What is ACP? – Attorney for Customs Procedures - ACP JAPAN - Attorney for Customs Procedures

ACP stands for Attorney for Customs Procedures and is also known as a Customs Procedure Agent or CPA. In Japan, an ACP handles import and export customs procedures on behalf of a non-resident importer or exporter.

Let us briefly explain when and why an ACP is necessary under the Japanese customs system.

In principle, Japan Customs does not permit foreign entities to act as the Importer of Record.

However, even such a foreign entity can import as a non-resident importer, if the entity appoints an ACP who can handle the customs procedure on your behalf.

Let’s look at an example. Assuming that a foreign entity wants to ship the goods to an Amazon Fulfillment Center in Japan. Under the Amazon’s FBA program, the consumers are not yet decided at the timing of the import. Therefore, the foreign entity does not have a Japanese resident entity who can act as an importer. Also, Amazon, announces that they won’t become an importer. So, what should they do?

In this case, using ACP is a most straightforward solution. You can import by yourself if you appoint a Japanese resident entity as ACP. Amazon, also releases the guidance to international sellers :

“If you do not have a Japanese entity to act as the importer of record, it is mandatory that you appoint an Attorney for Customs Procedure (ACP). Overseas Sellers, as non-resident importers, can generally rely on a program called ACP to help bring their inventory into Japan. An ACP is a resident Japanese entity who registers with Japan Customs as your agent to help with entries and communications.” – Amazon’s guidance “Understand ACP and IOR guidance”.

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

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:

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

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:

*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).

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.

Japan Consumption Tax (JCT) Compliance

Understanding the handling of JCT (such as payment of import JCT, collection of sales JCT from customers, and JCT returns) is crucial to avoid significant cost burdens. This is a vital aspect, so please ensure a thorough understanding to determine the most optimal business model.

Basic Process of JCT Handling

The JCT treatment for foreign corporations without a base in Japan, importing and then selling in Japan, can be broadly outlined in the following three steps:

At Import: Pay import VAT (10% of the declared value) to customs – Supported by ACP (Attorney for Customs Procedures)
At Sale: Collect VAT (10% of sales) from customers
Final Tax Return (usually annually): Deduct the import VAT paid (step 1) from the JCT collected from customers (step 2), and pay or receive the difference to/from the tax office – Supported by a Tax Representative (Certified Tax Accountant)

Note: Using ACP to become the importer (IOR) is essential for JCT deductions and refunds. If another company acts as the IOR, you cannot deduct the input tax (step 1), and must pay the entire VAT collected (step 2) to the national tax authorities, leading to significant costs.

If you are a JCT-exempt business, the process ends at steps 1 and 2. For taxable businesses or invoice-registered businesses, step 3 (Final Tax Return) is obligatory.

In the Final Tax Return (step 3), if the JCT paid (step 1) exceeds the provisional JCT received (step 2), the difference is refunded. Conversely, if the provisional JCT received (step 2) exceeds the JCT paid (step 1), the difference must be paid to the tax office.

Is Being the Importer Important?

It is very important. Without acting as the importer (IOR) through ACP (Attorney for Customs Procedures), you cannot deduct input tax in step 3. You must pay the full amount of JCT collected in step 2 to the tax office, with no possibility of a refund, resulting in substantial costs. Be careful not to let another company act as the importer.

Are we a Tax-Exempt Business?

Tax Filing Obligations of Nonresidents and Foreign Corporations

First, the consumption tax received from customers in Step 2 above should basically be paid to the national tax office. Consumption tax is imposed on transfers, etc. of assets made in Japan. Therefore, even if a nonresident or foreign corporation transfers assets in Japan, it is subject to consumption tax and is obligated to pay the tax.

In some cases, such as exempt businesses, it may not be necessary to pay the tax to the national tax office.

However, the following are examples where one cannot qualify as an exempt business and must file for consumption tax:

<Examples of Entities Required to File JCT Tax Returns (Non-Exempt Businesses)>

Qualified Invoice Issuers:
Businesses registered as qualified invoice issuers under Japan’s invoice system.
Businesses with Taxable Sales Exceeding JPY 10 Million During the Base Period:
Entities whose taxable sales in Japan during the base period (generally the fiscal year two years prior) exceed JPY 10 million.
Businesses with Taxable Sales Exceeding JPY 10 Million During the Specific Period:
Entities whose taxable sales in Japan during the specific period (generally the first six months of the previous fiscal year) exceed JPY 10 million.
Newly Established Corporations with Capital of JPY 10 Million or More:
Newly established corporations (including certain newly established corporations) with capital or investment of JPY 10 million or more during a taxable period without a base period.
Foreign Corporations with Capital of JPY 10 Million or More Deemed to Have No Base Period: (Applicable to taxable periods starting on or after October 1, 2024) *
Foreign corporations without a base period and with capital or investment of JPY 10 million or more at the start of the fiscal year are not exempt from consumption tax obligations.
Businesses Opting for Taxable Enterprise Status:
Entities that voluntarily select to be treated as taxable enterprises.

*Important Notes on the 2024 JCT Tax Law Amendment
Under the 2024 amendment of Japan’s Consumption Tax Law, the exemption for foreign corporations initiating business in Japan has been significantly tightened.

Foreign corporations with no base period and capital of JPY 10 million or more at the beginning of the fiscal year are no longer exempt from consumption tax obligations during that fiscal year.

Starting from taxable periods beginning on or after October 1, 2024, a foreign corporation that has an existing base period but was primarily conducting business outside Japan and subsequently starts taxable business activities in Japan after the day following the end of its base period will be deemed as having no base period.

Being “deemed to have no base period” means that if the corporation’s capital or investment is JPY 10 million or more, it will incur consumption tax obligations from the deemed base period fiscal year onward.

As a result of this amendment, many foreign corporations will be required to file consumption tax in Japan from their first year of business operations in the country.

Disclaimer: The above outlines the general principles of Japan’s consumption tax obligations. Each company’s specific tax liability should be confirmed by consulting with a licensed tax accountant.

Can Tax-Exempt Businesses Receive Refunds?

Yes, it’s possible, but a final tax return (step 3) is necessary. Even if you’re an exempt business, you are still able to opt to submit a “Taxable Business Selection Notification” to the tax office, intentionally becoming a taxable business to file a final tax return and receive a refund for the paid import JCT. This is applicable only if the JCT paid at import (step 1) exceeds the provisional JCT collected (step 2). Note that using an ACP (Attorney for Customs Procedures) to act as the importer is essential for input tax deduction and refunds.

Is It Better to Become a Registered Invoice Issuer?

This depends on individual circumstances, but generally speaking, for B2B where customers are corporations, it’s better to be a Registered Invoice Issuer (as corporations file JCT returns and need qualified invoices for input tax deductions). For B2C where customers are primarily consumers, the necessity is somewhat reduced (as most consumers do not file JCT returns).

Many companies seem to become Registered Invoice Issuer without fully understanding the system. Being a registered business mandates the filing of a final tax return (step 3). Please seek advice from appropriate experts.

Is Support from a Certified Tax Accountant Necessary?

For non-residents conducting tax office procedures (step 3) in Japan, appointing a Tax Representative is required. The ACP handles customs procedures, while the Tax Representative deals with national tax (tax office) matters. Under the Certified Tax Accountant Act, the following tasks are exclusively performed by the Certified Tax Accountants, making their support essential:

Preparation of tax documents
Tax representation
Tax consultation

Our company, in partnership with Certified Tax Accountants skilled in international taxation, will provide support in these areas.

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?

ACP, is not capable to handle all kinds of goods. If the goods are subject to specific regulations requires importer to be resident in Japan, such goods can not be handled under the ACP.