Can a Japan Importer of Record Import Goods Before You Have a Buyer? (2026)

In short

Yes. A Japan Importer of Record can bring goods into Japan and hold them before a downstream buyer is secured, provided a disposal path is agreed before the import declaration (輸入申告) is filed, not...

Can a Japan Importer of Record Import Goods Before You Have a Buyer? (2026)

Yes. A Japan Importer of Record can bring goods into Japan and hold them before a downstream buyer is secured, provided a disposal path is agreed before the import declaration (輸入申告) is filed, not arranged afterward. Duties and Japan Consumption Tax (JCT, 消費税) are funded upfront, and a maximum hold period is fixed in advance. Goods are never imported and simply left in limbo with nothing agreed.

Does Japan Customs Require a Buyer to Be Identified Before Import?#

No. Japan Customs does not require a downstream buyer to be identified at the time of import. What it requires is that the named importer hold actual disposition rights (処分権限) over the goods, a standard that followed the 2023 reform to the Customs Act (関税法). Disposition rights are about who controls what happens to the goods, not about whether a resale contract with an end buyer already exists.

This is the structural basis for what IOR and EOR in Japan: How to Import and Export Without a Japan Entity describes as import-and-hold: the importer takes title, clears customs in its own name, and carries the goods while a buyer is identified. The importer's control over the goods, evidenced by title and the arrangements made before filing, is what satisfies the Customs Act standard. A buyer showing up later does not retroactively create the disposition rights; they exist because the importer already holds title and has a disposal path arranged.

What Has to Be in Place Before the Goods Are Imported?#

Three things have to be settled before filing, not after. Skipping any of them turns an import-and-hold structure into an open-ended liability with no agreed way out.

Key points:

(a) Duties and JCT funded upfront. Duties and Japan Consumption Tax are paid at the point of clearance regardless of whether a buyer has been found yet. The client funds this in advance; it is not deferred until a sale closes.

(b) A maximum hold period agreed in advance. The goods do not sit indefinitely. A ceiling on how long the hold runs is fixed before import, so the importer, and anyone financing the position, knows the window it is working inside.

(c) A disposal path agreed before the import declaration is filed. This is the condition that actually satisfies the disposition-rights standard. A fallback path, even one less attractive than the buyer the client hopes to land, must already be arranged as the position of last resort before the goods are ever declared.

What Happens Once a Japan Buyer Is Found?#

Once a buyer is identified inside the hold period, the goods are resold to that buyer under an ordinary sale, with duties and JCT already paid passed through at cost. This is the most common exit and the one the structure is generally designed around. It closes the import-and-hold position cleanly: the importer's title transfers to the new buyer, and the transaction is priced on the same basis any IOR resale is priced.

Three other exits exist for situations where a straight resale is not the right fit. Where the counterparty wants use of the equipment without taking title, or the hold period is really a trial or evaluation window ahead of a purchase decision, a lease structure can substitute for a sale, though a lease is the wrong tool for consumables, single-use goods, or anything whose return logistics would be impractical. Where no Japan buyer ever materializes and the goods need to leave Japan, re-export is available, and this pairs cleanly with goods that entered under Temporary Admission; see the Japan Duty Drawback Guide for how duty recovery works on goods that leave Japan again after import. Where the hold is expected to run long, placing the goods with a Japan-based commercial partner who takes custody is possible, but that is a distinct, separately arranged path, not a casual storage arrangement.

Does Fixed Asset Tax Apply to Goods Held Pending a Buyer?#

It depends entirely on which exit path the goods sit under, not on how long they stay in Japan. Goods held as ordinary inventory pending resale, and goods that will be re-exported, are not subject to Fixed Asset Tax (固定資産税) at all, because inventory held for resale is classified as stock-in-trade (棚卸資産) rather than as a depreciable business asset.

The exposure shows up specifically on the lease path and the long-term partner-placement path, because in both of those the goods are being used as a business asset rather than held as resale stock. This distinction, and the mechanics of the assessment date and how to plan around it, is covered in full in When Must You Remove Business Equipment From Japan to Avoid Fixed Asset Tax?. The point to take from this post is narrower: choosing the resale exit or the re-export exit keeps a held shipment outside Fixed Asset Tax exposure altogether, while the lease and partner-placement exits do not.

Frequently Asked Questions#

Can Aplash import goods into Japan on our behalf before we have found a Japan customer?

Yes, provided a disposal path is arranged before the import declaration is filed, duties and JCT are funded upfront, and a maximum hold period is agreed in advance. The goods are never imported with nothing settled; a fallback disposal path stands as the position of last resort even before a preferred buyer appears.

Who pays the duties and consumption tax if no buyer has been found yet?

The client funds the full estimated duties and Japan Consumption Tax (消費税) upfront. These are paid at clearance regardless of whether a buyer has been identified, because payment is a condition of the import declaration itself, not of the eventual sale.

Does holding imported goods in Japan trigger Fixed Asset Tax even if we have not sold them yet?

Not if the goods are held as ordinary inventory pending resale or destined for re-export; both are classified as stock-in-trade (棚卸資産) and fall outside Fixed Asset Tax. The exposure arises specifically where the goods are placed on a lease or with a long-term custody partner and used as a business asset rather than held as resale stock.

Conclusion#

Import-and-hold is a workable structure under Japan's disposition-rights standard, but only when the disposal path, the funding of duties and JCT, and the hold period are all settled before the import declaration is filed. Which exit path applies at the end of the hold, resale, lease, re-export, or partner placement, determines both the commercial outcome and the Fixed Asset Tax position. For the underlying structure that makes import-and-hold possible without a Japan entity, see the IOR/EOR service page.


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.