Selling into Japan without a Japanese company: your three routes

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

You do not need a Japanese company to sell to Japanese customers. Marketplaces accept foreign sellers, payments clear cross-border, and contracts can be signed from abroad. What actually forces a structural decision is customs: every commercial shipment needs an import declarant (輸入申告者) — the party Japan Customs treats as the importer of record (IOR) — and since 1 October 2023 that party must genuinely own or control the goods. Whoever takes that role decides who pays Japanese import taxes and, crucially, who can get them back. That single fact splits your options into three routes.

The short answer

An entity is optional; an importer is not. Japan Customs itself confirms that a non-resident company can be the import declarant, provided it appoints an Attorney for Customs Procedures (ACP, 税関事務管理人) — a Japan-resident agent notified to customs in advance under Article 95 of the Customs Act (Customs FAQ 9601). For fulfillment-warehouse cargo, customs’ official case collection goes further: the non-resident seller must declare in its own name via an ACP (Japan Customs case collection, Dec 2023). So the realistic routes are:

• Route A — a Japanese distributor or partner buys and imports; you ship FOB/CIF and stay out of Japanese tax entirely.
• Route B — your foreign company imports as non-resident IOR via an ACP, keeps its stock in a 3PL or FBA, and files Japanese consumption-tax returns through a tax agent.
• Route C — you incorporate a subsidiary, which imports and sells like any domestic company.

Route A: a Japanese distributor or partner imports

The traditional route. A Japanese distributor or trading company buys your goods, files the import declaration as the transaction party, pays customs duty and import consumption tax (JCT, 消費税), and — because it is the importer named on the permit — credits that import JCT as its own input tax. You invoice the distributor from abroad and have, in the normal case, no Japanese filings at all.

Pros. Simplicity. The distributor absorbs customs, product-regulation and logistics work, and for licensed categories (cosmetics, food, electrical goods) it may be the only practical importer. No ACP, no Japanese tax registrations, no audit exposure in Japan for you.

Cons. You sell at a distributor price, so the margin between that price and Japanese retail belongs to your partner. You also give up pricing, channel and customer-data control, and any Japanese tax paid in the chain is the distributor’s to recover, not yours. If you later want to run direct-to-consumer sales alongside, you are back to Route B anyway.

The post-2023 caveat. The partner must genuinely be the buyer or hold the right to dispose of the goods after release. Since 1 October 2023, a party entrusted only with procedures — a customs-arrangement agent, a forwarder, a warehouse — can no longer be named as a nominal importer (Japan Customs leaflet; NTA Q&A 16/27). A 3PL can legitimately import only where it sells on consignment in its own name — mere storage plus paperwork does not qualify.

Route B: you import yourself — non-resident IOR via ACP

Your foreign company becomes the importer of record without any Japanese entity. Mechanically:

1. Appoint an ACP. Any Japan-resident person or company can serve. You notify customs on Form C-7500 before the first declaration; since October 2023 the notification must state your relationship to the ACP and attach the delegation contract (Japan Customs reform page). Providers report roughly two weeks for registration.
2. Import in your own name. The ACP files declarations, attends inspections, handles duty-payment mechanics and receives customs correspondence for you (Customs FAQ 9601, Japanese). It is a procedural agent only: liability for duty, import JCT, correct valuation and any post-clearance audit stays with you, and the ACP is not a customs broker unless separately licensed.
3. Register for JCT and recover the import tax. Goods sold while located in Japan are domestic taxable sales even with no entity or office here (NTA Tax Answer 6210). You become a taxable person once base-period sales exceed ¥10 million (NTA Tax Answer 6501), or voluntarily earlier, appoint a Japan-resident tax agent (納税管理人) for filings (NTA Tax Answer 6635), and credit the import JCT shown on your import permits against the JCT you charge customers.

What you gain is the full retail margin, direct control of pricing and channels, and stock positioned inside Japan for next-day fulfillment. What you take on is real compliance: customs valuation for your own inventory cannot use the price you paid your supplier (there is no import transaction), so it typically falls to the deductive method — Japan selling price minus fees and domestic costs — with supporting evidence expected (Customs FAQ 1404). You keep records, face audits, and need both the ACP (customs side) and the tax agent (NTA side) — two separate appointments.

Route C: incorporate a Japanese subsidiary

At some volume, the overhead of a company — usually a stock company (株式会社, KK) or an LLC-type company (合同会社, GK) — starts paying for itself. The subsidiary imports in its own name with no ACP needed, credits import JCT in the ordinary way, issues qualified invoices to business customers, can hire staff, and can hold the product licences that block the ACP route for regulated goods (see below).

The trade-offs are structural: Japanese corporate income tax on the subsidiary’s profits by design, ongoing accounting and filing costs, and the slowest setup of the three routes. Note one tax detail: a newly established company with capital of ¥10 million or more is a consumption-tax payer from its first year (NTA Tax Answer 6503) — usually harmless for an importer, since taxable status is what lets you credit import JCT anyway. Route C is rarely the first step; it is where Route B businesses land once headcount, B2B expectations or licensing make an entity worthwhile.

Comparison: the three routes side by side

Does consignment stock in a 3PL create a taxable presence?

Route B’s tax appeal rests on having no permanent establishment (PE, 恒久的施設): a foreign company without a PE in Japan pays no Japanese corporate income tax on its trading profits, even while registered for and paying JCT — the two systems are separate. Since the 2018 reform (fiscal years from 1 January 2019), a facility used for storage, display or delivery of your goods is excluded from PE only if the activity is preparatory or auxiliary for your business, an anti-fragmentation rule stops splitting functions to stay under that bar, and agent PE covers persons who habitually conclude contracts or play the principal role in concluding them — while independent agents acting in the ordinary course of their own business are excluded (NTA Tax Answer 2883).

The generally accepted reading — an application of those rules rather than an official ruling, so treat it as a starting point, not a guarantee — is that stock held at an independent 3PL serving many clients does not give you a fixed place of business at your disposal, and neither the 3PL nor the ACP (a customs-procedure agent, not a contract concluder) is a PE-creating agent. The risk factors are the exceptions: a warehouse operated by or dedicated to you, a Japanese party filling orders for you beyond ordinary 3PL services, or staff in Japan negotiating sales. And tax treaties override the domestic definition — some older treaties keep the storage exclusion without the preparatory-or-auxiliary condition, others differ the other way (NTA Tax Answer 2883 confirms the treaty definition prevails). Anything beyond plain third-party storage deserves treaty-specific advice.

The FBA hand-off in practice

Amazon Japan will not act as importer of record or consignee for inbound FBA shipments — a policy stated in Seller Central (login required) and consistently applied in practice. Never name an Amazon fulfillment center as importer or consignee on shipping documents; such shipments sit at customs with no valid declarant. The working pattern for Route B sellers is:

1. Clear customs as non-resident IOR via your ACP, with a 3PL warehouse named as the delivery destination.
2. The 3PL receives the goods and handles FBA prep — any Japanese-language labeling your product category requires, FNSKU labels, poly-bagging and carton compliance.
3. The 3PL ships domestically into FBA (or fulfills orders itself, with FBA as one channel).

Two current rules make the paperwork stricter than it used to be. Since 12 October 2025, import declarations must state the post-clearance delivery destination, whether the goods are mail-order (通販) goods, and if so the platform name (Japan Customs). And because your FBA stock has no import transaction, its customs value is normally built backwards from your Japanese selling price (Customs FAQ 1404) — undervaluation of fulfillment cargo is exactly what triggered the 2023 reform, so expect scrutiny and keep your fee reports. Do not plan around the ¥10,000 de minimis exemption either: it is assessed on the aggregated customs value of the whole declaration — and goods split across shipments are totalled — so bulk fulfillment cargo does not qualify (Customs FAQ 1006).

When regulated goods force Route A or C

The ACP fixes the customs-residency problem only. Product laws have their own domestic-representative regimes, and an ACP does not substitute for any of them:

• Pharmaceuticals, quasi-drugs, cosmetics, medical devices — marketing requires a Japan-based Marketing Authorization Holder (製造販売業者) or designated MAH under the Pharmaceuticals and Medical Devices Act; the import declarant or its agent must hold the licence (Customs FAQ 1805).
• PS-mark products (electrical goods, gas appliances, etc.) — since 25 December 2025, overseas businesses selling these directly to Japanese consumers must notify as a specified importer (特定輸入事業者) and appoint a domestic administrator (国内管理人) under the amended Product Safety laws (METI) — a second domestic-representative regime on top of the customs ACP.
• Radio and wireless devices — equipment without the technical conformity (技適) mark generally cannot be used legally in Japan (using it typically amounts to unlicensed radio operation, with narrow exceptions); certify before importing sale inventory.
• Food and food-contact goods — import notification to quarantine under the Food Sanitation Act; in practice a domestic food importer files.

If your catalog sits in these categories, the decision usually makes itself: a licensed Japanese partner (Route A) or your own licence-holding subsidiary (Route C). Some sellers split the catalog — unregulated SKUs through Route B, regulated SKUs through a partner.

Frequently asked questions

Do I need a Japanese company to sell on Amazon Japan?

No. Foreign sellers can open an Amazon Japan seller account from abroad. The hurdle is import clearance: per Amazon Seller Central policy (login required), Amazon will not act as importer of record or consignee for inbound FBA shipments. So you either import in your own name as a non-resident importer via an ACP, or have a Japanese partner import the stock and forward it to FBA.

Can my forwarder or 3PL be the importer of record instead of me?

Generally no. Since 1 October 2023 Japan Customs requires the import declarant to be a party with a real interest in the goods, such as the buyer or the person holding the right to dispose of the cargo after release. A forwarder or 3PL that only handles paperwork and storage cannot be a nominal importer. A Japanese company can be the importer if it genuinely buys the goods, or sells them on consignment in its own name.

Can I recover the 10 percent import consumption tax without a Japanese entity?

Yes, but only if your company is the importer named on the import permit. You then register as a consumption-tax payer, appoint a Japan-resident tax agent, and credit the import JCT against the JCT charged on your domestic sales in your returns. If a distributor or forwarder is the importer instead, the credit belongs to them, not you.

Does keeping inventory in a Japanese 3PL warehouse create a taxable presence?

Usually not, but it is not automatic. Storage and delivery facilities are excluded from the permanent-establishment definition only where the activity is preparatory or auxiliary for your business, and an applicable tax treaty can change the analysis. A warehouse at your own disposal, or staff in Japan soliciting sales, are the classic risk factors. Take professional advice for anything beyond ordinary third-party 3PL storage.

How long does it take to set up the non-resident importer route?

The ACP notification (Customs Form C-7500) must be filed before your first import declaration, and service providers report that registration takes roughly two weeks. Add time for gathering the power of attorney and company registry documents, agreeing a customs valuation method for your own stock, and appointing a tax agent for consumption-tax filings.

What is the difference between an ACP and a tax agent (nozei kanrinin)?

They are separate appointments with separate authorities. The ACP handles customs procedures and is notified to Japan Customs under Customs Act Article 95. The tax agent handles national-tax matters such as consumption-tax returns and is notified to the tax office under Article 117 of the General Act of National Taxes. A non-resident seller importing and selling in Japan typically needs both.

Related reading

• Importer of Record (IOR) in Japan
• The ACP appointment procedure, step by step
• Import duties & consumption tax
• Find a warehouse or 3PL in the directory