Importer of Record (IOR) and Exporter of Record (EOR) let a non-resident company move goods into and out of Japan under the Customs Act (関税法) without incorporating a Japan entity. IOR covers the import side, EOR covers the export side, and despite the similar-sounding acronyms they solve different problems and are structured differently. Either can put a first shipment through customs within three to four weeks of engagement.
A foreign company entering the Japanese market usually assumes the first step is incorporating a Japan entity. That assumption is expensive and slow: setting up a KK or GK runs from roughly JPY 1 million to 5 million and takes two to six months, and since the October 2025 reform, the Business Manager visa route now requires JPY 30 million in capital before an entity-based structure even qualifies for that visa category. For a company still testing whether the market works, none of that is necessary yet. IOR, EOR, and the similarly-worded but unrelated "Employer of Record" have to be kept apart, since the confusion between them sends companies to the wrong service.
Importer of Record (IOR): Why the October 2023 Reform Changed the Structure#
Japan Customs (税関) rewrote the operative definition of "importer" in October 2023. Before the reform, a Japan-registered company could appear as the nominal importer on a customs declaration with little scrutiny of whether it had any real commercial relationship to the goods. After the reform, the named importer on an import declaration (輸入申告) must be the party holding actual disposition rights (処分権限), meaning the authority to decide whether the goods are sold, at what price, and how they are distributed once cleared. A logistics company that only handles boxes is not the importer under this test. A customs broker filing the paperwork is not the importer either. The party that owns and controls the commercial fate of the goods is.
This closes off the pure name-lending arrangements that used to let a Japan shell entity be named on a declaration for a fee while a foreign seller ran the actual transaction behind it. What remains available to a non-resident company are two structurally distinct paths, and per firm policy they are never presented as interchangeable alternatives.
The first path is Aplash as the Importer of Record. Aplash purchases the goods from the overseas seller under a genuine back-to-back purchase agreement, takes title before the customs declaration is filed, clears the shipment through Japan Customs in its own name, and re-sells to the Japan buyer. Because Aplash holds real disposition rights under this structure, it satisfies the October 2023 test on its own account. This suits a company that wants no Japan customs identity at all.
The second path is the Attorney for Customs Procedures (ACP, 税関事務管理人). Article 95 of the Customs Act allows a non-resident to remain the named importer on its own declaration by appointing a Japan-resident agent to handle the procedural side of customs clearance. Aplash does not take title under this structure and does not appear as the importer; the non-resident company does. This suits a company that wants to hold the Japan customs identity, and the consumption tax position that comes with it, directly.
Why the Named Importer Decides Who Recovers Consumption Tax
Only the entity named as importer on the declaration can claim import Japanese Consumption Tax (JCT, 消費税) as an input credit against JCT collected on the resale. On meaningful import volumes, that rule decides whether import JCT is a recoverable cost or a permanent one.
(a) Under the IOR structure, Aplash is the importer, pays import JCT at clearance and credits it as input tax in its own JCT return. The Japan buyer pays Aplash a resale price made up of the goods value and the customs duty (plus any agreed charges), with JCT charged on that price at the applicable rate and a qualified invoice (適格請求書) issued; import JCT is never a separate line.
(b) Under ACP, the non-resident company is the importer, pays import JCT directly, and recovers it only if it completes a separate registration chain: appointing a consumption tax payment administrator (消費税の納税管理人), then registering as a Qualified Invoice Issuer (適格請求書発行事業者) if it conducts B2B sales in Japan. Skipping either step leaves the import JCT stranded as an unrecoverable cost, regardless of how correctly the customs side was handled.
(c) Whichever structure is used, the entity that is not the named importer has no claim on that JCT credit. This is why "who appears on the import declaration" is a commercial decision with a tax consequence attached, not a formality to settle after the fact.
The ACP Appointment Timeline
Engaging an ACP provider and signing the appointment typically takes one to two weeks. Filing the notification (税関事務管理人届出書) with the relevant Customs office and having it recorded runs approximately two more weeks. First import can proceed once the appointment is on record, putting most non-resident companies three to four weeks from engagement to their first cleared shipment. The appointment cannot be filed retroactively, so this sequence has to run before any shipment is planned.
Exporter of Record (EOR): The Export-Side Equivalent#
Exporter of Record addresses a different problem than IOR: moving goods out of Japan, in a company's own name, without a Japan entity. It does not refer to hiring or employing staff in Japan. That is a different service, described under a similarly-worded but unrelated term ("Employer of Record") used elsewhere in the market to describe a third party that legally employs staff on a company's behalf for payroll and visa purposes. The two are easy to confuse because the acronym is identical; they have nothing else in common, and a company evaluating either should confirm up front which of the two a provider means.
Aplash's EOR service covers export compliance from Japan, and it splits into the same two structures as the import side, mirrored on the export declaration (輸出申告):
In Client-Named-Exporter EOR, the non-resident company remains the named exporter and Aplash acts only as the Japan-resident procedural agent handling the export filing. This role is granted directly under Aplash's own service agreement and applies to the export declaration only. It is a separate appointment from the Article 95 (第95条) role a non-resident importer uses on the import side, so the two should not be described as the same appointment even though both put a Japan-resident party on record for customs procedures. This structure is the standard fit for re-exporting goods that entered Japan under temporary admission (一時輸入): demonstration units and trade show exhibits brought in under an ATA carnet, equipment sent back out after repair, and similar round-trip movements where the same party that imported the goods needs to send them home. See our Client-Named-Exporter EOR guide for the full structure.
Under buy-and-sell EOR, Aplash takes title to the goods and becomes the named exporter itself under the Foreign Exchange and Foreign Trade Act (外為法). This is used where a non-resident wants full delegation of the export-side liability, including the compliance exposure that comes with being the party of record on a controlled or license-required shipment.
Where EOR Comes Up
The most common trigger is temporary admission. Goods that entered Japan duty-free and JCT-free under a re-export condition must leave again within the admitted period; when that re-export happens, someone has to be the named exporter on the corresponding declaration, and for a non-resident company that party is the ACP-based EOR structure described above.
The second common trigger is two-way trade: a company that already uses Aplash as IOR to bring goods into Japan later needs to move goods back out, whether that is returning defective stock, shipping a repaired unit home, or exporting Japan-sourced goods it has purchased for resale elsewhere. Where the underlying goods intersect with Japan's export control regime under the Foreign Exchange and Foreign Trade Act, screening for controlled technology or dual-use classification runs alongside the export filing itself; that screening is a compliance question specific to the goods and end-use, decided case by case.
Choosing Between the Two Import Structures, and When Export-Side Matters#
The decision between Aplash-as-IOR and ACP on the import side turns on one question: does the company want to hold the Japan importer identity, and the JCT recovery position that comes with it, itself, or hand the entire customs role to Aplash and stay off the declaration. A fuller comparison of the two, including the questions that determine the right fit, is covered in our IOR vs ACP structure guide. Aplash's importer of record service runs the buy-and-sell structure described above end to end, from the back-to-back purchase agreement through customs clearance and resale to the Japan buyer.
Export-side EOR only becomes relevant once goods are already moving through one of the two import structures above, since a re-export or onward export presupposes an import already happened. An import structure and EOR do not substitute for each other; a company moving goods in both directions typically needs both. Companies exhibiting at a trade show and planning to take their goods home afterward should read the temporary admission and ATA carnet guide before shipping, since the re-export deadline attached to the carnet is where most first-time exhibitors run into trouble.
What This Looks Like Across a First Year#
A company testing the Japan market with no entity typically moves through three stages. First, it ships under ACP or Aplash-as-IOR while it validates demand, with no Japan entity, no visa application, and monthly overhead limited to the per-shipment IOR or ACP fee. Second, once volume and commitment justify it, it incorporates a KK or GK, at which point the entity becomes its own importer of record directly and engages a licensed customs broker (通関業者) for filing. Third, with the entity in place and its own import identity established, ACP is no longer needed for future shipments, since ACP is only available to a non-resident; the same logic applies on the export side if the company also used EOR for re-export or export shipments during the testing phase. For the cost math of staying on these structures versus incorporating, see our IOR vs entity cost-benefit guide.
Frequently Asked Questions#
Do I need a Japan entity to import goods for the first time?
A first import does not need a Japan entity. Both Aplash-as-IOR and ACP let a non-resident company clear its first shipment through Japan Customs without incorporating a KK or GK. The choice between the two structures turns on whether the company wants to hold the Japan importer identity itself (ACP) or hand the entire customs role to a party that takes title to the goods (IOR), not on whether an entity is required, since neither path requires one.
Is EOR the same thing as Employer of Record?
The two share an acronym and nothing else. Exporter of Record covers export compliance and the export declaration (輸出申告) for goods leaving Japan. Employer of Record is an unrelated service, used elsewhere in the market, for a third party that legally employs staff on a company's behalf for payroll and visa purposes. Confirm which one a provider means before engaging, since the terms are easy to conflate and describe different services.
How long does it take to get from engagement to a first cleared shipment?
For ACP, engaging a provider and signing the appointment typically takes one to two weeks, and filing the notification (税関事務管理人届出書) with the relevant Customs office and having it recorded runs approximately two more weeks, putting most non-resident companies three to four weeks from engagement to their first cleared shipment. The appointment cannot be filed retroactively, so this sequence has to run before any shipment is planned.
Is a Client-Named-Exporter EOR appointment the same as an ACP appointment on the import side?
Client-Named-Exporter EOR is a separate appointment from the Article 95 (第95条) role a non-resident importer uses on the import side. It is granted directly under Aplash's own service agreement and covers the export declaration only, so the two should not be described as the same structure even though both put a Japan-resident party on record with Customs.
This article is informational only and does not constitute legal, tax, or regulatory advice. Consult a qualified advisor before acting on the content. Last updated: September 2026.