Chile is unusual among Japan's trade partners in one specific way: it has two separate preferential tariff routes into Japan running at the same time. The Agreement between Japan and the Republic of Chile for a Strategic Economic Partnership entered into force on 3 September 2007, more than fifteen years before the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP) entered into force for Chile on 21 February 2023. Both remain in force today, and a Chilean exporter shipping to Japan, whether mining equipment, wine, copper products, or agricultural goods, has to actively decide which agreement to claim preference under rather than defaulting to whichever one comes to mind first. That choice sits alongside the same structural question every non-resident exporter without a Japan entity faces: who is named as the importer on the Japan import declaration (輸入申告).
Two Agreements, Not One
The Japan-Chile Economic Partnership Agreement (EPA) predates CPTPP by well over a decade and has its own tariff schedule and its own product-specific rules of origin, negotiated bilaterally between the two countries. CPTPP, which Chile joined years after the original Trans-Pacific Partnership negotiations, brought Chile into a much larger multilateral framework spanning eleven other member economies including Japan, Canada, Mexico, Australia, and Vietnam, with its own separate tariff schedule and its own rules of origin that are not identical to the bilateral EPA's terms.
This matters in practice because the two agreements do not always produce the same result for the same product. A given tariff line may have reached a lower rate faster under one agreement than the other, or the origin criterion a product needs to satisfy may be easier to meet under one agreement's rules than the other's. Neither agreement automatically applies; an exporter has to choose one, support the claim with that agreement's specific origin documentation, and cannot mix and match terms across the two on a single shipment. Determining which agreement produces the better outcome for a specific product requires checking both tariff schedules against the good's actual HS classification; this guide does not assert that one agreement is categorically better than the other, because the answer varies by product.
A broader look at how Japan's various EPA and CPTPP preference mechanisms work, including the declaration and origin-certification process common across them, is covered in our EPA and FTA preference utilization guide. Since Canada and Mexico face a comparable multi-agreement question of their own within CPTPP, see our guides for Canadian manufacturers and Mexican manufacturers for how the equivalent CPTPP-only mechanics work.
The Structural Problem: No Japan Entity, No Direct Filing
Whichever preferential agreement a Chilean manufacturer ultimately claims, a company with no Japan-registered office, residence, or address cannot file a Japan import declaration in its own name. Two structures resolve this, and per firm policy they are never presented as interchangeable.
IOR (Aplash as Importer of Record). Aplash purchases the goods from the Chilean manufacturer and clears them through Japan Customs (税関) in its own name, becoming the named importer on the declaration. Because Aplash is the importer under this structure, Aplash is the party that would claim whichever preferential agreement applies, and the duty savings show up in the cost structure of the onward resale to the Japan buyer rather than on the Chilean manufacturer's own books. This suits a manufacturer selling through a Japan distributor or buyer expected to take on the import role itself.
ACP (Chilean Manufacturer as Importer via Attorney for Customs Procedures). Under Article 95 of the Customs Act, reinforced by the October 2023 reform requiring the party with actual disposition rights (処分権限) over the goods to be the named importer, a Chilean manufacturer can remain the legal importer on its own Japan declaration by appointing Aplash as its Japan-resident agent, the 税関事務管理人, to handle customs procedures on its behalf. Aplash does not take title and does not become the importer under this structure. Because the manufacturer is the named importer, it is the manufacturer, not Aplash, that claims preference under the Japan-Chile EPA or CPTPP directly, and the manufacturer is also the party positioned to recover Japan consumption tax, covered below. ACP is available only while the manufacturer remains a non-resident: no Japan address, residence, or office. A manufacturer that later incorporates a Japan entity becomes its own importer and engages a licensed customs broker (通関業者) directly.
Chilean Export Categories Where This Recurs
Mining and industrial equipment. Chile's mining sector drives significant capital equipment trade, and machinery, parts, and specialized mining equipment exported to Japan typically involve routine customs classification, though exporters should confirm early whether any wireless-enabled components intersect with Japan's Radio Act (電波法) certification requirements before assuming a purely customs-driven process.
Wine and agricultural products. Chilean wine has a substantial and growing presence in the Japanese market, and food-category imports carry their own compliance layer independent of the tariff-preference question: food consignments require a separate import notification under the Food Sanitation Act (食品衛生法) regardless of which importer structure applies, and Aplash's ACP service does not extend to the food category for a structural reason covered in our importer-of-record and ACP service references; food inquiries route to a Japan-resident importer structure rather than ACP.
Copper and metal products. Copper and refined metal products moving from Chile to Japan are typically industrial commodity trade with well-established classification, but valuation accuracy matters disproportionately on commodity goods where price benchmarking against published market indices is a routine part of customs review.
JCT Recovery for Chilean Manufacturers Under ACP
Under ACP, the Chilean manufacturer is the importer of record and pays Japan Consumption Tax (JCT, 消費税) at the border. Recovering that JCT rather than absorbing it permanently requires completing a specific three-step registration chain.
(a) ACP appointment with Japan Customs. Aplash files the 税関事務管理人届出書 on the manufacturer's behalf, establishing the manufacturer as the named importer under the Customs Act.
(b) Appointment of a consumption tax payment administrator (消費税の納税管理人) with Japan's National Tax Agency. The manufacturer appoints a Japan-resident party, a role Aplash can fill directly, giving the manufacturer a tax-filing presence in Japan.
(c) Registration as a Qualified Invoice Issuer (適格請求書発行事業者) under Japan's Qualified Invoice System, required where the manufacturer conducts B2B sales in Japan. This registration is what makes import JCT paid at the border creditable against output JCT on the manufacturer's Japan sales.
Without all three steps, import JCT sits outside the manufacturer's Japan tax position as a permanent cost. With all three in place, it offsets against output tax through the manufacturer's own JCT filings, prepared for the substantive computation and return by a licensed tax accountant (税理士).
Common Mistakes Chilean Manufacturers Make
Defaulting to CPTPP without checking whether the older bilateral EPA produces a better result. CPTPP is the newer and more widely discussed agreement, but the Japan-Chile EPA has not been superseded and may offer a faster-staged or more favorable rate on a specific tariff line. Check both before assuming the newer agreement is automatically the right one to claim.
Mixing origin documentation between the two agreements. Each agreement has its own rules of origin and its own declaration format. An origin claim has to be prepared under one agreement's specific terms, not a blend of both.
Assuming a mining-sector reputation exempts equipment from Radio Act review. Industrial equipment with embedded wireless modules, telemetry, or remote monitoring capability still needs a Radio Act determination independent of its industrial classification.
Treating ACP as available for wine and other food-category shipments. It is not. Food consignments route to a different importer structure regardless of the manufacturer's residence status.
Conclusion
Chile is one of the few Japan trade partners where an exporter has a genuine, ongoing choice between a long-standing bilateral EPA and a newer multilateral framework, and getting that choice right on a per-product basis is worth the extra step before the first shipment. Combined with an ACP appointment, a Chilean manufacturer can hold the Japan importer identity itself, claim whichever agreement produces the better outcome, and recover Japan consumption tax, all without establishing a Japan entity. For the equivalent multi-agreement question facing other CPTPP members, see our guides for Canadian manufacturers and Mexican manufacturers.
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: 2026-08.