry of Economy, Trade and Industry (normally, electronic application through NACCS).  

 

Compliance with Export Control Standards (enacted April 2010)

– Those engaged in exporting or providing technology as a business (exporters etc.) must comply with the Exporter Compliance Standards according to Article 55-10, Paragraph 4 of the Foreign Exchange Law.  

– Exporters etc. dealing with security-sensitive specified important goods (List Control items) must comply with Standards I and II. Those not dealing with such items must comply with Standard I only.  

Tips for Export Management (Utilization of Forms)

By establishing and utilizing company-specific forms (formats), export management tasks can be securely implemented, and illegal exports can be prevented.

Form Examples:  

– Yes-No Determination: Yes-No Determination Form  

– Transaction Examination: Use Checklist, End-User Checklist, Clear Guideline Sheet, Transaction Examination Form  

– Shipping Management: Shipping Checklist  

Reference: Ministry of Economy, Trade and Industry Security Trade Control Guidance Materials  

Gratuitous Exception (exemptions where permit application is waived)

Gratuitous Notice: Goods imported gratuitously as specified by the Minister of Economy, Trade, and Industry under Article 4, Paragraph 1, Item Ho and He of the Export Trade Control Order.

Goods imported gratuitously and subsequently returned without consideration (9 cases extracted):

– Goods exported from Japan that are repaired in Japan and re-exported.
– Goods exhibited at exhibitions held in Japan from abroad.
– Goods imported through an ATA Carnet for temporary import.
– Items carried by persons temporarily entering and leaving the country for personal use.
– Goods imported for the purpose of transporting other goods.

Goods to be exported gratuitously as specified (7 cases extracted):

– Goods exported by the International Emergency Assistance Team for use in international emergency assistance activities.
– Goods exported by experts dispatched by the Japan International Cooperation Agency for their use.
– Items carried by persons temporarily leaving the country for personal use.
– Goods exported for the purpose of transporting other goods.

Small Amount Exception (exemptions where permit application is waived)

(1) Items under Items 1-4 of Schedule 1 of the Export Order: No application of small amount exception.
 (2) Goods under Items 5-13 of Schedule 1 of the Export Order, except below (3): Below 1 million yen.
 (3) Goods specified by the Minister of Economy, Trade, and Industry under the provisions of Schedule 3, Item 3 of the Export Order (Schedule 3, Item 3 Notice): Below 50,000 yen.
 (4) Goods under Item 14 of Schedule 1 of the Export Order: No application of small amount exception.
 (5) Goods under Item 15 of Schedule 1 of the Export Order: Below 50,000 yen.
 (6) Goods under Item 16 of Schedule 1 of the Export Order: No application of small amount exception.

  Note: If the destination is a concern country (North Korea, Iran, Iraq, etc.), the small amount exception does not apply.

U.S. Export Control Regulations – EAR (Export Administration Regulations)

A feature of the U.S. EAR is its “extraterritorial application”. When U.S.-origin goods or technology exported from the U.S. are re-exported from the importing country, in addition to review under the domestic laws of that country, an export review based on U.S. law is also required. If applicable, permission must be obtained from the U.S. government.

 Step-1: Check if the item is subject to EAR regulations (CCL – Commerce Control List). 
 Step-2: Check if an ECCN (Export Control Classification Number) exists.
 Step-3: Check if re-export permission is required.
 Step-4: Check if a license exception is applicable.
   → If necessary, apply for permission from the U.S. government.

   

Our Service – Attorney for Customs Procedures (ACP) for Exporter of Record (EOR)

 

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)

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:

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 Procedure) to Japan Customs: This process is generally completed in about two weeks.
3. 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.

As previously mentioned in another article (“Announcement from Japan Customs | Mandatory to Use ACP in Many Cases – Attorney for Customs Procedures”), since October 2023, overseas sellers—especially those operating on e-commerce platforms such as Amazon, Rakuten, and Shopify—have been required in many cases to appoint an Attorney for Customs Procedures (ACP), also known as a Customs Procedure Agent or CPA, and act as the Importer of Record (IOR) themselves.

The practice of designating another Japanese corporation as the importer in name only is no longer considered acceptable under Japanese customs rules. Despite the clear guidance, we continue to observe some businesses offering IOR arrangements that may not align with the revised importer requirements.

The continued prevalence of such questionable practices has prompted us to publish this cautionary article. Sellers operating in Japan should understand and comply with the applicable legal framework to avoid unnecessary penalties and other compliance risks.

Problematic Practices – Violation of Customs Laws

There are instances where transactions seem to exist between overseas businesses and Japanese IORs (who are merely importers in name), with manipulated documents like invoices reflecting undervalued declared prices for customs clearance. In reality, these goods are not directly shipped to fulfillment centers like Amazon but temporarily stored in domestic warehouses. Here, they are labeled before being sent to the final fulfillment destination. This scheme aims to avoid detection by customs as e-commerce products. Such actions are illegal and not in compliance with the law, and I strongly urge an immediate cessation of these practices.

Importing through illegal schemes often leads to undervalued import declarations. Even if customs clearance is initially granted, subsequent Post Clearance Audit by customs can lead to substantial penalties. Legally, the IOR is liable for these payments, which can lead to disputes between overseas sellers and IOR businesses. Typically, the financial burden of import duties and taxes falls on the overseas sellers, making conflicts predictable.

Both the uninformed overseas businesses using these illegal schemes and the IOR operators bear responsibility.

Observing extremely low prices for products by overseas sellers on e-commerce platforms like Amazon often gives an impression of an unfair competitive environment. Legitimate overseas businesses pay appropriate taxes and add these costs to their selling prices, putting them at a disadvantage against sellers who avoid proper tax payments. This unfairness is precisely why the customs system was revised in October 2023.

For businesses with low compliance awareness, the issues likely extend beyond just declared values. Often, they might also be non-compliant with intellectual property laws and other regulations.

 

   

Concerns Over Cost Impact of Customs Valuation/Import Declarations

When overseas sellers import goods for e-commerce into Japan, whether through ACP or as another IOR company, there is no “import transaction” with a Japanese buyer, leading to the exceptional determination method for declared import values, typically based on the domestic selling price.

There are concerns about high valuation leading to excessive duties and taxes. However, this is a determination method based on the Customs Tariff Law, which must be adhered to. The cost impact of the valuation is not as significant as often feared.

The taxes on import are mainly customs duties and consumption tax. Japan’s import tariffs are relatively low on a global scale, and many industrial products are duty-free. As for consumption tax, which is a uniform 10%, it is an indirect tax borne by the final consumer, not a cost for the overseas seller. Taxable businesses regularly file consumption tax returns to the tax office, adjusting the tax paid on imports against the tax collected from sales, neutralizing the cost impact. However, this necessitates that the overseas business itself becomes the importer, achievable only through using ACP.

With the start of the consumption tax invoice system in October 2023, many overseas businesses might have registered as qualified invoice-issuing entity. For B2C businesses, registration as a qualified invoice issuer is not always necessary, but many companies seem to register without fully understanding the system. I recommend that overseas businesses seek advice from qualified professionals to navigate these changes correctly.

As seasoned experts in customs and trade facilitation, we at ACP Japan are here to navigate these complexities on your behalf. Our approach, grounded in professionalism and profound regulatory knowledge, ensures a seamless, compliant, and strategic entry into Japan’s vibrant market.

We invite you to reach out to us — let’s discuss how we can support your business’s successful and compliant expansion into Japan. Your peace of mind is our top priority.

We look forward to your inquiry!

 

   

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:

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

   

 

Japanese Customs System Reform: Clarification of Importer Definitions

Starting October 1, 2023, Japanese Customs has instituted a pivotal reform aimed at addressing the issue of foreign sellers improperly designating third parties (such as forwarders or customs agents) as importers.

This revision necessitates foreign corporations to utilize an Attorney for Customs Procedures (ACP) to assume the role of Importer of Record (IOR) directly in many cases. The practice of merely nominally appointing another entity as the importer is no longer feasible.

Notably, foreign corporations that act as importers themselves, through the engagement of ACP, are eligible for Japan Consumption Tax (JCT) benefits. (link: Consumption Tax Treatment and Benefits of Using ACP).

As a dedicated ACP firm, we ensure compliance with the law to facilitate correct import procedures, allowing you to trust us with your importation requirements confidently. We are eager to engage in further discussions with you.

Revisions Effective October 1, 2023:

Definition of the Importer

   

 

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.

For Foreign Corporations Without a Base in Japan:

We are informing you about the two new systems that commenced in October 2023. These systems are distinct and must be approached separately. However, there are aspects where they intersect and must be understood collectively. Here’s a detailed breakdown:

Japan Customs has clarified the definitions of Importers, necessitating the shift from using IOR Providers to ACP (Attorney for Customs Procedures / Customs Procedure Agent) in numerous instances

Since October 2023, Japan Customs mandated that foreign corporations (non-residents) without a presence in Japan must act as importers themselves in many situations. Utilizing another company to serve nominally as the importer, such as an IOR service provider, will no longer be an option.

To comply with these regulations, foreign corporations lacking a Japanese base need to appoint an ACP (Attorney for Customs Procedures), making the ACP system essential for their operations.

Why this System Change?

There have been instances where foreign corporations, along with importing agents unfamiliar with customs laws or lacking proper compliance awareness, have collaborated. Such collaborations often result in the failure to accurately pay the necessary duties and consumption taxes upon importation by utilizing undervalued invoices, almost simulating a sales transaction. To address this issue, Japan Customs now instructs foreign corporations to engage with ACP. Using ACP mandates that commercial distribution transaction details be presented to the customs office, ensuring the declaration of an appropriate import value.

Typically, the import declaration value is derived by subtracting certain domestic costs from the projected domestic sales price, in line with the Japanese Customs Tariff Law. However, we believe there’s no significant cause for concern regarding this value. Japan’s tariff rate is relatively low on an international scale, and the import consumption tax is primarily a “tax borne by the end consumer”. Though a 10% consumption tax is required at the point of import, it can be recouped from customers during sales. If a tax return is accurately filed, any overpayments will be refunded.

Moreover, to claim credits for the consumption tax on purchases (paid upon importation), the seller—a foreign corporation—must assume the role of an importer. Alongside appointing an ACP, foreign entities should also designate a tax accountant to act as a tax agent. This ensures the accurate filing of consumption tax returns with the tax office.

As seasoned ACP professionals, we lead consultations with Japan Customs proactively to guarantee seamless import customs clearance and oversee the determination of import declaration values, among other critical aspects. Our expertise extends to countless import/export projects, and we pride ourselves on a flawless record of customs clearance.

Qualified Invoice System (QIS) for Japan Consumption Tax (JCT)

The forthcoming alteration pertains to the national tax system.

The advent of the consumption tax invoice system means a surge in overseas companies becoming consumption tax invoice issuers. For a Japanese customer (buyer), during consumption tax return filing, the invoice must be issued by a registered invoice-issuing entity. Otherwise the Japanese customer cannot claim the purchase tax credit on the consumption tax paid to a seller. 

Once Company-A obtains a JCT invoice registration number, it becomes a taxable entity required to file JCT returns regularly.

For non-resident entities (Company-A) importing and selling in Japan, the standard procedure involves three steps:

1. Pay import JCT to customs: 10% of the import customs value.
2. Collect JCT from customers in Japan: 10% of the sales price.
3. File a JCT tax return and pay the net JCT to the tax office.

If Company-A paid the import JCT as the importer using an Attorney for Customs Procedures (ACP), they need only pay the net amount of sales JCT minus import JCT.

If Company-A paid the import JCT but was not the importer, they must pay all the collected sales JCT without deducting the import JCT.

Therefore, using an ACP to act as the Importer of Record (IOR) is crucial for managing JCT deductions and refunds. If another company acts as the IOR, you cannot deduct the import JCT, resulting in significant costs.

We strongly recommend using our ACP services to ensure you can act as IOR, optimizing your JCT handling. Our team has extensive experience helping clients become importers and successfully manage their JCT responsibilities. You can rely on our expertise to navigate these complexities.

 

 

   

 

 

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 ACP Japan, 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.

 

   

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. Mr. Sawada also serves as an external expert for the World Bank’s B-READY project in the field of 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) / Customs Procedure Agent (CPA) Services

We have supported import and export operations in Japan for over 300 clients across more than 40 countries.

 

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:

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

 

The increasing demand for importing and delivering goods to data centers in Japan is largely driven by the tech and AI boom. Often, clients who are non-resident companies seek to deliver goods—either their own or their end-clients’—to these data centers without making a sale. To facilitate this, the clients need to handle the import process into Japan on their own.

However, there’s a challenge: Japanese Customs generally mandates that only resident entities can act as importers. This is where the ACP—Attorney for Customs Procedures, also known as a Customs Procedure Agent or CPA—comes into play. It allows non-resident entities to act as the Importer of Record (IOR), bridging the gap in this process.

At ACP Japan, we possess a wealth of experience in supporting the import and delivery of goods to data centers. Typically, products shipped to these data centers are non-regulated items like servers, switches, transceivers, cables, and more. We’re here to assist you with your needs. Please feel free to contact us.  

 
     

   

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:

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

     

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.

We would like to inform you about a significant revision by Japan Customs clarifying the definition of an importer. This change took effect on October 1, 2023.

Following the revision, there has been an increase in cases where foreign corporations must appoint an Attorney for Customs Procedures (ACP), also known as a Customs Procedure Agent or CPA, and become the Importer of Record (IOR) themselves. Merely designating another entity as the importer in name only is no longer considered acceptable under Japanese customs rules.

In instances other than normal import transactions between an overseas seller and a Japanese buyer, where the importer does not have the authority to dispose of the goods after importation (for example, when a foreign corporation does not become the IOR themselves and nominates a forwarder, customs broker, or another third party who is not involved in the transaction to be the nominal IOR), there is a high probability that approval will not be granted as such nominations are not recognized as legitimate importers, therefore careful attention is required.

As a professional ACP firm, we follow the law to facilitate proper import procedures. You can entrust us with your importation needs with confidence. We look forward to discussing further with you.  

Japan Customs’ Official Guideline for E-Commerce Sellers

Here is the official guideline from Japan Customs. On page 2 of the leaflet, you’ll see a clear comparison:

• On the left side, which reflects the rule before September 30, 2023, it was allowed for an “Import Agency” (such as a logistics or warehouse company) to act as the Importer of Record (IOR).
• On the right side, from October 2023 onward, the Seller must be the IOR by appointing a Customs Procedures Agent — which is what we refer to as an ACP (Attorney for Customs Procedures).

• Japan Customs: Revision of Import Declaration Items and Attorney for Customs Procedure (ACP) System
• Japan Customs Notice – Available in English, Chinese, Korean, and Japanese

Revisions Effective October 1, 2023:

Definition of the Importer

Under Japan Customs practice, the importer is determined as follows.

For cargo imported under an import transaction, such as a normal transaction between an overseas seller and a buyer in Japan, the importer is the buyer in Japan, namely the person who imports the cargo as referred to in Article 6-1(1) of the General Notification of the Customs Act.

In cases other than the above, the importer is the person who has the right to dispose of the import cargo at the time of import declaration.

In addition, another person acting for the purpose of the import, such as those listed below, may also be treated as the importer:

• for cargo imported under a lease contract, the person who rents and uses the cargo;
• for cargo imported for consignment sales, the trustee who sells the cargo in their own name under the consignment arrangement;
• for cargo imported for processing or repair, the person who processes or repairs the cargo; and
• for cargo imported for disposal, the person who disposes of the cargo.

 

Importer Defined as the “Person Having the Right of Disposal”

One of the most notable aspects of the amendment is the clarification that the “person having the right of disposal” is regarded as the importer under Japan Customs law. The term “right of disposal” is similar to ownership, but not identical. Although there is no explicit definition in the customs-related legislation, according to Japan Customs, it refers to the authority to decide how the goods will be handled after being released into Japan—for example, whether to sell the goods or to enter into a sales contract.

 

For additional information, please refer to the following resources:

• Japan Customs: Importer Eligibility and ACP System — English Leaflet
  
• English: Announcement from Japan Customs | Mandatory to Use ACP in Many Cases – Attorney for Customs Procedure 

 

   

Case Study: Directives to use ACP

Case 1: Importing Goods Using FS (Fulfillment Services) by Non-resident Sellers

A non-resident seller plans to import goods for sale domestically using FS provided by EC platform operators. At the time of import declaration, there is no sales contract between the seller and the consumer. The seller (non-resident) is the main entity for sales on the EC platform after domestic pickup of the goods. Therefore, the seller, who aims to sell the goods in accordance with the purpose of import, needs to become the import declarant and appoint Attorney for Customs Procedure (ACP) to carry out the import declaration.

Case 2: Importing Goods Using FS by Non-resident Sellers

A non-resident seller plans to import goods for sale domestically using FS provided by EC platform operators. At the time of import declaration, there is no sales contract between the seller and the consumer. The seller (non-resident) entrusts domestic customs clearance arrangements to Company-A (located in Japan), but the main entity for selling the goods within the domestic market using FS remains the seller (non-resident). It is planned that the seller (non-resident), who intends to sell the goods on the EC platform after domestic pickup, should become the import declarant and appoints Attorney for Customs Procedure (ACP) in accordance with the purpose of import declaration.

A non-resident seller plans to import goods for sale domestically using FS provided by EC platform operators. At the time of import declaration, there is no sales contract between the seller and the consumer. The seller (non-resident) entrusts the transportation of the goods from overseas sellers to Japan to an overseas forwarder, but the main entity for selling the goods within the domestic market using FS remains the seller (non-resident). It is planned that the seller (non-resident), who intends to sell the goods on the EC platform after domestic pickup, will become the import declarant and appoints Attorney for Customs Procedure (ACP) in accordance with the purpose of import declaration.

Case 4: Importing Goods for Consignment Sales

Goods (consignment sales goods) intended for domestic sale by an assignee who has received consignment sales from a non-resident consignor are imported. The imported goods are stored in an FS warehouse and sold on the EC platform under the name of the assignee. The assignee is the main entity for selling the goods within the domestic market using FS.

Either of the following options is necessary:

The consignor (non-resident) who has the authority to dispose of the consignment sales goods becomes the import declarant, appoints Attorney for Customs Procedure (ACP), and carries out the import declaration.

The assignee (i.e., the seller on the EC platform) who conducts the act of selling on behalf of themselves as the purpose of import becomes the import declarant and carries out the import declaration.

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.

The Import Permit Document holds significant importance in import clearance procedures. It serves as evidence for the deduction of Japan Consumption Tax (JCT). When filing periodic JCT returns, this document is necessary to claim deductions or refunds for the amount paid during import. It is crucial to ensure that the Import Permit accurately reflects the information of the Importer of Record (IOR) as it directly impacts the eligibility for JCT deduction.

Non-resident entities utilizing the services of an Attorney for Customs Procedures (ACP), also known as a Customs Procedure Agent or CPA, will have their names clearly stated on the Import Permit as the IOR, allowing them to successfully claim JCT deductions.

Import Permit Document Sample

Upon completion of import clearance procedures, Japan Customs issues an Import Permit document. 

Please refer to the sample Import Permit document below:

 

Japan Consumption Tax (JCT) is set at a fixed rate of 10%. On the other hand, the tariff rate for Customs Duty varies depending on the HS Code assigned to the imported goods. To verify the applicable tariff rate, you can refer to the Japan Customs Tariff Schedule on their official website here:  Japan Customs Tariff Schedule

 

 

Alert: Importer (IOR) Service Provider May Not Be in Compliance with Customs Laws

Attention must be given to cases where IOR service providers or forwarders act as the IOR but mask or omit their information on the Import Permit Document. This raises concerns about their compliance with Japan Customs Law, such as Customs Valuation. It is important to be cautious when encountering such situations as they may indicate underlying issues.

Importers are responsible for paying penalties, such as additional taxes or penalties, when there is a shortfall in the tax amount owed. It is the importer’s obligation to fulfill their tax payment requirements. However, it should be noted that IOR service providers may not be cooperative in the event of a customs post clearance audit.

Unfortunately, we actually observe that some non-resident entities suffer from the fact that the 10% import consumption tax is not deductible (or refundable), and they were penalized by the customs post clearance audit. In the end, they decided to use ACP, not IOR service provider.

While not all IOR service providers are non-compliant, it is observed that certain providers engage in inappropriate practices. Opting for these providers based on cost-saving measures may result in the inability to deduct or refund 10% JCT, leading to hidden costs and detrimental business outcomes.

As a reputable Customs professional, ACP Japan strictly adheres to Japan Customs Law and confidently provides clients with the Import Permit Document. We are listed as the ACP, while clients are appropriately identified as the IOR on the document.  

Benefits of Using ACP

For non-resident entities, choosing ACP is strongly recommended. We ensure full compliance with the Japan Customs Law and offer the best solution for correct JCT deduction/refund.

 

Japanese Customs System Reform: Clarification of Importer Definitions

Starting October 1, 2023, Japanese Customs has instituted a pivotal reform aimed at addressing the issue of foreign sellers improperly designating third parties (such as forwarders or customs agents) as importers.

This revision necessitates foreign corporations to utilize an Attorney for Customs Procedures (ACP) to assume the role of Importer of Record (IOR) directly in many cases. The practice of merely nominally appointing another entity as the importer is no longer feasible.

Notably, foreign corporations that act as importers themselves, through the engagement of ACP, are eligible for Japan Consumption Tax (JCT) benefits. 

As a dedicated ACP firm, we ensure compliance with the law to facilitate correct import procedures, allowing you to trust us with your importation requirements confidently. We are eager to engage in further discussions with you.

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. Mr. Sawada also serves as an external expert for the World Bank’s B-READY project in the field of 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 300 clients across more than 40 countries.

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:

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

 

 

Japan Qualified Invoice System and Compliance JCT (Japan Consumption Tax)

Recently, many companies have been registering as Qualified Invoice Issuers for Japanese Consumption Tax (JCT) due to the new invoice system introduced in October 2023. This new system is similar to the EU’s VAT invoice system.

After October 2023, your Japanese customer cannot claim input JCT credits unless the sellers (suppliers) issue a qualified invoice that includes a JCT registration number. To issue a qualified invoice, sellers (suppliers) need to be a taxable entity and obtain a JCT registration number.

Before October 2023:

Any customer (Company-B) who paid for goods or services could deduct input JCT regardless of whether the seller (Company-A) was registered for JCT. There was no requirement to verify the tax status of the seller.

After October 2023:

Any customer (Company-B) can only deduct input JCT if Company-A, the seller, is registered and can provide a qualified invoice with a JCT registration number. If Company-A cannot issue such an invoice, Company-B may choose not to continue purchases from them. If Company-A sells only to consumers and not businesses, it may not need to issue qualified invoices since consumers typically do not claim JCT tax returns. 

 

Once Company-A obtains a JCT invoice registration number, it becomes a taxable entity required to file JCT returns regularly.

For non-resident entities (Company-A) importing and selling in Japan, the standard procedure involves three steps:

1. Pay import JCT to customs: 10% of the import customs value.
2. Collect JCT from customers in Japan: 10% of the sales price.
3. File a JCT tax return and pay the net JCT to the tax office.

If Company A pays the import JCT as the importer by appointing an Attorney for Customs Procedures (ACP), also known as a Customs Procedure Agent or CPA, it generally needs to pay only the net amount of sales JCT minus import JCT.

If Company-A paid the import JCT but was not the importer, they must pay all the collected sales JCT without deducting the import JCT.

Therefore, using an ACP to act as the Importer of Record (IOR) is crucial for managing JCT deductions and refunds. If another company acts as the IOR, you cannot deduct the import JCT, resulting in significant costs.

We strongly recommend using our ACP services to ensure you can act as the IOR, optimizing your JCT handling. Our team has extensive experience helping clients become importers and successfully manage their JCT responsibilities. You can rely on our expertise to navigate these complexities.

       

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:

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

     

Our Japan Consumption Tax (JCT) Representative Services

At ACP Japan, 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.  

 

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.