An Attorney for Customs Procedures (税関事務管理人), or ACP, is a Japan-resident agent that a non-resident company appoints under Article 95 of the Customs Act (関税法) to handle customs formalities on its behalf. You need one whenever your company wants to be the Importer of Record (IOR) in Japan without a local address, office, or resident staff, typically for market testing, e-commerce fulfillment, or import volume that does not yet justify incorporating.
What Is an ACP (Attorney for Customs Procedures)?#
An ACP is the Japan-resident procedural agent a non-resident importer is legally required to appoint before it can clear goods through Japanese customs. The ACP is not the importer. Article 95 of the Customs Act (関税法第95条) defines the role: a person without an address, residence, or office in Japan who intends to engage in customs procedures must appoint a resident agent to act on their behalf.
The non-resident entity remains the actual importer. It owns the goods and pays the duties and taxes. The ACP liaises with Japan Customs, files the required notification (届出), and keeps the records the law demands, but legal responsibility for the goods and the tax position stays with the non-resident. This distinction matters for every downstream question in this article, from tax deductibility to which entity carries audit exposure.
Why Was the Old Third-Party IOR Model Banned?#
Japan Customs tightened the importer definition in October 2023 because the prior system let foreign sellers name any Japanese company as IOR, including companies with zero commercial interest in the goods. That created four systemic problems the reform was designed to close: customs valuation fraud, unanswerable compliance questions during audits, unrecovered consumption tax, and a structural lack of accountability.
Specifically, non-residents could route shipments through nominee importers who provided artificially low invoices, which understated duty and Consumption Tax (JCT) at the border. Those nominee IORs then had no real knowledge of the goods and could not answer Customs' questions in a post-clearance audit (事後調査). Consumption Tax on the resulting domestic sales frequently went unreported, and because the nominee held no actual stake in the goods, it had no incentive to police any of this.
The reform replaced "any Japanese company willing to be named" with "person with disposition rights (処分権限)," meaning whoever actually controls the goods must be the importer of record. If that controlling party sits outside Japan, an ACP is what makes it legally possible for them to remain the IOR anyway. For a fuller comparison of when the non-resident should hold IOR status directly versus route through a different structure, see IOR vs ACP for Japan Imports.
How Long Does ACP Setup Take?#
ACP setup runs roughly three to four weeks from engagement to first import. The sequence is: sign a service agreement with an ACP provider (roughly one to two weeks), the ACP files the required notification (届出) with the relevant Customs office (roughly two weeks), then registration is confirmed and import operations can begin.
Once registered, the ongoing import flow does not change shape shipment to shipment. The non-resident ships goods to Japan, a freight forwarder handles the physical logistics, and a licensed customs broker files the import declaration naming the non-resident as IOR. The ACP coordinates between the broker and Customs, and duties and Consumption Tax (JCT) are assessed and paid, since a 2024 rule change, through the ACP's own bank account. Goods are then released for domestic distribution, and the ACP maintains the records Article 95 requires. The document flow that keeps this sequence from stalling on a first shipment is covered in The Document Checklist That Keeps Your First Japan IOR or ACP Shipment From Stalling.
What Does an ACP Provider Actually Do?#
An ACP provider's scope extends well past filing the initial notification. In practice it covers:
(a) ACP registration and ongoing notification maintenance with Japan Customs, plus liaison with customs brokers, freight forwarders, and individual Customs offices; (b) documentation handling (commercial invoices, shipping documents, declarations), customs valuation under the Customs Tariff Act, HS classification, and advance ruling applications for binding determinations on classification, valuation, or origin; (c) regulated-product compliance support, spanning PSE/PSC product safety, the Food Sanitation Act, and the Radio Act (電波法), record-keeping under the Customs Act, and security export control screening under the List Control and Catch-All Control provisions of the Foreign Exchange and Foreign Trade Act (外国為替及び外国貿易法).
Where the goods themselves trigger a separate certification requirement, that runs in parallel to the ACP relationship rather than through it; see Do You Need PSE, PSC, or Food Safety Certification for how that determination is made.
Does ACP Affect Consumption Tax (JCT) Recovery?#
Yes, and this is the mechanic most non-residents underestimate. Import Consumption Tax (JCT) paid at the border is deductible as input tax against output JCT on domestic sales, but only for the entity that is legally the IOR.
If the non-resident routes through an ACP and holds IOR status itself, the import JCT it pays is deductible against its own output JCT. If a third party is nominally IOR instead, the non-resident cannot deduct that JCT at all: it becomes an unrecoverable cost on every single import, and on meaningful volume that compounds materially year over year. The non-resident IOR also has two related obligations: appointing a Consumption Tax (JCT) tax representative (消費税の納税管理人), and, for B2B sales, registering as a Qualified Invoice Issuer under the Qualified Invoice System, which itself launched alongside the October 2023 importer reform.
Do I Need ACP or a Full Japan Entity?#
ACP is sufficient when the goal is speed and low commitment; a full entity is required once the business needs a legal presence beyond customs clearance. The dividing line runs through what the entity is actually for, not through import volume alone.
Key points:
(a) ACP is enough for market testing before incorporating, e-commerce fulfillment (Amazon FBA, Rakuten import-and-sell) without a local entity, contractual fulfillment shipments, low-volume imports where entity overhead is not justified, and setup speed (three to four weeks against three to six months for entity formation). (b) A full entity is needed once the business requires permanent employees under a Japan legal employer (or an Employer of Record as a bridge structure), banking or licensing that requires a Japan entity, a Business Manager or Highly Skilled Professional (HSP) visa holder running the operation, scaling past validation volume, a Japan brand address, or a regulated-product license that names a Japan entity as the holder. (c) A common progression pairs ACP plus non-resident IOR with an Employer of Record for year-one hires, then incorporates a KK or GK in year two, transfers IOR status to the new entity, and drops the ACP once the entity is fully operational.
For a structural side-by-side of these two paths, see IOR vs ACP for Japan Imports, and for the ACP service scope and engagement structure, see Aplash's ACP page directly.
What Happens If ACP Is Set Up Incorrectly?#
Getting the ACP relationship wrong exposes the non-resident to customs, tax, and reputational risk simultaneously. Goods can be held at the border pending correction, generating storage charges, delivery delays, and spoilage risk on perishable or time-sensitive cargo.
Beyond the immediate shipment, a post-clearance audit (事後調査) can reach back across years of import history, assessing additional duty, Consumption Tax (JCT), and penalties on top of the original liability. Any JCT lost to an incorrect IOR structure is permanently unrecoverable, not merely delayed. The Customs Act also carries penalties for false declarations, undervaluation, or record-keeping failures, and a flagged import history invites enhanced scrutiny on every subsequent shipment. Recovering some of that unrecovered duty after the fact is possible in narrow circumstances; see Japan Duty Drawback Guide for what qualifies.
How Do I Choose an ACP Provider?#
Screen for a certified customs specialist (通関士) on staff, ACP and Consumption Tax (JCT) tax representative service offered under one provider rather than split across two, and demonstrated experience with regulated products such as PSE/PSC, the Food Sanitation Act, the Radio Act (電波法), and cosmetics. A provider with an actual track record of ACP registrations and clearances, advance ruling application capability, and transparent pricing is a materially lower-risk choice than one offering ACP as a side service.
What Is the Current Regulatory Timeline for ACP?#
Three changes since 2023 shape the current ACP landscape. October 2023 clarified the importer definition, effectively ending the third-party IOR model, and launched the Qualified Invoice System, which requires a registered invoice for JCT input credit. In 2024, Japan Customs moved to automatic duty and tax payment through the ACP's own bank account for non-resident importers, replacing older payment routing. In October 2025, the Business Manager visa reform raised the required capital to JPY 30 million, which made full entity entry meaningfully more expensive and made ACP comparatively more attractive as a market-testing structure while a company builds toward incorporation.
For the underlying statutory text, Article 95 of the Customs Act is published in full on the Japan Customs (税関) site and in the government's official English translation database. Consumption Tax representative and Qualified Invoice System rules are published by the National Tax Agency, and Business Manager visa capital requirements are administered jointly with Ministry of Economy, Trade and Industry guidance on foreign business entry.
Frequently Asked Questions#
Is the ACP the same as the importer of record?
No. The ACP is a Japan-resident procedural agent appointed under Article 95 of the Customs Act (関税法第95条) to handle customs formalities; the non-resident company remains the actual Importer of Record (IOR), owns the goods, and carries the tax liability. Confusing the two roles is the single most common structural error non-residents make when entering Japan.
Can I switch from ACP to a full Japan entity later without disrupting imports?
Yes, this is a common and well-established progression. A company typically runs ACP plus non-resident IOR during market validation, incorporates a KK or GK once volume justifies it, and then transfers IOR status to the new entity, at which point the ACP is no longer needed.
Why does it matter whether I or a third party holds IOR status?
Import Consumption Tax (JCT) is deductible as input tax only for the entity that is legally the IOR. If a third party holds nominal IOR status instead of your company, the JCT you pay at import becomes permanently unrecoverable, which compounds into a material cost on meaningful import volume.
Conclusion#
ACP exists to let a non-resident company import into Japan legally without first standing up a local entity, but it only works if the non-resident, not a nominee, holds IOR status. Get that structure right and ACP delivers speed and JCT recovery; get it wrong and the exposure runs from held goods at the border to a multi-year post-clearance audit.
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: August 2026.