What is IOR – Importer of Record?

When you send goods to Japan, for import, there must be an Importer of Record (IOR) in place.

The importer, in principle, shall be a Japanese resident person/entity who’s 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 IOR.

But if the foreign entity apponts ACP (Attorney for Customs Procedure), the entity can be Non-Resident Importer (IOR) then you can import by yourself.

 

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

Attorney for Customs Procedures (ACP) is the best solution for addressing the issue of Japan IOR – Importer of Record. Below is an outline of our primary services and a diagram illustrating the operational structure of the ACP service. Upon successful ACP registration, a foreign entity can become the Japan IOR – Importer of Record.

Basic Scope of Services:

• Consultation with the Japan Customs Office for successful ACP registration. 
• Liaising with stakeholders, including Logistics Forwarding Companies and the Customs Offices, on behalf of non-resident clients (i.e., non-resident Japan IOR) to ensure the secure importation of goods.
• Assistance in preparing the necessary documentation for import clearance.
• Support of calculation of Customs Value (Customs Valuation Formula), in accordance with appropriate compliance under the Japan Tariff Customs Law.
• Documents keeping, required under article 95 – Japan Customs Law

**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

 

 

 

Reform in the Japanese Customs System (Mandatory Use of ACP; IOR services Prohibited)

Effective from October 1, 2023, the Japanese Customs authorities have implemented a significant reform in response to increasing instances where foreign sellers incorrectly designate third parties (like forwarders or customs agents) as importers.

This revision mandates foreign entities to comply with new regulations, which include the compulsory utilization of an Attorney for Customs Procedures (ACP). Under this new framework, it is expressly forbidden for foreign sellers to appoint another Japanese service provider in the role of Importer of Record (IOR).

For additional information, please refer to the following resources:

• Japan Customs: Leaflet(English)  Revision of Import Declaration Items and Attorney for Customs Procedure (ACP) System
• English: Announcement from Japan Customs | Directive to use ACP – Attorney for Customs Procedure 

*We are pleased to announce that our ACP/IOR services can support the importation of various regulated items, including those under the Food Sanitation Act (such as food products, tableware, cooking utensils and kitchen tools).

 

 

 

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 from the 10% import consumption tax is not deductible (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, SK Advisory 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.

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

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

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

Since the seller becomes a taxable entity, the seller is obligated to file JCT tax returns on a regular basis.

For the case of a non-resident entity, when you import and sell to customers in Japan
(1) Pay import JCT to a customs office, 10% of the import customs value when you import
(2) Collect JCT from a customer in Japan, 10% of the sales price when you sell
(3) Submit JCT tax return to a tax office periodically
   (3-1) If you paid (1) as IOR = Importer, which means you appoint ACP, then you’re required to pay only the difference amount (2) – (1)
   (3-2) If you paid (1) but you were not IOR = Importer, then you’re required to pay all the amount of (2). You can’t deduct (1).

 

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

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

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

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

 

 

 

Our 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.

 

 

 

Why choose us?

• Customs and International Trade Professionals – Our CEO, Mr. Sawada, is a Certified Customs Specialist in Japan. With years of experience providing services in the Trade & Customs field, his leadership at KPMG and the establishment of his own company, SK Advisory, ensures our commitment to excellence and high-quality service.
• Full Adherence to Japanese Customs Law – Our top priority is to maintain full compliance with Japanese Customs Law and safely import / export our clients’ goods into / from Japan. We meticulously manage all import compliance aspects, including Japan Importer of Record (IOR) matter, HS code classification and the correct Customs Valuation of goods entering Japan. We support to complete all the necessary shipping documents, such as Invoice, Packing List and BL, on behald of non-resident / foreign Japan IOR.
• Communication in English, Chinese, and Japanese – Our team, with extensive international experience, excels in communication in English, including facilitating English-language meetings, and has earned considerable trust from clients. We also have staff capable of communicating in Chinese, making us equipped to handle Chinese-language support as well. Naturally, as a Japan-based team, we’re totally fluent in Japanese, ensuring seamless communication across these three key languages.
• Reputable and Reliable Partner -The growing demand for our Attorney for Customs Procedures (ACP) services is testament to our quality. We proudly serve clients globally, registering over 50 ACP customers annually. Our consistent track record underscores our reliability and credibility. For a detailed list of our clientele, please visit our “Experiences” section. Our unwavering commitment ensures all our clients successfully acquire Japan IOR status and import goods seamlessly into Japan.
• Recognized ACP Service Provider on Amazon SPN SPN (Service Provider Network) – We are a certified ACP service provider within Amazon’s Service Provider Network (SPN), listed under the Trade Compliance category. Many international Amazon Sellers have successfully become Japan Importers of Record (IOR) through our ACP services.

     

 

Our ACP Service (Attorney for Customs Procedures)

Contact us

 

 

 

[Our Service]

Our ACP Service for Importer of Record (IOR)

Our ACP Service for Exporter of Record (EOR)

 

[Knowledge Pages]

What is ACP? – Attorney for Customs Procedures

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

What is IOR? – Importer of Record

Amazon won’t become an IOR

Customs Valuation System in Japan

Customs Valuation When You Import By ACP

Consumption Tax in Japan

IOR and ACP

IOR Service

ACP’s Limitation

ACP’s Qualification

ACP’s registration

 

[Recent Updates]

Urgent Compliance Alert for E-Commerce Sellers: Avoid Penalties with Japan’s New Import Regulations – Act Now!

October 2023: Introduction of Two New Systems in Japan – (1) Switching from IOR Provider to ACP & (2) QIS: Japan Consumption Tax’s Qualified Invoice System

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

Taxes on Imports: Customs Duty and Japan Consumption Tax (JCT)

Import Permit Document and Alert on IOR Service

New Japan Qualified Invoice System and import JCT (Japan Consumption Tax)