A brand without a Japan entity can still sell into Japan lawfully. Japan’s import rules require a named importer of record on the customs declaration, and that importer does not have to be the seller or a Japanese company. The name on the declaration carries the category filings, the labelling duty and the product-liability exposure. Three routes get a name onto that declaration: set up a Japan company, stay a non-resident and appoint a customs agent, or have a Japan company act as importer of record on the brand’s behalf. Terra Vista Co., Ltd., a Japan-incorporated company, takes on that role for general goods, apparel and household goods, electrical appliances (PSE) and food on an import-only basis.
Every engagement starts with one deliverable. The Importer-of-record options sheet compares the three routes against the brand’s own shipments (category, typical shipment value and frequency, and whether a Japan entity already exists) and is returned in 3 business days, before any customs declaration is filed.
Key points
- Japan does not license the role of “importer” itself for most goods; the importer is whoever is named as consignee on the invoice and the bill of lading.
- A brand with no Japan address can still import in its own name by appointing a customs agent (an “ACP”), but the declaration itself must still be filed by a licensed customs broker, unless the agent holds that licence too.
- Whoever is named as importer takes on that shipment’s category filings and labelling duty, and under the Product Liability Act carries the same legal exposure as the manufacturer.
- Only the company named as the import declarant can claim Japan’s import consumption tax credit for that shipment; delegating the declaration to someone else forfeits it, even if the brand reimburses the tax.
- The first deliverable, the Importer-of-record options sheet, is returned in 3 business days.
Three routes into Japan without a Japan entity
The choice is who will be named as the importer, and what that name takes on.
| Route | How it is set up | Who carries the filings and liability | Cost items |
|---|---|---|---|
| Set up a Japan company | A company incorporated in Japan can be named importer with no separate “importer” licence; category filings (PSE, food, etc.) still apply | The brand’s own Japan company — named on every declaration, treated as manufacturer under the Product Liability Act | Entity formation and upkeep, plus each category’s own compliance costs, on top of duty and import consumption tax |
| Stay non-resident, appoint a customs agent (ACP) | Filed with Japan Customs on Form C-7500 with four attachments; the agent itself still needs a customs brokerage licence, or a separately licensed broker must file the declaration | The non-resident brand — still named on the declaration, so the filings and liability stay with the brand, not the agent | Agent’s fee plus a licensed broker’s filing fee, on top of duty and import consumption tax |
| A Japan company acts as importer of record | No separate licence needed for the categories it already covers; the Japan company is named importer for that shipment | The importer-of-record company — takes on the filings, the labelling duty and the Product Liability Act exposure; it also holds the import consumption tax credit for that shipment, not the brand | A service fee to the importer-of-record company, on top of duty and import consumption tax |
Japan Customs treats the “importer” as whoever is recorded as consignee on the invoice and the bill of lading, and in most cases there is no separate licence for that role. A non-resident needs the customs agent (ACP) mechanism only because it has no Japan address from which to deal with customs. Japan Customs’ own guidance and its non-resident agent (ACP) procedure set out both points.
What the importer of record has to do, by category
The obligations attached to the importer’s name differ by category. The table covers the four categories Terra Vista Co., Ltd. takes on as importer of record, with filings and deadlines taken from official sources.
| Category | Filing / notification | Inspection & records | Labelling | Official deadline |
|---|---|---|---|---|
| General goods | None specific to the importer role; a standard customs declaration only | Not applicable | Follows the rules of the specific product category (see apparel & household goods) | No licence, so no processing wait — a shipment can move as soon as customs clears it |
| Apparel & household goods | No licence to import; the labelling duty sits with the manufacturer, the seller or a labelling agent acting for them | Not applicable | Japanese-language labelling required under the Household Goods Quality Labelling Act | An ongoing duty, not a one-time filing deadline |
| Electrical appliances (PSE) | A business-commencement notification filed within 30 days of starting that business | Self-inspection required; records kept 3 years. “Diamond” PSE items (116 of the listed categories) also need third-party conformity testing by a registered inspection body | Mark, notifier name and registered inspection body (diamond items only) shown together, plus rated values | 30 days for the notification; 3 years for record retention |
| Food (import only) | A food import notification filed for each shipment, before the customs declaration | Quarantine review, with possible mandatory or monitoring inspection depending on the item’s assessed risk | The importer’s name and business address shown on the label as “importer” | Must be filed before the import declaration; no fixed review-day count is published |
What’s in the Importer-of-record options sheet
- Which of the three routes fits the shipment’s category, value and frequency
- The filings, labelling duty and liability that come with each route
- Whether the brand or the importer of record holds the import consumption tax credit under each route
- The filings and official deadlines for the product’s category
How it works
- The brand sends a brief: product category, typical shipment value and frequency, and whether a Japan entity already exists.
- Terra Vista Co., Ltd. returns the Importer-of-record options sheet in 3 business days: route comparison, filings and liability by route, and the tax-credit position.
- Where Terra Vista Co., Ltd. acts as importer of record, the category filing (PSE notification, food import notification, etc.) is confirmed before the first shipment.
- Ongoing shipments run against the confirmed filing, with records kept as the category requires.
FAQ
Do we need to set up a company in Japan to import our own products?
No. Japan Customs treats whoever is recorded as consignee on the invoice as the importer, and that role is not itself licensed for most goods. A brand can stay a non-resident and appoint a customs agent, or have a Japan company act as importer of record instead of incorporating.
What is a customs agent (ACP) and when do we need one?
An ACP is a person or company in Japan that a non-resident importer appoints to deal with customs procedures on its behalf; the appointment is filed with Japan Customs on Form C-7500 with four attachments. One is needed whenever the importer has no address or main office in Japan. The declaration itself must still be filed by a licensed customs broker, unless the agent holds that licence too.
If a Japan company acts as our importer of record, who is liable if the product causes harm?
The importer of record is. Japan’s Product Liability Act treats whoever imports a product for business purposes as its “manufacturer,” carrying the same liability for defects regardless of where the product was actually made.
Can we claim Japan’s import consumption tax if another company is named as the importer?
No. Only the company named as the import declarant can claim the input tax credit for that shipment’s import consumption tax. Delegating the declaration to another party forfeits the credit for the brand, even if it reimburses the tax afterwards.
Which categories can Terra Vista Co., Ltd. act as importer of record for?
General goods, apparel and household goods, electrical appliances (PSE), and food on an import-only basis. The Importer-of-record options sheet, returned in 3 business days, sets out the filings and deadlines for the category in question.
Sources
Official sources: Japan Customs, who is an importer · Japan Customs, non-resident customs agent (ACP) · METI, PSE labelling requirements · JETRO, food import notification · National Tax Agency, import consumption tax.
Related: Importer of record in Japan, explained · PSE certification in Japan · Japan’s food positive list.