Last reviewed: 27 July 2026 · Sources: Japan Customs, NTA, e-Gov statute texts (linked inline)
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If your company has no entity in Japan but needs to clear Japanese customs in its own name — as importer of record for fulfillment stock, or as exporter of record for goods bought in Japan — there is one appointment you must make before anything ships: an Attorney for Customs Procedures (ACP, 税関事務管理人). This page walks through the actual mechanics: the form, the attachments, where to file, how long it takes, and what the ACP can and cannot do for you afterwards.
What an ACP is and who must appoint one
The legal basis is Article 95 of the Customs Act (関税法). Paragraph (1) says that a person who needs to process customs procedures but has no domicile or residence in Japan — for a company, no principal office in Japan — must appoint someone who does have a Japanese address to process those procedures on its behalf. Paragraph (2) requires the appointment to be notified to customs in advance, before the first declaration. See Japan Customs FAQ 9601 (English), the Japanese original, and the statute text on e-Gov (an English translation is published by the Japan Tariff Association). Japan Customs’ own English materials call this person a “Customs Procedure Agent”; the trade almost universally says ACP. The fine detail — what to file and what to attach — sits in the Customs Act Enforcement Order (関税法施行令) Articles 84 and 84-2 and the Enforcement Regulations (関税法施行規則) Articles 11-2 and 11-3, all listed on Japan Customs’ reform overview page.
Why this matters more than it used to: effective 1 October 2023, Japan Customs clarified who may be the import declarant. A non-resident seller shipping its own stock to a Japanese fulfillment warehouse must now declare in its own name — a Japanese agent hired only to handle procedures can no longer be the nominal importer. Japan Customs’ official case collection (PDF) and leaflet (PDF) state this expressly for fulfillment-service cargo. For that whole population of sellers, the ACP appointment is the gateway to importing at all.
Who can serve as your ACP — and what an ACP is not
Any individual resident in Japan, or any corporation with its head office in Japan, can serve; no licence or qualification is required (Customs FAQ 9601). In practice ACPs tend to be customs brokers, trade consultancies, specialist ACP service firms, or a group company of the non-resident.
Two things an ACP is not:
- Not a customs broker. Customs clearance as a business is reserved for licensed customs brokers (通関業者). FAQ 9601 states that an ACP without a brokerage licence cannot carry out clearance work as a business — so the standard setup is ACP plus a licensed broker, sometimes the same firm wearing both hats, more often two separate firms.
- Not a product-law representative. Regulated goods need their own domestic licence holders: pharmaceuticals, quasi-drugs, cosmetics and medical devices require a Japan-based marketing authorization holder under the 薬機法 (Customs FAQ 1805), and since 25 December 2025 overseas businesses selling PS-mark products directly to Japanese consumers must notify as a specified importer (特定輸入事業者) and appoint a separate domestic administrator (国内管理人) under the amended Product Safety 4 Laws (METI). Appointing an ACP satisfies none of those regimes.
The appointment, step by step
Everything below happens before your first shipment leaves origin. Working backwards from a booking date, allow at least a month.
- Choose your ACP. Decide who will serve: a group company, your customs broker, or a specialist provider. Practical selection points: whether the same firm can also act as your tax agent (納税管理人) on the National Tax Agency side (see below), whether it works smoothly with your forwarder and broker, and — for export work — whether it screens shipments for export-control classification before accepting them.
- Assemble the documents. Since 1 October 2023 the notification must state the relationship
between you and the ACP and include documents evidencing the delegation contract
(Japan Customs reform page).
The working checklist:
Document Notes Notification Form C-7500 (税関事務管理人届出書), two copies The official form (PDF). It doubles as the notification of a tax agent for consumption taxes collected by customs at import. Delegation contract or power of attorney Required attachment since 1 Oct 2023: documents evidencing the delegation between the non-resident and the ACP. Identity documents for both parties Corporate registry extract (登記事項証明書) for the ACP; certificate of incorporation or equivalent registry document for the non-resident (FAQ 9601). Statement of the notifier–ACP relationship A formal notification item since 1 Oct 2023 (e.g. service contract, group company). Transaction-flow chart Commonly requested in practice: a simple diagram of who owns the goods, who sells them, and where they go after clearance. - File Form C-7500 with the right customs office. File in duplicate with the customs office that has jurisdiction over your intended port of declaration — for air freight arriving at Narita or Haneda, that is Tokyo Customs. Electronic filing through NACCS (Japan’s customs single-window system) is also possible, using general-application procedure code GT7 (FAQ 9601). The GT7 filing is labelled as doubling as the consumption-tax tax-agent notification for the import taxes customs collects.
- Get your importer/exporter code. Declarations in NACCS identify the importer by code. A non-resident without a Japanese corporate number applies for a customs-issued code (税関発給コード), which is free of charge and has a dedicated non-resident pathway (Japan Customs code page). Alternatively, a non-resident that has appointed an ACP is eligible for a JASTPRO code (JASTPRO registration terms). Your ACP or broker normally handles the application.
- Allow processing time. There is no statutory deadline for customs to register the notification; practitioners commonly report around two weeks. Build that into the schedule and do not let cargo ship until the appointment is confirmed — goods arriving with no registered ACP sit at the port.
- First shipment. Your broker declares with you as importer of record; the import permit (輸入許可通知書) is issued in your company’s name and duty plus import consumption tax are paid in your name. Two housekeeping points: since 12 October 2025, import declarations must additionally state whether the goods are mail-order goods, the platform name where applicable, and the post-clearance delivery address (Japan Customs); and keep every import permit notice — only the importer named on it can credit the import consumption tax in a Japanese tax return (NTA Q&A 16/26). See our import-tax guide for how that credit works.
Changing or cancelling the appointment
Changes to a registered appointment, and its termination, are notified on Form C-7510 (in NACCS, termination uses procedure code GT8) — see Customs FAQ 9601. Switching providers means filing the termination and the new C-7500; do not leave a gap while shipments are in transit.
The state can also force the issue. Since 1 October 2023, the Director General of Customs may demand in writing that a non-resident file the ACP notification by a specified date, and — if it fails to comply — may designate a domestic party related to the non-resident (a 特定税関事務管理人) to serve as its ACP (Customs Act Art. 95(3)–(5); Japan Customs; statute text). This was aimed at non-resident e-commerce sellers who simply ignored the requirement.
What the ACP does — and does not — do
Per Customs FAQ 9601, the ACP, on the non-resident’s behalf:
- files import and export declarations and other customs procedures (in practice, alongside the licensed broker);
- attends customs inspections;
- handles the payment procedures for customs duty and import consumption tax;
- receives and forwards documents between customs and the non-resident — including documents in customs investigations (Enforcement Regulations Art. 11-3);
- receives refunds.
What it does not do:
- It does not become the taxpayer. Customs Act Article 6 puts duty liability on the person importing the goods (Customs FAQ 1103). No provision transfers that debt, or the import consumption tax, to the ACP.
- It is not an audit shield. The ACP is the conduit for audit correspondence, but the party answerable for declaration accuracy, valuation, and any additional assessment remains the non-resident importer.
- It holds no product licences — see above.
- It is not automatically your tax agent for the tax office. That is a separate appointment, covered next.
ACP vs tax agent (納税管理人): two appointments, two authorities
Foreign sellers routinely confuse the ACP with the tax agent (納税管理人). They are different appointments under different laws, made to different authorities — and a non-resident that imports and then sells in Japan typically needs both (NTA Q&A 16/27).
| ACP (税関事務管理人) | Tax agent (納税管理人) | |
|---|---|---|
| Authority | Japan Customs | National Tax Agency / tax office |
| Legal basis | Customs Act Art. 95 | General Act of National Taxes Art. 117 |
| Covers | Import/export declarations, inspections, duty and import-tax payment mechanics, customs notices, refunds | National tax filings: consumption tax returns, payments and refunds, receiving tax-office correspondence |
| Who can serve | Any Japan-resident individual or Japan-registered corporation | Any Japan-resident individual or corporation (typically a tax accountant, 税理士) |
| Notification | Form C-7500 to customs (or NACCS GT7) | Notification of Tax Agent to the competent tax office (NTA Tax Answer 6635) |
| When you need it | Whenever a non-resident is importer or exporter of record | Whenever a non-resident must file or pay Japanese national taxes without an address in Japan |
One nuance softens the double paperwork: the C-7500 (and its NACCS equivalent GT7) doubles as the tax-agent notification for the consumption taxes collected by customs at import. The tax-agent notification to the tax office for filing consumption tax returns is still a separate filing on the NTA side. The typical full sequence for an e-commerce seller: appoint ACP → import as importer of record, pay duty and import consumption tax → sell domestically → through the 納税管理人, register and file consumption tax returns crediting the import tax shown on the import permits.
What it costs
The customs materials linked above attach no filing fee to the C-7500 notification itself, and the customs-issued importer code is free. The real cost of the route is the ACP provider’s service fee, which is commercial, varies with shipment volume and scope (ACP only, or ACP plus tax-agent and broker coordination), and is not published in any official source — get quotes from more than one provider before committing.
Frequently asked questions
- Does the ACP pay the import duty and consumption tax for me?
- No. The ACP handles the payment procedures, but legal liability for customs duty and import consumption tax stays with the importer of record under Article 6 of the Customs Act. If a post-clearance audit finds underpaid duty, the bill goes to the importer, not to the ACP.
- Is the ACP the same as a customs broker?
- No. The ACP is an administrative agent appointed under Article 95 of the Customs Act. Unless the ACP also holds a customs brokerage licence, the actual clearance filings are still prepared and lodged by a licensed customs broker (tsukan-gyosha). Many brokers offer ACP service, so one firm can hold both roles.
- How long does the ACP appointment take?
- There is no statutory processing period. Practitioners commonly report that customs takes roughly two weeks to register a C-7500 notification, so file it well before your first shipment leaves origin. Shipping before the appointment is registered is a common cause of cargo being held at the border.
- Do I also need a tax agent (nozei kanrinin) for the tax office?
- Usually yes, if you go on to sell the goods in Japan. The C-7500 filed with customs doubles as the tax-agent notification for consumption tax collected by customs at import, but the separate tax-agent notification on the National Tax Agency side is still required before you can file consumption tax returns. They are two different appointments under two different laws.
- What happens if I never appoint an ACP?
- Without an ACP a non-resident cannot process customs procedures, so shipments declared in its name cannot clear. Since 1 October 2023 the Director General of Customs can also formally demand that a non-resident appoint an ACP by a set date and, if it fails to comply, designate a related domestic party as its ACP.
- Can my Japanese 3PL or warehouse act as my ACP?
- Legally yes. Any individual or company with an address or head office in Japan can serve, and no licence is required. Serving as ACP does not make the 3PL the importer of record and does not move any tax liability onto it, but taking on the role is entirely at the operator's discretion, so confirm willingness before you plan your supply chain around it.