Last reviewed: 27 July 2026 · Sources: Japan Customs, NTA, METI (linked inline)
On this page
- What "importer of record" means at Japanese customs
- Who may lawfully be the importer: the October 2023 rule
- Why carriers and Amazon refuse to be your IOR
- Three routes into Japan, compared
- Becoming a non-resident IOR via an ACP
- Customs valuation when you import your own stock
- Where the ACP route breaks: regulated goods
- Post-clearance audits and penalties
- Frequently asked questions
Every commercial shipment into Japan needs an importer of record (IOR): the party that files the import declaration, owes the customs duty and import consumption tax (JCT, 消費税), and answers to Japan Customs afterwards. Since 1 October 2023, Japanese customs law is strict about who that party may be — and the answer reshaped how foreign e-commerce sellers and equipment vendors structure their shipments. This guide explains the legal test, the three lawful routes for a foreign company without a Japanese entity, and the products for which the standard workaround does not work.
What "importer of record" means at Japanese customs
Japan’s Customs Act (関税法) never uses the English term "importer of record." The functional equivalent is the import declarant (輸入申告者) — "the person who intends to import the goods" — who files the import declaration under Article 67. Under Article 6, customs duty is owed by "the person importing the goods," and import JCT is collected together with the duty from the same person (Japan Customs Answer 1103; Customs Act, e-Gov).
The importer’s name and address are formal import-declaration items under the Customs Act Enforcement Order (関税法施行令 Art. 59), a status they gained in the October 2023 reform. Since 12 October 2025, declarations must additionally state whether the goods are mail-order (通販) goods, the platform name where applicable, and the post-clearance delivery destination (Japan Customs reform page). Customs now sees exactly who imports what for which platform — worth keeping in mind throughout this guide.
Who may lawfully be the importer: the October 2023 rule
Effective 1 October 2023, Japan Customs amended its Basic Circular to define who the import declarant must be (official reform page; customs leaflet, PDF):
- Goods imported under an import transaction (輸入取引 — the sale that caused the goods to arrive in Japan): the importer is a party to that transaction — typically the Japanese buyer, or the non-resident seller where goods go to a fulfillment warehouse with no Japanese buyer yet.
- Goods imported without an import transaction (your own inventory, leases, consignment, repairs): the importer is the person who, at the time of declaration, holds the right to dispose of the goods after release — the leaflet’s examples include the lessee, the consignment seller selling in its own name, the processor or repairer.
- A mere import agent (輸入代行者) entrusted only with procedures can no longer be named as importer. The previously common practice of borrowing a Japanese forwarder’s or agent’s name on the declaration is expressly disallowed.
Japan Customs’ own case collection spells out the consequence for e-commerce: for fulfillment-service cargo (Amazon FBA and similar), the non-resident seller itself must be the import declarant, appointing an Attorney for Customs Procedures to do so (Japan Customs case collection, PDF). A foreign company can absolutely be the IOR — for warehouse-stocking models it is generally required to be.
Why carriers and Amazon refuse to be your IOR
The right-to-dispose rule explains the refusals that surprise many first-time shippers. A marketplace, carrier or warehouse has no ownership of your goods and no authority to dispose of them, so naming one as importer is exactly the "nominal importer" arrangement the 2023 reform abolished. Amazon Japan does not act as IOR or consignee for inbound FBA shipments (per Amazon Seller Central policy, login required — and consistent with the customs case collection above); shipments arriving without a valid importer are held at customs.
Express carriers take the same line on Delivered Duty Paid (DDP) shipments, where the foreign seller bears clearance and taxes and is therefore functionally the importer. DHL’s global customs guidelines, for example, require a power of attorney from the named destination-country IOR on file before clearance (DHL Express Global Customs Customer Guidelines, PDF). A non-resident doing DDP into Japan therefore needs either its own IOR arrangement via an ACP, or a Japanese consignee genuinely willing and qualified to be the importer.
Three routes into Japan, compared
A foreign company without a Japanese entity has three lawful structures. The consumption-tax column matters most: import JCT is 10% of (CIF value + duty), and whether anyone can recover it depends entirely on who is named on the import permit (輸入許可書).
| Route | Importer on the permit | Import JCT recoverable by | Setup burden | Watch out |
|---|---|---|---|---|
| 1. Japanese distributor buys your goods | The distributor (party to the import transaction) | The distributor, in its own JCT returns | Low — a genuine buy-sell distribution agreement | Must be a real buyer with disposal authority; nominal importers are disallowed since Oct 2023 |
| 2. You import as non-resident IOR via an ACP | Your foreign company | Your company — only if it is a JCT taxable person filing returns via a tax agent (納税管理人); otherwise the 10% is unrecoverable by anyone | Medium — ACP appointment (Form C-7500), importer code, customs broker, tax agent | Regulated goods need separate domestic licence holders; audit exposure sits with you |
| 3. Incorporate a Japanese subsidiary | The subsidiary | The subsidiary, in its own JCT returns; it can also hold product-law licences | High — incorporation, registered office, ongoing corporate filings and tax presence | Cost and commitment; usually overkill for market testing |
Becoming a non-resident IOR via an ACP
Customs Act Article 95(1) requires a person without a domicile or principal office in Japan to appoint a Japan-resident Attorney for Customs Procedures (ACP, 税関事務管理人) before processing customs formalities (Japan Customs FAQ 9601). Any Japan-resident individual or Japanese corporation can serve — no special licence is needed, though in practice ACPs are customs brokers, trade consultancies or a group company. Note that an ACP that is not a licensed customs broker (通関業者) cannot itself perform clearance as a business, so a broker is still engaged alongside.
Mechanics, per FAQ 9601 and the customs reform page:
- Notify customs on Form C-7500 before the first declaration; changes or termination use Form C-7510. Electronic filing via NACCS uses procedure codes GT7/GT8.
- 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, registry extracts).
- You need an importer code for declarations: customs issues a code (税関発給コード) free of charge to parties without a Japanese corporate number (Japan Customs code page), and a JASTPRO code is also available to a non-resident once an ACP is appointed.
- The ACP files declarations, attends inspections, handles duty and JCT payment mechanics, and receives customs correspondence and refunds on your behalf.
What the ACP does not do: it never becomes the taxpayer. Duty and import JCT remain your debt under Article 6, and the ACP holds no product-law licences for you. The customs-side filing can double as the tax-agent notification for consumption tax collected by customs, but if you sell inside Japan you separately need a tax agent (納税管理人) appointed to the National Tax Agency for JCT registration, returns and refunds — two appointments, two authorities (FAQ 9601; NTA Q&A 16/27).
Customs valuation when you import your own stock
Transaction value — invoice price as the customs value — is only available where there is an import transaction: a sale to a buyer in Japan that caused the shipment. Japan Customs excludes from that definition transactions where the buyer has no address, office or place of business in Japan (Customs Answer 1403). A non-resident IOR moving its own unsold inventory into a Japanese warehouse — the FBA pattern, and consignment sales generally — has no import transaction, so the price you paid your factory is normally not usable (Customs Answer 1404).
Valuation then falls to the alternative methods, in practice most often the deductive method: your Japanese selling price minus commissions or profit and general expenses, post-arrival transport and insurance, and duty and other public charges. Expect to support the numbers with listing pages, marketplace fee reports and sales data. Systematic undervaluation of fulfillment cargo was the stated reason for the whole 2023 reform, so this is where customs looks first.
Where the ACP route breaks: regulated goods
The ACP solves one problem only — customs-procedure residency. Product-safety laws have their own domestic-presence requirements that an ACP cannot satisfy:
| Product category | Law | Japan-based role required | Source |
|---|---|---|---|
| Electrical appliances and other PS-mark goods | Product Safety 4 Laws (amended, effective 25 Dec 2025) | Overseas businesses selling PS-mark products directly to Japanese consumers must file notification as a specified importer (特定輸入事業者) and appoint a domestic administrator (国内管理人) | METI |
| Wireless / radio devices | Radio Act (電波法) | Technical conformity (Giteki, 技適) certification before the devices can lawfully be used in Japan; operating non-conforming equipment as an unlicensed station risks up to 1 year confinement (拘禁刑) or a ¥1,000,000 fine | MIC Q&A; Radio Act Art. 110 |
| Cosmetics, quasi-drugs, pharmaceuticals, medical devices | PMD Act (薬機法) | A Japan-based Marketing Authorization Holder (MAH, 製造販売業者) or designated MAH must hold the marketing licence; the ACP does not confer this status | Customs FAQ 1805 |
| Food and food-contact goods | Food Sanitation Act (食品衛生法) | Import notification to quarantine; in practice a domestic food importer files, and ACP firms commonly handle food by acting as the designated importer themselves | ACP practitioner guide |
If your catalogue includes any of these, budget for the extra domestic role (or a licensed partner) before the first shipment — customs clearance is not the binding constraint.
Post-clearance audits and penalties
Japan runs a self-assessment system, and the accuracy of classification, valuation and declarations is the importer’s responsibility — including a non-resident importer’s. Customs conducts post-clearance audits against non-resident IORs, with the ACP acting as the conduit for documents and correspondence during an investigation while liability stays with you (FAQ 9601; PwC Japan on non-resident importers and the ACP system).
The 2023 amendment also gave customs enforcement teeth against non-residents who ignore the rules: the Director General of Customs may formally demand that a non-resident appoint an ACP by a deadline and, on failure, may designate a related domestic party as its ACP (Customs Act Art. 95, paras 3–5; Japan Customs). Combined with the platform-name and delivery-destination declaration items in force since October 2025, cross-border e-commerce flows are increasingly easy for customs to target. Declare properly from the first shipment.
Frequently asked questions
- Can Amazon be my IOR in Japan?
- No. Amazon Japan does not act as importer of record or consignee for inbound FBA shipments (per Amazon Seller Central policy, login required). A non-resident seller must import in its own name after appointing an Attorney for Customs Procedures (ACP), or buy-sell through a Japanese partner that lawfully qualifies as the importer, such as a genuine distributor or an own-name consignment seller.
- Can a foreign company be the importer of record in Japan?
- Yes. A foreign company with no Japanese entity can file import declarations in its own name if it first appoints a Japan-resident Attorney for Customs Procedures (ACP) under Customs Act Article 95 and notifies customs on Form C-7500 before the first declaration. Since October 2023 the notification must state the relationship between the parties and attach documents evidencing the delegation contract. For fulfillment-warehouse stock the foreign seller is not just allowed but generally required to be the importer.
- Does the ACP take over my customs duty and tax liability?
- No. The ACP handles procedures only: declarations, attending inspections, payment mechanics, receiving documents and refunds. Customs duty and import consumption tax remain the debt of the importer under Customs Act Article 6, and responsibility for accurate declarations, valuation and post-clearance audits stays with the non-resident importer.
- If I ship DDP, can my Japanese customer deduct the import consumption tax?
- No. Only the person named as importer on the import permit may credit import JCT as input tax. If you import as a non-resident IOR, your Japanese customer cannot deduct that JCT, and you can recover it only by being a JCT taxable person filing returns through a tax agent. A narrow exception in Consumption Tax Basic Circular 11-1-6 applies only in limited quota or exemption cases under strict conditions.
- Do I need an ACP for every product I sell into Japan?
- An ACP solves the customs residency requirement and nothing more. Electrical and other PS-mark goods, radio equipment needing the Giteki mark, cosmetics and other PMD Act products, and food each require a separate Japan-based licence or notification holder that an ACP does not replace.
- How long does it take to become a non-resident IOR?
- Plan for a few weeks before your first shipment. The C-7500 notification must be filed with customs before your first import declaration, and providers commonly quote around two weeks for onboarding. You also need an importer code: customs issues a code free of charge to parties without a Japanese corporate number, and a JASTPRO code is also available to a non-resident once an ACP is appointed.