Food, drinks & supplements × Foreign seller — no entity in Japan (own-name import via ACP)

Rules verified as of 2026-08-08 · reviewed quarterly (next review: November 2026)

Typical products: Packaged food, beverages, health supplements, food additives

Additives, residual pesticides and labeling are the usual blockers; alcohol adds liquor-tax licensing. Supplements with pharmaceutical ingredients cross into the PMD Act — check before shipping.

Which regimes apply

Food Sanitation Act import notification (食品衛生法)

Food, drinks and supplements — AND food-contact utensils, containers and packaging, and toys for infants — require an import notification (食品等輸入届出) to the quarantine station BEFORE customs clearance. Synthetic-resin food-contact items must comply with the positive list. The notifier must be an importer in Japan.

File 食品等輸入届出 with the quarantine station before clearance (electronic: NACCS)
Prepare composition/material documentation; resin items: positive-list compliance
Expect document review and possible inspection orders on first import

Sources: MHLW — import monitoring

Customs: duty, consumption tax and the importer of record

Every commercial import needs an importer of record with post-release disposal authority, correct HS classification, duty and 10% consumption tax. A non-resident importer files through an Attorney for Customs Procedures (ACP, 税関事務管理人) and needs a tax agent for JCT recovery.

Classify the product (HS code) and check the duty rate
Convert values with the official customs FX rate
Non-residents: appoint ACP (form C-7500) before the first declaration

Sources: Customs Answer 9601 — ACP

→ Tools: tariff finder & landed-cost calculator · customs FX rates · Guides: IOR, ACP

Who can be the importer — verdict

You CAN be the importer of record as a non-resident by appointing an Attorney for Customs Procedures (ACP) before the first declaration, and a tax agent to recover import JCT. BUT product regimes that require a domestic notifier or license holder (PSE, PSC, food sanitation, PMD) are NOT satisfied by the ACP — you need a Japan-side responsible business for those: a partner importer, or (for direct B2C sales of PSE/PSC goods since Dec 2025) a notified 国内管理人.

Your checklist

Appoint an ACP (税関事務管理人) — Customs form C-7500 — before the first import declaration
Appoint a tax agent (納税管理人) with the tax office if you will recover import JCT
Confirm who fulfils each product regime on the Japanese side (see the regimes above)
Register the invoice/classification pack: HS code, duty rate, customs FX rate
[Food Sanitation Act import notification (食品衛生法)] File 食品等輸入届出 with the quarantine station before clearance (electronic: NACCS)
[Food Sanitation Act import notification (食品衛生法)] Prepare composition/material documentation; resin items: positive-list compliance
[Food Sanitation Act import notification (食品衛生法)] Expect document review and possible inspection orders on first import
[Customs: duty, consumption tax and the importer of record] Classify the product (HS code) and check the duty rate
[Customs: duty, consumption tax and the importer of record] Convert values with the official customs FX rate
[Customs: duty, consumption tax and the importer of record] Non-residents: appoint ACP (form C-7500) before the first declaration