What is IOR – Importer of Record

When sending goods to Japan, for import, there must be a Japan Importer of Record (IOR) in place.

The importer, in principle, shall be a Japanese resident person/entity that is responsible for taxes, customs duties as well as import-related regulations.

Unlike other regions, Japan Customs does not permit a foreign entity to act as Japan IOR.

However, by appointing an ACP (Attorney for Customs Procedures), a foreign entity can become a Non-Resident Importer (IOR) and import goods directly.

When Do You Need ACP – Attorney for Customs Procedures?

As a non-resident companies without a presence in Japan to act as the Japan Importer of Record (IOR), you need to appoint an Attorney for Customs Procedure (ACP) to fulfill this role.

By appointing an ACP, you gain the ability to become the Japan IOR and handle the import process independently.

If you require assistance with IOR-related matters, engaging an ACP can provide a suitable solution.

At ACP Japan, we offer ACP services, ensuring a seamless import customs procedure for our non-resident clients.

Advantages of Using ACP

One significant advantage of using our ACP service is that only the importer can deduct input JCT (import consumption tax) during the periodic JCT tax filing. If another IOR service provider becomes the importer, it may not be possible for the non-resident entity to claim the input JCT deduction. We highly recommend utilizing our ACP service to maximize this advantage.

For more details about JCT, please visit : Consumption Tax 

Our ACP Service: The Best Solution for the Japan Importer of Record (IOR) and Exporter of Record (EOR)

ACP is an effective solution for addressing Importer of Record (IOR) and Exporter of Record (EOR) requirements in Japan. Through our ACP service, non-resident entities located outside Japan are able to import and export goods as Non-Resident IOR and EOR.

Below is an overview of our basic scope of work, together with a diagram illustrating the operational structure of the ACP service. Once ACP registration is completed, the non-resident entity can act as the Importer of Record (IOR) and Exporter of Record (EOR) in Japan.

Scope of Work – How We Can Assist

• Consultation with Japan Customs to support successful ACP registration.
• Liaison with relevant stakeholders, including freight forwarders and Japan Customs, to ensure the smooth and compliant import and export of goods.
• Assistance in preparing and reviewing import and export clearance documentation.
• Support in the calculation of customs value, in accordance with the Japan Customs Tariff Act.
• Assistance with advance rulings on HS classification, customs valuation, and rules of origin.
• Import compliance support for regulated products, including Domestic Administrator (sometimes referred to as “Domestic Representative”) Services under the Product Safety Acts (PSE/PSC) and food-related products regulated under the Food Sanitation Act.
• Support for security export control, including list-based classification, catch-all control assessment, and assistance with export license applications to the Ministry of Economy, Trade and Industry (METI).
• Record-keeping support in accordance with Article 95 of the Japan Customs Law.
• Provision of professional trade and customs advisory services to address and resolve issues that may arise during import or export operations.

**Both import and export activities can benefit from the use of an ACP (Attorney for Customs Procedures). This support is applicable in scenarios where a non-resident acts as the Importer of Record (IOR) for imports and as the Exporter of Record (EOR) for exports.

Three Steps to Initiate Shipments Under the ACP Program:

1. Quotation Review to Contract Conclusion: Upon receiving your contact details, we will promptly provide a quotation for your review.

2. Commencing the Registration of ACP (Attorney for Customs Procedure) 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.

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.

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

Attention must be given to cases where IOR service providers or forwarders act as the IOR but MASK (ERASE) 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 (penalty), 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 because the 10% import consumption tax is not deductible or refundable, and they were penalized by the customs post clearance audit. Ultimately, they decided to use an ACP rather than an 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.  

Why choose us?

We specialize in navigating complex issues at the intersection of customs procedures and taxation—an area where our ability to offer practical, comprehensive support from both perspectives sets us apart. Understanding the close relationship between customs duties and national taxes (especially, Japan Consumption Tax – JCT), and addressing both in an integrated manner, is crucial in the context of international trade.

• Customs and International Trade Professionals – Led by our CEO, Mr. Sawada—Certified Customs Specialist and former KPMG professional—ACP Japan provides expert-level support in Customs and international trade.
• Full Compliance with Japanese Customs Law – We ensure full adherence to Japanese Customs Law, including Importer of Record (IOR) structure, HS code classification, and customs valuation. We assist in preparing all essential shipping documents for non-resident entities.
• One-Stop ACP and JCT Tax Representative Service – We offer a fully integrated service for both ACP and JCT Tax Representative needs. Our expertise enables efficient deduction or refund of import JCT through accurate JCT tax filings.
• Multilingual Communication – Our team communicates fluently in English, Japanese, and Chinese, offering smooth coordination with global clients and authorities in Japan.
• Support for Regulated Products – Our ACP/IOR partnership system can manage regulated items, including cosmetics, PSE-products, foodstuffs, and tableware.
• Trusted by Global Clients – Serving around 100 ACP clients annually, including many Amazon sellers, we’re a certified provider on Amazon SPN (Service Provider Network) under Trade Compliance.

Track Record – Attorney for Customs Procedures (ACP) Services

We have supported import and export operations in Japan for over 200 clients across more than 40 countries.

Examples of International Logistics Partners We Have Worked With

We have a proven track record of working with a wide range of logistics providers. As the Attorney for Customs Procedures (ACP), we handle customs-related responsibilities while logistics companies manage transportation and warehousing operations.

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

FAQ for ACP (Attorney for Customs Procedures)

What is the role of ACP (ACP Japan)?

• Representation: ACP (ACP Japan) represents the foreign importer and liaises with Japan Customs and the Forwarding Company/Customs Broker.
• Documentation and Compliance: ACP assists in preparing essential import documents (e.g., Invoices) in compliance with Japan Customs Law and formally requests the Customs Broker to proceed with customs clearance.
• Expert Consultation and Troubleshooting: We are a team of legal experts in Customs Laws, providing direct consultations with Japan Customs to ensure compliance and address issues, including troubleshooting unique challenges in non-resident imports.

How long does it take to complete ACP registration?

It will take approximately 2 weeks until receiving approval from Japan Customs. The breakdown of the task is as follows.

• Prepare the necessary documentation in coordination between the client and ACP Japan
• Start pre-consultation with Japan Customs and proceed with the initial review
• Submit a paper-based set of application documents to Japan Customs for final review

What documents are required for ACP application?

For example, but not limited to: a Power of Attorney, company registry documents, the calculation method for customs valuation, product catalogs for the imported goods, and the business/logistics flow.

ACP can handle all kinds of goods?

While many ACP service providers do not handle the regulated items, our ability to handle those regulated items has become a competitive advantage of our company. We can support the items including cosmetics, PSE-regulated products, foodstuffs, and tableware.

Which regions in Japan are we covering?

We can handle shipments to any region in Japan.

What is the difference between ACP and IOR?

ACP is not the Importer. ACP enables non-resident entities to become IOR (Importer of Record).