How ACP Japan supported HS code review and Japan Customs consultation for classification under HS 7020 instead of HS 7007.19 with a 3.5% duty rate
Overview
ACP Japan supported an overseas gaming accessories brand in reviewing the HS code classification of a gaming glass mouse pad imported into Japan and in communicating with Japan Customs through oral and e-mail-based classification guidance.
During the customs clearance process, Japan Customs initially raised the possibility that the product could be classified under HS 7007.19, “Safety glass – toughened safety glass, other,” because the product used tempered or strengthened glass. If HS 7007.19 had applied, the product would have been subject to a 3.5% customs duty rate, which could have resulted in a significant duty cost impact for repeated imports into Japan.
However, the product was not designed as safety glass in the ordinary sense. Unlike automotive safety glass, architectural safety glass, or smartphone protective glass, the product was not primarily intended to protect people, buildings, vehicles, or devices from impact. Its core function was to improve mouse glide, control, operational feel, and abrasion resistance for gaming and e-sports use.
ACP Japan reviewed the product’s material composition, structure, intended use, sales presentation, the WCO Explanatory Notes, and previous import records. Based on this review, we presented the position to Japan Customs that the product should be classified under HS 7020.00, “Other articles of glass,” which is duty-free.
As a result of the consultation, the classification approach was confirmed: the gaming glass mouse pad was appropriately classifiable under HS 7020.00-000, “Other articles of glass” duty-free, rather than HS 7007.19, “Safety glass – toughened safety glass, other” with a 3.5% duty rate.
This outcome helped the importer optimize customs duty costs while also strengthening the compliance basis for future continuous imports into Japan.
Background: Why HS Code Classification Was an Issue
The product was a gaming glass mouse pad sold by an overseas gaming accessories brand for the Japanese market.
Unlike ordinary fabric mouse pads, this product used a glass surface. It was designed to provide a smooth operating surface, stable mouse control, high glide performance, abrasion resistance, and tracking performance suitable for gaming.
The classification issue arose because the product description included terms such as “tempered glass,” “toughened glass,” and “chemically strengthened glass.” Based on these descriptions, Japan Customs considered whether the product might fall within HS 7007.19, which covers certain safety glass consisting of toughened glass.
HS code classification is a critical element of import compliance.
The HS code determines the applicable customs duty rate and can also affect import regulations, statistical codes, and compliance controls. If a product is classified incorrectly, the importer may either pay unnecessary customs duty or face post-clearance issues such as additional duty assessments, delinquent tax, penalties, or customs inquiries.
For this reason, the product could not be classified merely by looking at the words “tempered glass” in the product description. It was necessary to examine the actual nature of the product, including its principal use, objective function, product structure, and the relevant classification principles under the WCO Explanatory Notes.
Key Classification Question: Is Every Tempered Glass Product “Safety Glass” Under HS 7007?
The central question was whether a product using tempered glass should automatically be classified as safety glass under HS 7007.
HS 7007 covers safety glass consisting of toughened or laminated glass. The customs officer initially considered HS 7007.19, which would have carried a 3.5% customs duty rate.
However, customs classification is not determined only by the material name or manufacturing process. In many cases, the use, function, and essential character of the product must also be considered.
The WCO Explanatory Notes refer to examples of safety glass such as glass for motor vehicles, windows, doors, portholes, protective goggles for workers or drivers, lenses for gas masks or diving helmets, and bullet-proof glass.
These examples share a common feature: their essential purpose is safety or protection. They are designed to reduce danger upon breakage, protect people from impact, or provide protective functionality.
The gaming glass mouse pad at issue had a different nature.
Its primary role was to improve the mouse operating experience. The product was purchased and used for better glide, control, durability, and gaming performance. Even though the product had strengthened glass and shatter-resistant features, those elements were supplementary to its function as a mouse pad. They did not make the product safety glass in its essential character.
ACP Japan’s Review and Position
ACP Japan first reviewed the product’s actual structure and commercial use.
The product was used as a gaming and e-sports mouse pad, with features such as:
- Smooth glide performance from the glass surface
- Stable mouse control
- Abrasion resistance for long-term use
- Tracking performance suitable for gaming
- Anti-slip structure on the back side
- Supplementary shatter-resistant structure to reduce scattering risk upon breakage
Based on these features, ACP Japan concluded that the product’s essential character was not safety glass. Rather, it was a glass article used as a gaming mouse pad.
ACP Japan then explained this position to Japan Customs using the following key points.
1. The Product’s Main Purpose Was Gaming Performance, Not Safety Protection
The product was marketed and sold as a gaming mouse pad.
Customers purchase this type of product for its smooth surface, stable mouse movement, accurate tracking, abrasion resistance, and ease of cleaning.
In other words, the core value of the product lies in improving the mouse operating environment.
It is not comparable to automotive safety glass, architectural safety glass, or protective glass, whose primary function is to protect people, property, vehicles, or devices from impact.
By clarifying the product’s principal use, ACP Japan distinguished it from the type of safety glass contemplated under HS 7007.
2. Tempered Glass Alone Should Not Determine Classification Under HS 7007
The product used tempered glass or a similar strengthened glass material.
However, the use of tempered glass does not automatically mean that the finished product must be classified under HS 7007.
A product made with tempered glass may still be classified according to its actual use and essential character. For example, glassware, plates, furniture components, decorative items, and other glass articles may be classified under different headings depending on their nature and function.
Therefore, ACP Japan explained that the classification should not be based solely on the phrase “tempered glass.” Instead, the product should be considered as a glass article used as a gaming mouse pad, making HS 7020.00, “Other articles of glass,” the more appropriate classification.
3. The Shatter-Resistant Feature Was Supplementary
The product included a structure intended to reduce the risk of scattering if the glass were to break.
However, this feature did not define the product as safety glass. It was a supplementary feature that supported the safe use and durability of the product as a gaming mouse pad.
This distinction was important.
In customs classification, the existence of a particular feature does not necessarily determine the classification. The key question is whether that feature gives the product its essential character.
ACP Japan explained that the product’s essential character remained that of a gaming mouse pad, while the shatter-resistant function was secondary.
Result: Classification Under HS 7020.00 Was Confirmed
Through oral and e-mail-based consultation with Japan Customs, ACP Japan confirmed that the product was appropriately classifiable under HS 7020.00, “Other articles of glass,” rather than HS 7007, “Safety glass.”
Japan Customs indicated that a product is not automatically classified under HS 7007 simply because it is made of tempered glass. The purpose and function of the product must be considered.
For this gaming glass mouse pad, the primary purpose was to improve mouse control, glide, and abrasion resistance. The features related to reducing danger or scattering upon breakage were supplementary and did not determine the essential character of the product as safety glass.
As a result, the product could be declared under HS 7020.00, which is duty-free, instead of HS 7007.19 with a 3.5% duty rate.
Outcome: Duty Cost Optimization and Stronger Import Compliance
If the product had been classified under HS 7007.19, a 3.5% customs duty rate would have applied.
By confirming the classification approach under HS 7020.00 duty-free, the importer was able to use an HS code that better reflected the actual nature and use of the product. This helped optimize customs duty costs for ongoing imports into Japan.
The benefit of this case was not limited to duty savings.
When Japan Customs questioned the classification, ACP Japan organized the relevant product information, including structure, use, product characteristics, WCO Explanatory Notes, and past import records. This created a defensible classification rationale that could be explained to Japan Customs and used for future import operations.
This also helped the importer strengthen its import compliance framework and reduce the risk of repeated customs classification issues for future shipments.
ACP Japan’s Support Services
ACP Japan provides practical support for foreign companies, cross-border e-commerce sellers, IT infrastructure companies, and brand owners importing into Japan.
Our services include:
- HS code classification review
- Customs duty rate confirmation
- Prior consultation with Japan Customs
- Support for oral and e-mail-based classification guidance
- Support for written advance rulings
- Coordination with customs brokers
- Responses to Japan Customs inquiries
- Customs valuation and import declaration value consultation
- Non-resident importer support through ACP / Attorney for Customs Procedures
- Import support for Amazon FBA, cross-border e-commerce, and overseas brands selling into Japan
ACP Japan does not simply provide a mechanical HS code check. We review the actual nature of the product, its materials, intended use, sales format, transaction flow, logistics flow, and past import records. Based on this review, we prepare a customs declaration position that can be clearly explained to Japan Customs.
Where necessary, ACP Japan communicates directly with Japan Customs and helps importers build a stable and compliant framework for continuous imports into Japan.
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.
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.
Which regions in Japan are we covering?
Any region in Japan, we can handle.
What is difference between ACP and IOR?
ACP is not the Importer. ACP enables non-resident entities to become IOR (Importer of Record).