Wine, spirits, beer, and sake importers researching how to bring product into Japan typically find guidance on customs clearance and, if the brand has read closely, on the Food Sanitation Act (食品衛生法) notification that applies to any food or beverage product. What most of that guidance omits is that alcoholic beverages carry a third, alcohol-specific licensing requirement that sits on top of both: a liquor sales license (酒類販売業免許) issued under the Liquor Tax Act (酒税法), administered by the National Tax Agency (国税庁) through the regional taxation bureau (国税局) with jurisdiction over the applicant. Without this license, a company cannot lawfully import and sell alcoholic beverages commercially in Japan, regardless of whether the customs declaration and the food safety notification are both handled correctly. This article addresses the alcohol-specific layer only. For the general customs-and-food-safety framework that applies to all food and beverage imports, see our companion article on IOR structuring for food and beverage brands.
Why Alcohol Carries a Licensing Requirement That Ordinary Food Imports Do Not
Customs clearance under the Customs Act (関税法) and the food safety notification under the Food Sanitation Act answer two questions: who is the importer of record, and is the product safe to enter Japan's food supply. Neither answers a third question that is specific to alcohol: who is legally permitted to sell it. The Liquor Tax Act treats the sale of alcoholic beverages as a licensed activity in its own right, separate from the act of importing, because liquor tax (酒税) is collected at the point of manufacture, import, and sale, and the National Tax Agency uses the licensing system to control who sits in that collection chain.
This means an alcohol import into Japan has three distinct compliance tracks, not two: (a) the customs import declaration, (b) the Food Sanitation Act notification, and (c) the liquor sales license held by the entity conducting the commercial import-and-sale activity. A company can clear customs and pass food safety inspection on a shipment of wine and still be acting unlawfully if the entity selling that wine into the Japan market does not hold the correct liquor sales license.
The license categories are product- and channel-specific. The National Tax Agency distinguishes, among other categories, a wholesale liquor sales license (酒類卸売業免許) for companies selling to other licensed liquor businesses (importers, distributors, restaurants, retailers) from a retail liquor sales license (酒類小売業免許) for companies selling directly to end consumers. Within the wholesale category there are further sub-classifications tied to specific liquor types and import scope. Which category a given business needs depends on the actual sales channel, the type of beverage, and whether the applicant is importing for its own resale or on behalf of another party. This article describes the concept and the issuing authority; it does not attempt to specify which category applies to any particular business model. Confirm the current licensing procedure and the correct category with the National Tax Agency or with Aplash before committing to an import plan, since requirements in this area are administered case by case and can change.
How the Liquor License Interacts With the IOR Structure
IOR (Importer of Record) When Aplash acts as IOR, Aplash is the buyer and seller of record: Aplash purchases from the overseas producer or exporter, clears customs in its own name, and re-sells to the Japan buyer. Because Aplash is the entity conducting the commercial import-and-sale transaction, the liquor sales license requirement attaches to Aplash, not to the foreign brand. Aplash holds and operates under its own liquor sales license (in the category appropriate to the transaction, most commonly a wholesale license for a business selling to Japan distributors, restaurants, or retailers rather than directly to consumers), and no separate licensing action is required from the overseas brand. This is the structural reason the IOR path is often the lower-friction starting point for a foreign alcohol brand that does not intend to build its own Japan licensing infrastructure immediately: the brand supplies the product and the required certifications, and the licensed entity in Japan is Aplash.
ACP (Attorney for Customs Procedures / 税関事務管理人) Under ACP, the non-resident brand remains the legal importer named on the import declaration, and Aplash acts as the Japan-resident procedural agent before Japan Customs under Article 95 of the Customs Act (関税法第95条). This structural fact does not change under the Liquor Tax Act analysis, and it produces a genuine complication: the liquor sales license is a separate legal appointment tied to the entity conducting the sale, and a non-resident brand acting as its own named importer under ACP still needs its own path to a valid Japan liquor sales license if it intends to be the entity selling the alcohol into the Japan market. The ACP appointment gives Aplash authority to handle customs procedures on the brand's behalf; it does not give Aplash, or the brand, a liquor sales license by extension, and it does not substitute for one.
In practice, a non-resident brand using ACP for alcohol has two genuine paths, not a blended one. The first is to establish its own licensed presence in Japan (directly or through a Japan subsidiary) and hold the liquor sales license in that entity's name, which is a real licensing undertaking with its own application process, review period, and premises or business-plan requirements set by the National Tax Agency. The second is to structure the transaction so that Aplash, rather than the non-resident brand, is the licensed seller, which in practice means moving away from the ACP structure (where the brand is the named importer and seller) toward the IOR structure (where Aplash is the named importer and seller and already operates under its own license). These are two distinct routes with different legal consequences, not interchangeable options within a single ACP engagement, and the choice should be made deliberately at the outset rather than discovered after a shipment has already cleared customs and food safety notification with no lawful seller in place on the Japan side.
Confirm the License Category Before the First Shipment
Because the wholesale, retail, and beverage-type distinctions under the Liquor Tax Act licensing system are specific to the actual business model, a brand should confirm, before the first shipment, which category applies: whether sales will run through Japan distributors and retailers (pointing toward a wholesale license held by the selling entity), whether any direct-to-consumer sales are planned (which raises separate retail licensing considerations), and whether the beverage category (wine, spirits, beer, sake, or a mixed portfolio) carries any category-specific conditions. This confirmation should come from the National Tax Agency or from Aplash, not from a generic import guide or from a counterparty's own representation of what license it holds. A foreign supplier's or local distributor's statement that "our side has the license covered" is a claim to be verified, not a fact to build a shipment plan on; license status should be confirmed directly with the licensed entity's documentation and, where needed, with the issuing taxation bureau.
Practical Setup Sequence
First, decide which entity will be the licensed seller: Aplash under an IOR structure, or the brand's own Japan-licensed entity under an ACP structure. This decision should be made before the customs and food safety tracks are set up, because it determines who needs to hold the liquor sales license and how long that licensing step will take.
Second, if the brand intends to hold its own license, build the National Tax Agency licensing timeline into the overall launch schedule alongside the customs and Food Sanitation Act preparation. Liquor sales licensing is a separate administrative process from both of those tracks and does not run on the same timeline by default.
Third, confirm the correct license category for the actual sales channel and beverage type with the National Tax Agency or with Aplash rather than assuming a single "alcohol import license" covers every distribution model.
Fourth, once the licensed seller and its license category are settled, proceed with the customs and food safety notification setup described in our companion article on food and beverage IOR, coordinating the entity named there with the entity now confirmed to hold the liquor sales license.
Conclusion
The liquor sales license under the Liquor Tax Act is a licensing requirement in its own right, administered by the National Tax Agency and its regional taxation bureaus, and it sits alongside, not inside, the customs and food safety compliance tracks that apply to any beverage import. Under an IOR structure, this requirement is resolved because Aplash operates under its own license as the buyer and seller of record. Under an ACP structure, the non-resident brand remaining the named importer must separately secure its own path to a valid Japan liquor sales license, or the transaction structure should shift toward IOR instead. Treating the license as a checkbox to handle after the first shipment clears customs is the most common error; treating it as a structural decision to make before choosing between IOR and ACP is the correct sequence.
This article is informational only and does not constitute legal, tax, or regulatory advice. Liquor sales licensing categories and procedures under the Liquor Tax Act are administered by the National Tax Agency and its regional taxation bureaus and can be product- and channel-specific; confirm current requirements directly with the National Tax Agency or with Aplash before acting. Consult a qualified advisor before acting on the content. Last updated: 2026-07.