Steps of ACP, how foreign entity can import Japan by ACP | ACP JAPAN - Attorney for Customs Procedures

ACP stands for, Attorney for Customs Procedure. In principle, foreign entities cannot become the Importer of Record – IOR. However, if the entity appoints an ACP, the foreign entity can become the IOR.

Let’s look at the steps of how you import your goods by appointing ACP. 1st step is “Regulatory check”. “ACP registration” is the second step. And lastly “start shipment of the goods to Japan”.

As a first step, we need to check the eligibility to handle the goods, especially by looking at import regulations of the goods. ACP is not capable to handle all kinds of goods.

If the goods are subject to specific regulations such as Act on Pharmaceuticals and Medical Devices, the non-resident entity shall not be allowed to import by appointing ACP. So, we always check the eligibility as a first step. We can support you to make a decision whether your goods is regulated item or not.

The second step is to proceed with ACP registration. The foreign entity and ACP together, need to submit ACP application documents to a respective Japan Customs Office.

ACP can lead the preparation of the application documents on behalf of the foreign entity, but some information is necessary to provide by the foreign entity such as Company Registry, Power of Attorney, etc.

Under the application process, ACP has a series of discussions with Japan Customs. At this timing, we should also discuss with Customs Officers regarding how to set a proper customs value of the import goods. In total, it takes 2 weeks to complete the ACP registration on average.

Once we obtain the acceptance letter from the Japan Customs Office, now you’re entitled to become an IOR. You can start shipping your goods to Japan by using one of the logistics providers.

In the meantime, ACP leads the preparation of the documents required for the import clearance, such as invoices and evidence materials of the customs value to be used. When the products arrive in Japan, ACP will coordinate these documents with the designated logistics provider, so that the logistics provider can proceed with import clearance in Japan.

Once the import clearance has been done, the logistics provider can deliver the goods to the destination where the foreign entity would like to send them, such as the Amazon FC warehouse in Japan.

YouTube – The steps of how foreign entities can import to Japan by using ACP

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 the smooth and compliant import and export procedures.
Preparation and review of 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. We also advise on customs valuation (import declaration value) and its supporting documentation, HS classification, and country of origin to ensure compliance with Japanese customs requirements.
Advisory on customs valuation (import declaration value), HS codes, duty rates, and origin (including advance rulings).
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).
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 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:

Quotation Review to Contract Conclusion: Upon receiving your contact details, we will promptly provide a quotation for your review.
Commencing the Registration of ACP (Attorney for Customs Procedures) to Japan Customs: This process is generally completed in about two weeks.
Initiation of First Shipment, Import/Export

Track Record – Attorney for Customs Procedures (ACP) Services

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

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.

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

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:

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 time does it require to get ACP’s registration?

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

Prepare the necessary documentation between us
Start pre-consultation with Japan Customs Office and proceed initial review
Submit paper-based set of application documents to Japan Customs Office for final review

What kind of documents to be necessary for ACP application?

Not limited, but for instance – Power of Attorney, Company Registry, The calculation method of Customs Valuation, Catalog of the import goods, business/logistic flow

ACP can handle all kinds of goods?

Whereas many ACP service providers do not handle regulated items, our company’s competitive advantage stems from our ability to manage such products. We can support regulated items, including cosmetics, PSE-regulated products, foodstuffs, and tableware.