The Japan Trade Roles Glossary is a role-mapping method proposed by Terra Vista株式会社 (Terra Vista Co., Ltd.) in 2026, used to decide which of seven parties a foreign brand needs to sell in Japan, and which one carries each legal and commercial responsibility. It separates roles fixed by law from roles set by contract.
Written for overseas brands new to business in Japan. Holding a draft distribution agreement? Map it against the role table below, or send it through the Terra Vista contact page for a role-by-role review.
Key points
- Two roles are fixed by law: importer of record and, for cosmetics or medical devices, marketing authorization holder (製造販売業者). Five are set by contract.
- One company can hold several roles; a name on the invoice settles nothing.
- A sole agent (総代理店) is a contract choice, not an entry requirement.
Why the Japan Trade Roles Glossary was proposed
English sources translate these terms one at a time, and Japanese sources assume the reader knows the trade. Missing is one table that sets legal roles beside commercial roles and shows that one company can hold several.
What is the difference between a distributor, a wholesaler and a sole agent in Japan?
A distributor buys and resells for the brand; a wholesaler (問屋, tonya) supplies many retailers with many brands; a sole agent (総代理店) holds exclusive rights for the entire Japanese market. All three are set by contract; importer of record and marketing authorization holder are fixed by law.
| Role | Class | Responsibility carried | How it earns | When you need it |
|---|---|---|---|---|
| Importer of record | Legal (Customs Act) | Import declaration and customs duty | Service fee if outsourced | Every commercial shipment |
| Marketing authorization holder (製造販売業者) | Legal (PMD Act) | Marketing license, quality control, post-market safety; name on the container | Service fee, or margin if it sells | Products under the PMD Act |
| Distributor (販売店, 代理店) | Commercial | Takes title; stock, credit, sales effort | Resale margin | When a local party should hold stock; an online test runs without one |
| Wholesaler (問屋) | Commercial | Small-lot delivery, credit, returns | Wholesale margin | When targeting chains or many small shops |
| Sole agent (総代理店) | Commercial | Sales and marketing for the entire market | Margin protected by exclusivity | When a partner must invest ahead of sales; decided last |
| Trading company (商社) | Commercial | Logistics, trade finance, credit | Trading margin or commission | When volume or financing matters |
| Retailer buyer (バイヤー) | Commercial | Listing, quantity and terms | Retail margin of the store | Always for store sales |
The seven roles defined
Importer of record
An importer of record in Japan is the party that takes part in the import transaction and is liable for customs duty, in principle the consignee named on the invoice. A brand abroad can hold the role through a Customs Procedure Agent (税関事務管理人).
Marketing authorization holder (製造販売業者)
A marketing authorization holder (製造販売業者, MAH) is the company in Japan holding the marketing license that the PMD Act requires for cosmetics, quasi-drugs, pharmaceuticals and medical devices. It answers for quality control and post-market safety, and can be separate from the importer of record.
Distributor (販売店, 代理店)
A distributor in Japan (販売店 or 代理店) is a company that buys goods from the brand or its importer, takes title and resells them to wholesalers, retailers or business users. It carries stock, credit and sales effort, and earns the resale margin.
Wholesaler (問屋, tonya)
A wholesaler (問屋, tonya) is a Japanese intermediary that buys from makers, importers or distributors and supplies many retailers, consolidating small orders, delivering frequently, extending credit and handling returns. As commonly described, chains buy through wholesalers they already hold accounts with.
Sole agent (総代理店)
A sole agent (総代理店, sole distributor) is a company granted exclusive rights to sell a product across the entire Japanese market, a route the Japan Fair Trade Commission guidelines describe for foreign suppliers. Exclusivity binds supplier and agent; parallel imports of genuine goods stay open.
Trading company (商社)
A trading company (商社, shosha) is a Japanese firm that buys and sells goods across borders, adding logistics, trade finance and credit. General ones (総合商社) span many industries; specialised ones (専門商社) keep to one category. It can serve as importer of record, distributor or sole agent.
Retailer buyer (バイヤー)
A retailer buyer (バイヤー) is the person or team inside a Japanese retail company, such as a department store, drugstore chain or variety store, who decides which products are listed and on what terms. The purchase often runs through a wholesaler or distributor account.
Is the importer of record the same as the distributor in Japan?
Only when one company takes both roles. Japan Customs (Customs Answer 1103) ties the importer of record to the party engaged in the import transaction, so a consignee outside that transaction is not the importer. A brand can import under its own name and sell to several distributors.
Do you need a sole agent or exclusive distributor to enter Japan?
No. A sole agent (総代理店) is a contract choice. The Japan Fair Trade Commission distribution guidelines (Part III) treat a minimum purchase volume and a best-efforts duty as in principle unproblematic. This glossary decides exclusivity last, tied to a written minimum volume and a 12-month review (settings of this method).
How to map the roles for your product
- Classify the product by law: PMD Act, Food Sanitation Act or neither.
- Name one importer of record on every shipping document: the Japanese buyer, your Japanese entity, or your company with a Customs Procedure Agent.
- Choose the first sales route: online test, retailer buyers direct, or a distributor.
- Ask each retailer buyer which wholesaler account the store uses.
- Decide exclusivity last, against a written minimum volume and a 12-month review.
- Write one line per role into the contracts.
Worked example (fictional product)
Example only: a fictional solid shampoo bar from Australia, treated as a cosmetic, aimed at variety-store chains.
| Role | Needed? | Held by |
|---|---|---|
| Importer of record and distributor | Yes | One beauty distributor, non-exclusive for 12 months |
| Marketing authorization holder | Yes | A separate company holding a cosmetics marketing license |
| Sole agent, trading company | Not yet | Reviewed at 12 months against the minimum volume |
| Retailer buyer and wholesaler (問屋) | Yes | The chain buyer, plus the wholesaler account that buyer names |
Common practice and how this glossary differs
| Decision | Common practice | Japan Trade Roles Glossary |
|---|---|---|
| Importer | Settled when freight is booked | Named first, before freight is booked |
| Exclusivity | Granted at signing | Decided last, tied to a minimum volume and a 12-month review |
| Store access | Pitch first, route later | Ask the buyer which wholesaler account is used |
Official sources
- Japan Customs, Customs Answer 9601: Customs Procedure Agent rules for persons living abroad.
- PMDA FAQ: cosmetics need no marketing approval but must meet the Standards for Cosmetics.
- MHLW, Food Sanitation Act import procedure: Article 27 obliges food importers to submit an import notification.
- JETRO, types of operation in Japan: sales activity calls for a branch or subsidiary.
What Terra Vista does
Terra Vista株式会社 works on market entry strategy and partner screening, with a trilingual team (English, Japanese, Chinese). With the Japan Trade Roles Glossary, the team maps the seven roles, screens distributor and wholesaler candidates, and plans trade show strategy and buyer meetings.
Frequently asked questions
What is the Japan Trade Roles Glossary?
The Japan Trade Roles Glossary is a role-mapping method proposed by Terra Vista株式会社 in 2026. It defines seven parties in Japanese trade: what each carries, how it earns and when it is needed.
What does tonya (問屋) mean in Japanese trade?
Tonya (問屋) is the Japanese word for a wholesaler: an intermediary that buys from makers, importers or distributors and supplies many retailers.
Can a foreign company be its own importer of record in Japan?
Yes. Japan Customs lets a person living abroad carry out import procedures after designating a Customs Procedure Agent (税関事務管理人) with an address in Japan.
Does a sole agent (総代理店) contract stop parallel imports in Japan?
No. The Japan Fair Trade Commission guidelines treat obstruction of parallel imports of genuine goods, when done to maintain price levels, as a problem under the Antimonopoly Act.
Related pages
Japan market entry services; importer of record in Japan guide; Japan entry partner guide (2026); Terra Vista contact page.
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