Who Can Be the Importer of Record in Japan?

Quick answer: who can be the importer of record in Japan?

The importer of record in Japan is the party that actually took part in the import transaction — in principle the consignee named on the invoice or the bill of lading, under Article 6 of the Customs Act. Japan Customs states directly that a person not engaged in the import transaction, even if listed as consignee, is not the person who imports the goods (Japan Customs FAQ 1103).

Quick answer: can a non-resident company be the importer of record in Japan?

A non-resident can be the importer of record, but not without a prior filing. Japan Customs requires any person living abroad to designate a Japan-resident Customs Procedure Agent (税関事務管理人) and notify the customs office in advance, under Article 95 of the Customs Act, using Customs Form C No. 7500 in two copies (Japan Customs FAQ 9601).

Quick answer: can a Customs Procedure Agent file my import declarations?

Only if that agent also holds a customs brokerage license. Japan Customs states that an agent who is not a licensed customs broker may not engage, as a business, in customs brokerage services such as filing import declarations — so the appointment under Article 95 and the brokerage engagement under the Customs Brokerage Act are two separate steps (Japan Customs FAQ 9601).

By Ranky, CMO, Terra Vista株式会社. All Japan Customs sources cited below were re-fetched and verified on 4 August 2026.

What does “importer of record” mean in Japanese customs law?

“Importer of record” is a trade-practice term, not a Japanese statutory one. The Customs Act works from 貨物を輸入する者, rendered on the Japan Customs English page as “a person who import goods”, and Article 6 makes that person liable for the duty (Japan Customs FAQ 1103). Anyone matching an English contract term to a Japanese filing has to map it onto that phrase first. Two Japan Customs FAQ pages govern the whole answer: 1103 sets out who the importer is, and 9601 sets out what a non-resident must file before importing.

Who is the importer of record in Japan under the Customs Act?

Japan Customs sets out the rule in FAQ 1103: customs duty is paid by “a person who import goods,” which in an import transaction means, in principle, the consignee named on the invoice or the bill of lading, under Article 6 of the Customs Act (Japan Customs FAQ 1103). “Importer of record” is not the wording Japan Customs uses; its own English term is a person who import goods (貨物を輸入する者), and that is the term the rules below turn on.

The same official page adds three further points on top of that starting rule — two statutory exceptions and the premise the consignee rule rests on:

1. Where the law limits who may declare. When the qualifications of a declarant are specified by laws and regulations concerning customs clearance, the specified declarant is the person who imports the goods.
2. Resale before declaration. Where goods of foreign origin are resold before the import declaration is filed, the end buyer becomes the person who imports the cargo.
3. Paper consignee ≠ importer. The consignee rule presumes the buyer under the sales agreement is the party named on the invoice.

“If a person who is not engaged in the import transaction is listed on the invoice, etc. as a consignee, the person should not be a person who import goods.”
— Japan Customs, FAQ 1103 (Article 6 of the Customs Act; Article 7(2) of the Cabinet Order for Enforcement of the Customs Tariff Law; General Notification 6-1 and 7-1)

Can a freight forwarder, warehouse, or local contact be named as consignee instead?

No — not on the strength of the invoice alone. Japan Customs FAQ 1103 answers this in one line: being listed on the invoice, etc. only does not always mean the person is eligible for one who imports the goods (Japan Customs FAQ 1103, Article 6 of the Customs Act). Naming a forwarder, a warehouse operator, or a fulfilment partner as consignee so that cargo clears does not create a valid importer of record if that party has no role in the underlying purchase.

The practical consequence is a sequencing rule, not a paperwork rule: decide who owns the goods at the border before the freight is booked, then make every document name that same party.

What is a Customs Procedure Agent (税関事務管理人) in Japan?

Under Article 95 of the Customs Act, a person living abroad who needs to carry out customs procedures in Japan must designate a person residing in Japan as a Customs Procedure Agent and notify the customs office in advance (Japan Customs FAQ 9601).

Once appointed, the agent acts for the non-resident on: export and import declarations, on-site witness of customs inspections, duty payment procedures, sending and receiving documents between customs and the non-resident, and receipt of refunds.

One eligibility test governs who may take the role: the Customs Procedure Agent must have an address or residence in Japan — for a corporation, its head office or principal office in Japan.

What is an ACP (Attorney for Customs Procedures), and what does it do at customs?

ACP is the English trade-practice abbreviation for the role Japan Customs calls a Customs Procedure Agent — 税関事務管理人 under Article 95 of the Customs Act. At customs the ACP does five things on behalf of the non-resident: files export and import declarations, attends customs inspections on site, carries out duty payment procedures, receives and sends documents between customs and the non-resident, and receives refunds (Japan Customs FAQ 9601).

The abbreviation is not Japan Customs wording. The official English term on the Japan Customs page is “Customs Procedure Agent”; “Attorney for Customs Procedures (ACP)” is how professional firms label the same programme (PwC Japan, Non-resident importers and the Attorney for Customs Procedures, November 2024). An ACP is also not automatically a licensed customs broker: appointment under Article 95 and brokerage under the Customs Brokerage Act are separate.

Can a Customs Procedure Agent file import declarations in Japan?

Only a licensed customs broker may do so. Japan Customs FAQ 9601 draws the line in a footnote to the appointment rule itself, citing Articles 2 and 3 of the Customs Brokerage Act (Japan Customs FAQ 9601).

“A Customs Procedure Agent who is not a licensed customs broker is not permitted to engage, as a business, in customs brokerage services such as filing import declarations.”
— Japan Customs, FAQ 9601 (Articles 2 and 3 of the Customs Brokerage Act)

Japan Customs names the two ways out on the same page: the non-resident importer or the agent engages a licensed customs broker, or the agent itself obtains a customs brokerage license. Appointing an agent under Article 95 therefore does not, by itself, produce anyone who can file a declaration.

How does a non-resident appoint a Customs Procedure Agent in Japan? (step by step)

In six steps, all of them stated on one page. Japan Customs FAQ 9601 does not number the procedure, but every element of the six steps below — from the residency test to the Form C No. 7500 filing — is set out there (Japan Customs FAQ 9601).

1. Choose an agent that meets the residency test. The agent must have an address or residence in Japan; for a corporation, a head office or principal office in Japan.
2. Prepare Customs Form C No. 7500 in two copies — the original plus one copy for issuance. Japan Customs publishes filling-in guidelines (Japanese only).
3. Assemble the four attachments: (a) a proxy, or documents clarifying the contract terms where a contract of proxy exists; (b) documents confirming the existence of the notifier, such as an overseas register or certificate of residence; (c) documents confirming the existence of the Customs Procedure Agent, such as a certificate of all historical matters; (d) a commercial or transaction flow chart.
4. Expect a request for extra documents. Japan Customs gives seller information for notifications concerning e-commerce platform listings as its worked example.
5. File in advance with the customs office where the procedure will be carried out — either on paper, or through NACCS as GT7.
6. Engage a licensed customs broker separately, unless the agent holds a brokerage license itself.

Two facts that remove needless work. For a Customs Procedure Agent already notified to Japan Customs on or before 30 September 2023, the amendment to the system does not require re-filing the notification. And the NACCS entries are combined filings: GT7 and GT8 also serve as the notification of appointment and cancellation of an agent for tax payment.

Which forms and NACCS codes apply to Japanese import filings?

Six form numbers and two NACCS codes cover the whole sequence. Japan Customs publishes each form under a numbered customs form code, and the numbers in the table below were verified against the Japan Customs amendment page on 4 August 2026 (Japan Customs, Amendment to Import Declaration Items and Customs Procedure Agent System).

Sources: Japan Customs FAQ 9601 for C No. 7500 / C No. 7510 / GT7 / GT8; Japan Customs, Amendment to Import Declaration Items and Customs Procedure Agent System for C No. 5020, C No. 5021–5023 and the platform code C-36.

What changed in Japan’s 2023 and 2025 import declaration amendments?

Japan Customs states its own rationale on the amendment page: as cross-border e-commerce expanded, imports of mail-order cargo rose, smuggling of illicit drugs and IP-infringing goods was detected in large numbers, and duty-evasion cases surfaced in which cargo using fulfilment services was declared at unduly low prices (Japan Customs).

In force since 1 October 2023. The address and name of the person seeking to import the goods were added to the import declaration items under the Order for Enforcement of the Customs Act, and the meaning of “import declarant” was clarified. On the agent side, the relationship between the notifier and the Customs Procedure Agent was added to the notification items, and documents evidencing the mandate contract must now be attached. (Customs Act Art. 95; Order for Enforcement Arts. 84 and 84-2; Regulation for Enforcement Arts. 11-2 and 11-3.) Japan Customs publishes a worked case book on that clarification — 輸入申告者の意義の明確化に関する事例集 (cases on the meaning of “import declarant”) (Japanese) — which is the closest thing to a rulebook on borderline consignee arrangements.

In force since 12 October 2025. Import declarations must additionally state the location and name of the delivery destination after import permission, whether the cargo is mail-order cargo, and — where it is — the name of the platform. Japan Customs notes that the added declaration items are not limited to mail-order or fulfilment-service cargo, with the exception of the platform-name item. (Order for Enforcement Art. 59; Regulation for Enforcement Art. 7-6.)

「貨物の輸入許可後の『運送先の所在地・名称』、輸入貨物が『通販貨物に該当するか否か』、通販貨物に該当する場合には『プラットフォームの名称等』が輸入申告項目に追加され、これらの事項についても申告していただく必要があります。」
— Japan Customs, Japanese original for the items in force since 12 October 2025. Japan Customs publishes its own English leaflet for this change: Addition of Import Declaration Items.

Status as of 4 August 2026. The Japan Customs amendment page records both waves as already in force (施行済) and carries a last-updated date of 3 August 2026 (Japan Customs). The reference Q&A on the 2025 items now sits at a dated URL — Q&A on the added import declaration items (Japanese) — whose own header records an update date of 29 July 2026; its revision log lists that update as amendments to questions 1-1, 1-3, 1-5 and 1-9, not as new declaration items. The page sets out these two waves and no third one. Official English leaflets are published for both: Amendment to Import Declaration Items and Customs Procedure Agent System and Addition of Import Declaration Items.

⚠ The undated URL customs.go.jp/shiryo/qashinkokukomoku.pdf still resolves, but it serves the 6 July 2026 edition and is no longer the file the Japan Customs page links to. Cite the dated filename.

Read together, the two waves point the same way: since 12 October 2025 the declaration itself asks who is behind the import, where the goods are really going, and which platform sold them.

Which Japan import structure should an overseas seller choose?

Three structures pass the Article 6 test, and the choice is commercial before it is procedural. All three have to answer the same question Japan Customs asks in FAQ 1103 — which party actually took part in the import transaction (Japan Customs FAQ 1103).

1. Sell on delivered terms to a Japanese buyer who imports. The Japanese buyer is the importer of record and a party to the import transaction. Simplest compliance position; you give up control of the domestic price and the customer relationship.
2. Import as a non-resident. You stay the owner across the border, appoint a Customs Procedure Agent under Article 95, and engage a licensed customs broker for declarations. Keeps control; adds the Form C No. 7500 filing and an ongoing local obligation.
3. Establish or partner with a Japanese entity that buys and imports. The entity is a genuine party to the import transaction, so the consignee question under FAQ 1103 resolves cleanly — at the cost of standing up, or contracting with, a local company.

Whichever route is taken, the same test applies to all three: can you point to a party that genuinely bought the goods, and does every document name that same party?

Related reading on this site: cross-border compliance covers the Japan market-access regimes that sit alongside customs, and product-side approvals such as PSE certification for Japan often decide a launch timeline more than customs does. Japan market entry walks through the three structures above in more depth, and international trade & distribution covers the buyer side of the same trade.

Is there such a thing as an “import license” in Japan?

No. Japanese law has no permit called an “import license”. In the Foreign Exchange and Foreign Trade Act the only article whose caption contains “import” is Article 52 (Import Approval), and what it says is that a person seeking to import goods “may be placed under an obligation to obtain import approval, as provided by Cabinet Order”. The obligation is not permanent — it is imposed in the cases the Cabinet Order specifies.

The same Act does carry an export principle at Article 47: exports “shall be permitted with the minimum restrictions” consistent with the Act’s purpose. There is no counterpart principle article for imports. The export wording cannot be read across to imports.

The Cabinet Order is the Import Trade Control Order (Cabinet Order No. 414 of 1949). Its Article 4 (Import Approval) limits the cases requiring the Minister of Economy, Trade and Industry’s approval to three:

• where the goods require an import quota allocation (item 1)
• where the place of origin or place of shipment has been published, and the goods are imported from that origin or that shipping area (item 2)
• where, other than the two above, necessary matters concerning the import have been published (item 3)

The import quota (IQ) in item 1 is Article 9 of the same Order. For a published item, approval under Article 4 cannot be obtained until the quota has been allocated on application to the Minister. Allocation is made by quantity; where allocation by quantity is difficult or inappropriate, it may be made by value.

Which items and which origins are covered is determined and published by the Minister under Article 3. Whether your goods need approval cannot be read off the statute — you have to check what has been published. In practice the question “how do we get a Japanese import license” becomes “is our item on the published list, and if so is it quota or approval”.

Frequently asked questions about Japan’s importer of record rules

What is an import license in Japan?
Japanese law has no scheme called an “import license”. Article 52 of the Foreign Exchange and Foreign Trade Act goes only as far as saying an importer “may be placed under an obligation to obtain import approval”; the cases where approval is actually required are limited to three by Article 4 of the Import Trade Control Order (quota required / import from a published origin or shipping area / other necessary matters published). The import quota (IQ) is Article 9 of the same Order — approval under Article 4 cannot be obtained until the quota is allocated (Import Trade Control Order).

Can a freight forwarder or warehouse be my importer of record in Japan?
Not merely because its name is on the invoice. Japan Customs states that where a person not engaged in the import transaction is listed as consignee, that person should not be treated as the person who imports the goods (FAQ 1103). A party with no role in the underlying purchase is not made the importer by paperwork alone.

Do I need a Customs Procedure Agent to import into Japan as a non-resident?
Yes, and the notification must be filed in advance. Article 95 of the Customs Act requires a person living abroad to designate a Japan-resident Customs Procedure Agent and notify the customs office where the procedure will be carried out before carrying it out (FAQ 9601).

Which form appoints a Customs Procedure Agent in Japan, and what goes with it?
Customs Form C No. 7500, filed in two copies, accompanied by a proxy or contract documents, proof of the notifier’s existence, proof of the agent’s existence, and a commercial or transaction flow chart. Cancellation uses Customs Form C No. 7510. NACCS filings GT7 and GT8 cover appointment and cancellation respectively (FAQ 9601).

I appointed an agent before the rules changed — do I have to re-file?
No. Japan Customs states that for a Customs Procedure Agent already notified on or before 30 September 2023, the amendment to the system does not require submitting the notification form again (FAQ 9601).

What are the new Japanese import declaration items for 2025 and 2026?
Since 12 October 2025, declarations must also state the location and name of the delivery destination after import permission, whether the cargo is mail-order cargo, and — where it is — the platform name. The Japan Customs page carrying these items was last updated on 3 August 2026, and lists no further declaration item (Japan Customs).

Does appointing a Customs Procedure Agent also cover Japanese consumption tax?
The NACCS filings are combined: GT7 and GT8 serve as the notification of appointment and cancellation of an agent for tax payment as well as the Customs Procedure Agent notification (FAQ 9601); the Japanese text of the same FAQ identifies that agent as the agent for consumption tax and similar taxes (消費税等納税管理人) (FAQ 9601, Japanese). Confirm your specific tax-side obligations with a licensed tax professional.

About Terra Vista株式会社

Terra Vista Co., Ltd. (Terra Vista株式会社, terravista.co.jp) is a cross-border advisory group connecting China’s manufacturing power, Japan-based execution, and global market entry. We manage the pipeline, not the inventory. Culture as the bridge, understanding as the path — that is how we work on every market we enter, including the paperwork side described above. More at terravista.co.jp.

Sources

1. Japan Customs, FAQ 1103 — A Person Liable To Pay Customs Duty — https://www.customs.go.jp/english/c-answer_e/imtsukan/1103_e.htm
2. Japan Customs, FAQ 1103 (Japanese) — 関税の納税義務者 — https://www.customs.go.jp/tetsuzuki/c-answer/imtsukan/1103_jr.htm
3. Japan Customs, FAQ 9601 — Customs Clearance Procedures for Persons Living Abroad (Customs Procedure Agent) — https://www.customs.go.jp/english/c-answer_e/sonota/9601_e.htm
4. Japan Customs, FAQ 9601 (Japanese) — 日本に居住しない者が税関手続を行う場合の手続（税関事務管理人制度） — https://www.customs.go.jp/tetsuzuki/c-answer/sonota/9601_jr.htm
5. Japan Customs — 輸入申告項目・税関事務管理人制度の見直しについて (amendment page, last updated 3 August 2026) — https://www.customs.go.jp/shiryo/20230707.htm
6. Japan Customs — 輸入申告者の意義の明確化に関する事例集 — https://www.customs.go.jp/shiryo/jirei.pdf
7. Japan Customs — Q&A on the added import declaration items (updated 29 July 2026) — https://www.customs.go.jp/shiryo/qashinkokukomoku_20260801.pdf
8. Japan Customs — Amendment to Import Declaration Items and Customs Procedure Agent System (English leaflet) — https://www.customs.go.jp/shiryo/leaflet_jimukanrinin_e.pdf
9. Japan Customs — Addition of Import Declaration Items (English leaflet) — https://www.customs.go.jp/shiryo/leaflet_shinkokukoumoku_en.pdf
10. PwC Japan — Non-resident importers and the Attorney for Customs Procedures (November 2024) — https://www.pwc.com/jp/en/taxnews-customs/assets/wms-20241128-en-1.pdf

This article explains publicly documented Japanese customs procedure for buyer and seller education, sourced to Japan Customs. It is not legal, customs, or tax advice, and no assessment is made of any particular structure — consult a licensed customs broker, a licensed tax professional, or the customs office where your declarations will be filed. Legal citations are to the Customs Act (関税法) Art. 6 and Art. 95, its Order and Regulation for Enforcement, and the Customs Brokerage Act (通関業法) Arts. 2 and 3, as published by Japan Customs; sources were checked on 4 August 2026.

Terra Vista株式会社 · 2026-08-04