Most guides explain what an Attorney for Customs Procedures (税関事務管理人) is. Almost none explain how to actually set one up. The gap is consequential: getting the sequence wrong, particularly missing Qualified Invoice System (インボイス制度) registration before your first shipment, creates consumption tax (消費税) deductibility problems that cannot be fixed retroactively. This guide covers the full setup sequence from first contact through ongoing compliance, so you know exactly what to expect before your first cleared shipment.
What ACP Is (Quick Recap)
Under the Customs Act (関税法) Article 95, a non-resident entity that wants to be named as the legal importer on Japan import declarations (輸入申告) must appoint a Japan-resident agent to handle customs procedures on its behalf. That agent is the Attorney for Customs Procedures (税関事務管理人). The non-resident company remains the importer of record and retains title to the goods; the ACP provider is the statutory contact point for Japan Customs, accepts service of notices, and coordinates the clearance process. ACP does not transfer ownership or liability in the way that a buy-and-sell Importer of Record structure does.
The Three Registrations Required Before Your First Shipment
Before any compliant import declaration can be filed under the ACP structure, three separate registrations must be in place. Each involves a different authority, a different processing timeline, and a different consequence if missed.
(a) ACP Notification with Japan Customs
The ACP notification (税関事務管理人届出書) is filed with the relevant Japan Customs office and formally records the ACP appointment. It names the non-resident importer, identifies the Japan-resident ACP agent, and covers the specific port or customs office where declarations will be filed. This notification must precede any import declaration. It cannot be backdated. An appointment covering one customs office does not extend to other ports; each port of entry requires a separate filing.
(b) Tax Representative Appointment with the National Tax Agency
The non-resident importer must also appoint a Tax Representative (納税管理人) with the National Tax Agency (国税庁). This appointment is required under the Consumption Tax Act (消費税法) and establishes who Japan's tax authority can contact for JCT matters arising from the non-resident's import activity. In practice the ACP provider and the Tax Representative are often the same Japan-resident entity, but the two appointments are legally distinct and filed separately.
(c) Qualified Invoice System Registration with the NTA
The Qualified Invoice System (インボイス制度) registration converts the non-resident importer into a registered Qualified Invoice Issuer (適格請求書発行事業者). This registration is required for the non-resident to credit import JCT paid at clearance against output JCT on downstream domestic sales in Japan. If the first shipment is cleared before QIS registration is complete, the JCT paid on that shipment is not creditable and the loss is permanent. The National Tax Agency's processing window for QIS applications runs approximately four to six weeks. This is the single most common sequencing error in ACP setups.
Why All Three Are Needed and the Dependency Order
The ACP notification unlocks the right to clear customs as a non-resident importer. The Tax Representative appointment satisfies the NTA's requirement for a reachable contact. QIS registration enables the JCT input credit that makes recurring imports economically viable. None substitutes for another.
The practical dependency: the ACP notification and Tax Representative appointment can proceed in parallel, but QIS registration must be submitted early enough that NTA processing completes before the first shipment clears customs. Because QIS is the longest-lead item, it should be initiated at or before engagement, not after the ACP notification has been filed.
Step-by-Step Setup Timeline
The table below reflects a standard engagement. Complex situations, multi-port setups, and incomplete document packages extend these windows.
| Week | Activity | Notes |
|---|---|---|
| 1-2 | Engagement and document collection; ACP service agreement executed | Corporate documents, authorized signatory verification, intended customs office(s) confirmed |
| 2-3 | ACP notification filed with relevant customs office | Filed by Aplash on non-resident's behalf |
| 2-3 (parallel) | Tax Representative appointment submitted to NTA | Filed under the Consumption Tax Act; often same entity as ACP provider |
| 2-3 (parallel) | QIS registration application submitted to NTA | Allow 4-6 weeks for NTA processing; this is the critical-path item |
| 4-6 | QIS registration confirmed by NTA | First compliant import should not be cleared before this confirmation |
| 6+ | First import declaration filed; goods cleared | Aplash coordinates with customs broker (通関業者); non-resident named as IOR on import declaration |
Total timeline: typically four to six weeks from engagement to first compliant shipment. Delays most commonly arise from incomplete document packages at intake or from initiating QIS registration late.
Documents Required from the Non-Resident Company
The following documents are typically required at intake. Specific requirements may vary depending on the non-resident's jurisdiction of incorporation and the complexity of the import program.
- Certificate of incorporation or equivalent company registration document (apostille or consular authentication where required)
- Articles of association or equivalent constitutional document
- Evidence of authorized signatory authority (board resolution or power of attorney naming the individual signing the ACP agreement)
- Company registration number and registered address
- Description of goods to be imported, including preliminary tariff classification (関税率表) where available
- Intended Japan port(s) of entry
- Anticipated import volume and frequency (for scoping the service structure)
All documents in languages other than Japanese or English will require certified translation.
The Ongoing Import Flow: What Happens on Each Shipment
Once all three registrations are in place, the operational flow for each shipment is as follows.
The non-resident importer and the customs broker (通関業者) prepare the import documentation: commercial invoice, packing list, bill of lading or airway bill, and any product-specific permits or certificates required for the goods. Aplash coordinates this process, acts as the point of contact with Japan Customs, and ensures the import declaration correctly names the non-resident company as the importer of record.
The customs broker files the import declaration (輸入申告) with Japan Customs through the NACCS (Nippon Automated Cargo and Port Consolidated System, 輸出入・港湾関連情報処理システム). Customs duties (関税) and import JCT are assessed and paid. If the goods are subject to examination, Aplash handles Customs communications on the non-resident's behalf. Upon payment and release, the goods are delivered to the designated Japan-side consignee.
Import JCT paid at clearance is recorded and subsequently credited against the non-resident's output JCT on domestic B2B sales, processed through the NTA via the Tax Representative. This is the JCT recovery path that makes the ACP structure economically attractive for recurring importers.
Ongoing Compliance Obligations
The ACP structure carries continuing obligations that must be managed throughout the engagement.
Record-keeping under the Customs Act (関税法). The non-resident importer, through the ACP provider, must retain import-related documentation for five years. This includes import declarations, commercial invoices, valuation documentation, and any post-clearance audit correspondence.
Annual QIS reporting. As a registered Qualified Invoice Issuer, the non-resident must file periodic JCT returns with the NTA through the Tax Representative. The frequency depends on the non-resident's annual taxable sales volume in Japan.
ACP notification updates. If the non-resident's corporate details change (company name, registered address, authorized representative, or intended ports of entry), the ACP notification on file with Japan Customs must be updated. Stale notifications create procedural exposure at clearance.
Ongoing engagement maintenance. Aplash maintains the appointment record, conducts periodic client reviews, and manages Customs correspondence throughout the engagement term.
What ACP Does Not Cover
ACP is a customs procedures appointment. It covers import declarations (輸入申告) and customs-related procedures under the Customs Act (関税法). It does not cover product-specific safety and compliance filings, which are governed by separate laws and separate authorities.
If the goods being imported fall under any of the following regimes, parallel compliance work is required before or alongside the first import:
Electrical Appliance and Material Safety Act (電気用品安全法, PSE certification). Required for a defined list of electrical products. Compliance involves either obtaining PSE certification from an accredited body or operating under the Notifying Supplier (届出事業者) framework.
Food Sanitation Act (食品衛生法). Applies to food products, food-contact materials, and certain utensils. Requires notification to the Ministry of Health, Labour and Welfare (厚生労働省) at the port of entry.
Radio Act (電波法). Applies to wireless and radio-frequency devices. Products must carry the Technical Conformity Mark (技適マーク) before import for sale or use in Japan; approval is issued by an MIC-designated certification body.
These filings are independent of the ACP appointment. A non-resident importer who secures an ACP notification but ships non-compliant goods will face clearance refusal or post-clearance enforcement regardless. Both workstreams should be scoped and initiated together.
Pricing Structure
ACP engagements are typically structured as a one-time onboarding fee covering the initial ACP notification filing, combined with an annual or semi-annual retainer for ongoing appointment maintenance and a per-declaration fee for each import shipment. The economics depend on import volume and whether the client requires only the statutory ACP appointment or a full-service arrangement that includes customs broker coordination via a licensed customs specialist (通関士).
For recurring importers, the JCT recovery path is the key financial driver. Import JCT on B2B imports is typically creditable in full against output JCT once QIS registration is in place, reducing the net cost of the ACP structure significantly at scale. The setup cost and per-shipment fee are generally recovered within the first several shipments for importers with meaningful volume.
This article is informational only and does not constitute legal, customs, or tax advice. Procedures and requirements are subject to change. Before acting on the content of this article, consult a qualified licensed customs specialist (通関士), licensed tax accountant (税理士), or attorney (弁護士) with relevant Japan experience. Last updated: June 2026.