Exporter of Record (EOR) in Japan for Non-Residents

Last reviewed: 27 July 2026 · Sources: Japan Customs, NTA, METI (linked inline)

When goods leave Japan, someone must be named as exporter on the export declaration (輸出申告) filed with Japan Customs. That party — the exporter of record (EOR) — is legally responsible for the declaration, carries the export-control obligations, and is the only party who can treat the shipment as a tax-exempt export for Japanese consumption-tax purposes. This guide explains who can hold the role and how a foreign company with no Japanese entity can be the exporter of record itself by appointing an Attorney for Customs Procedures (ACP, 税関事務管理人). One caution before we start: this page is about the customs exporter of record, not the “employer of record” HR service that hires staff on your behalf abroad. The two share an acronym and nothing else.

What “exporter of record” means in Japan

Japanese law never uses the English phrase “exporter of record”. The functional equivalent is the export declarant: under Article 67 of the Customs Act (関税法), the person who intends to export goods must declare them to customs and obtain an export permit (輸出許可) before shipment. The party named on that declaration is what logistics people abroad call the EOR. The export permit document (輸出許可書) issued back by customs names that party — and, as covered below, holding permits in your own name is what later unlocks the consumption-tax exemption.

In practice the declaration itself is filed electronically through NACCS by a licensed customs broker (通関業者) acting on the exporter’s behalf. Brokerage is a separate, licensed function — being the exporter of record does not mean you push the buttons yourself, it means the declaration is made in your name and on your responsibility.

Who can be the exporter of record

Any individual or company in Japan that actually exports goods can declare them. The interesting question is the non-resident case. There is no free-standing rule saying “the exporter must be Japanese”; instead, the residency requirement flows from Customs Act Article 95: a person with no domicile or residence in Japan (for companies, no principal office) cannot process customs procedures except through a Japan-resident Attorney for Customs Procedures (ACP, 税関事務管理人). Without an ACP, the declarant must in practice be a Japan-based party.

Article 95 covers customs procedures generally — export as well as import declarations. Japan Customs’ own guidance, Customs FAQ 9601 (Japanese original), expressly lists import and export declarations among the procedures the ACP handles for a non-resident. So a foreign company with no Japanese entity can be the exporter of record on a Japanese export declaration, provided it appoints an ACP first.

The non-resident route: appointing an ACP

The ACP can be any individual resident in Japan or any Japanese-registered company — in practice usually a customs broker, a trade consultancy or a group company. The mechanics, per Customs FAQ 9601 and Japan Customs’ ACP-system reform page:

1. Choose an ACP with an address (for companies, head office) in Japan.
2. File Customs Form C-7500 with the customs office having jurisdiction, before the first declaration. Since 1 October 2023 the notification must state the relationship between you and the ACP and attach documents evidencing the delegation contract (power of attorney etc.). Changes and termination use Form C-7510; electronic filing goes through NACCS (procedure codes GT7 / GT8).
3. Obtain an exporter code (next section).
4. Classify the goods for export control (該非判定) and obtain a METI licence if required (see export controls).
5. If you want to recover consumption tax, additionally appoint a tax agent (納税管理人) for the National Tax Agency side and register as a taxable person (see consumption tax).
6. Ship: your customs broker files the export declaration in your name; keep every export permit (輸出許可書).

Getting an exporter code (輸出者符号)

Export declarations in NACCS identify the exporter by a code (輸出者符号, exporter code — see Customs FAQ 9703). Three kinds exist, and which one you use depends on who you are:

For a non-resident EOR the practical sequence is: appoint the ACP first, then apply for a JASTPRO code or a customs-issued code. Your customs broker or ACP will usually handle the application as part of onboarding.

Typical use cases

The non-resident EOR structure exists because in these situations there is often no Japanese party willing — or legally appropriate — to be the exporter:

• Auction and used-equipment purchases. A foreign buyer picks up vehicles, machine tools, farm equipment, collectibles or excess inventory in Japan and ships them out in its own name. Japanese sellers frequently refuse to appear as exporter for goods they no longer own, and an intermediary exporter would capture the consumption-tax refund (see below).
• Exhibition and demo returns. Equipment brought to a Japanese trade fair or customer demo goes back to the overseas owner afterwards; the venue and the local partner have no reason to take exporter-of-record responsibility.
• Repair and warranty returns. Goods repaired in Japan are re-exported to their overseas owner, or defective units are pulled back to the factory; the repair vendor often declines to be exporter for goods it does not own.
• Inventory pull-outs and mis-delivered cargo. A foreign seller repatriating unsold fulfillment stock, or returning cargo that entered Japan in error, may find no suitable Japanese exporter at all.

ACP providers that support the EOR route typically ask for a power of attorney, company registry documents, the valuation basis and product catalogues at onboarding — and run an export-control screening before accepting the engagement.

Export controls: METI licences and classification

Security export control under the Foreign Exchange and Foreign Trade Act (FEFTA, 外為法) attaches to the exporter. Article 48(1) requires whoever exports specified categories of goods to obtain a licence from the Minister of Economy, Trade and Industry (METI, 経済産業省); the list controls and catch-all controls implementing it are set out in the Export Trade Control Order (see METI’s application guide and English overview).

The statute contains no residency qualifier and no carve-out for non-resident exporters. Official guidance does not address the non-resident-EOR case in so many words, so treat this conservatively: assume that classification of the goods against the control lists (該非判定, “applicability determination”) and any licence application are your obligations as exporter of record. Used machine tools, semiconductor-related items, sensors, and high-spec electronics are frequent triggers, which is exactly why reputable ACPs screen EOR engagements and may refuse controlled goods. When in doubt, ask METI or a licensed customs broker before the goods are committed to shipment.

Consumption tax: exports are zero-rated

Exports from Japan are exempt from consumption tax (JCT) under Article 7 of the Consumption Tax Act — the 輸出免税 regime explained in NTA Tax Answer 6551. Although Japanese law calls it an exemption, it works like zero-rating: the export sale itself bears no JCT, while input tax on related Japanese purchases remains creditable. The proof condition matters: the exporter must retain the export permit (輸出許可書) — issued in its own name — as evidence.

This is why being the EOR yourself, rather than exporting through an intermediary, decides who gets the money. A foreign buyer that pays 10% JCT on goods purchased inside Japan can recover it only by (1) being the exporter of record holding export permits in its own name, (2) registering as a JCT taxable person, and (3) filing JCT returns through a Japan-resident tax agent (納税管理人), appointed under Article 117 of the General Act of National Taxes and covered in NTA Tax Answer 6635. If a Japanese trading company exports on your behalf instead, the zero-rating and any refund belong to that company, not to you (JETRO Q&A on export JCT).

Note that the 納税管理人 (NTA side) and the 税関事務管理人 (customs side) are two separate appointments with separate filings — a non-resident running the full buy-in-Japan-and-export cycle typically needs both. Also, input credit on your Japanese purchases generally requires qualified invoices from registered sellers under the invoice system.

Frequently asked questions

Is the exporter of record the same as an employer of record?

No. They share an acronym and nothing else. An employer of record is an HR service that legally employs staff for you in another country. The exporter of record covered here is a customs role: the party named as exporter on a Japanese export declaration, responsible for the declaration, export-control compliance and the consumption-tax treatment of the export.

Can a foreign company with no entity in Japan be the exporter of record?

Yes. Customs Act Article 95 lets a non-resident conduct Japanese customs procedures, including export declarations, after appointing a Japan-resident Attorney for Customs Procedures (ACP) and notifying customs on Form C-7500 before the first declaration.

Do I need a JASTPRO code to export from Japan?

You need an exporter code of some kind on the declaration. Japanese companies normally use their corporate number. A non-resident can apply for a JASTPRO code once it has appointed an ACP, or use a customs-issued code, which Japan Customs provides free of charge to parties without a corporate number.

Can I recover Japanese consumption tax on goods I buy in Japan and export?

Often, yes — but only if you are the exporter of record. Export sales are exempt from consumption tax with credit for input tax, and the exporter named on the export permit can register as a taxable person, file returns through a tax agent (nozei kanrinin) and credit or reclaim the tax paid on its Japanese purchases. If a Japanese intermediary exports for you, the exemption belongs to the intermediary, not to you.

Does the ACP obtain export licences or classify my goods for me?

No. The ACP is a procedural agent for customs paperwork. Classifying goods against the export-control lists and obtaining any METI licence remain obligations of the exporter, and the ACP does not become liable for duties, taxes or penalties.

How long does it take to become a non-resident exporter of record?

Plan for a few weeks before the first shipment: the C-7500 notification must be filed and accepted before the export declaration, an exporter code must be issued, and the goods should be classified for export control. ACP providers typically quote around two weeks for the customs notification alone.

Related reading

• Importer of Record (IOR) in Japan
• The ACP appointment procedure
• Selling in Japan without a local entity
• Find a warehouse or 3PL in the directory