This post collects the questions foreign companies ask most often when they first encounter IOR, EOR, and ACP as terms describing how to move goods into Japan or hire staff there without a Japan legal entity. Each answer is deliberately short; where a fuller walkthrough exists elsewhere on this site, it is linked. Use this page as a starting index, not a substitute for the dedicated posts on any topic that applies to your situation.
General
What do IOR, EOR, and ACP stand for? IOR is Importer of Record. ACP is Attorney for Customs Procedures (税関事務管理人). EOR is Employer of Record in a hiring context, though the same three letters also mean Exporter of Record in a trade-compliance context; the two meanings are unrelated and covered separately below.
Do I need all three? Almost never. IOR and ACP both address moving goods into Japan and are alternatives to each other, not a pair you use together for the same shipment. EOR addresses hiring a worker in Japan and is unrelated to the goods-side decision. A company that both ships product into Japan and hires a local sales representative may need one goods-side structure (IOR or ACP) plus EOR, run as two separate engagements.
Is any of this required if I already have a Japan entity? No. IOR, ACP, and EOR all exist specifically to let a company operate in Japan, importing goods or hiring staff, without first setting up a Japan legal entity. A company with its own Japan-registered entity is already its own importer and its own employer under Japan law and does not need any of these three structures for that purpose.
IOR
What is IOR, in plain terms? A Japan-resident provider becomes the legal importer named on your customs declaration. It buys your goods from you (or from your overseas seller), clears customs in its own name, and re-sells to your Japan buyer. You are never named on the import declaration.
Who is liable if something goes wrong with the declaration under IOR? The IOR provider, since it is the party named as importer and the party that holds legal title at the point of customs clearance.
Can I recover Japan consumption tax paid on the import if I use IOR? Not directly. Under IOR, the provider pays and recovers import consumption tax through its own tax filing, since it is the named importer. Your company does not appear on that filing.
Does IOR require me to have any Japan presence? No. IOR exists specifically for companies with no Japan address, residence, or office.
ACP
What is ACP, in plain terms? Your company remains the legal importer named on the declaration. A Japan-resident agent, appointed under the Customs Act (関税法), handles the procedural interface with Japan Customs on your behalf, because a non-resident company cannot interact with Customs directly.
Who is eligible for ACP? Only companies that are genuinely non-resident in Japan, meaning no Japan address, residence, or office. If your company has any Japan presence, even a registered branch, ACP is not available and you would need to file directly.
Can I recover Japan consumption tax paid on the import if I use ACP? Yes, but not automatically. Recovery requires appointing a Japan-resident tax agent and registering as a Qualified Invoice Issuer, both separate from the ACP appointment itself. Without these, the import consumption tax your company pays at the border becomes a permanent cost rather than a recoverable credit.
Is ACP cheaper than IOR? The fee structures are built differently rather than directly comparable. ACP is typically priced as a flat per-event fee because the agent carries no title risk and advances no duty or tax. IOR pricing scales with cargo value because the provider is taking on title, capital advance, and full importer liability. Which one is actually less expensive for your situation depends on shipment volume, product complexity, and whether you can manage the tax registrations needed to recover import consumption tax under ACP.
IOR vs ACP
How do I decide between IOR and ACP? The deciding question is whether you want to be named as the importer yourself. If yes, subject to the non-resident eligibility requirement, that points to ACP. If you would rather someone else take on that role and its liability entirely, that points to IOR.
Can a provider offer both and let me pick whichever is more convenient? A provider can offer both, but they answer opposite preferences on the same question and should never be presented as interchangeable options you choose based on convenience alone. Choosing without first deciding who you want named as importer, and drifting between the two structures shipment to shipment without documentation, is itself a pattern that draws scrutiny in a customs review.
What happens if I just let my distributor or freight forwarder be named importer informally, without either structure? This is a nominee arrangement, sometimes called name-lending, and it is not a compliant substitute for either IOR or ACP. It creates undocumented liability for whoever is named importer and exposes your company once the arrangement is examined.
EOR (Employer of Record)
What is EOR, in the hiring sense? A Japan-resident entity becomes the legal employer of a worker based in Japan, running payroll, enrolling the worker in social insurance, and handling tax withholding, while your company directs the worker's actual day-to-day duties under a separate agreement.
Does EOR require a Japan entity? No. That is the entire point of the structure: it lets you engage a Japan-based worker without first incorporating.
Is EOR the same as a PEO? No. The PEO co-employment model common in other markets does not have a direct equivalent under Japanese labor law; EOR is structured differently to fit Japan's legal framework for employment.
Does EOR include a work visa? Not automatically, and this depends on the worker's nationality and the specific arrangement; visa sponsorship is a separate question from the employer-of-record function itself and should be confirmed explicitly before assuming it is included.
I saw "EOR" used in an export-compliance context. Is that the same thing? No. In a trade and customs context, EOR commonly means Exporter of Record, an export-compliance role distinct from Employer of Record. If EOR comes up alongside export licensing or export declarations rather than hiring, that is the other meaning.
Practical Starting Questions
I am not sure which structure applies to me. Where do I start? Identify what you are actually trying to do in Japan: bring in physical goods, hire a worker, or both. Goods point to the IOR-versus-ACP decision above. Hiring points to EOR. Both point to two separate, parallel engagements rather than one combined product, since the legal frameworks behind goods and employment do not overlap.
Does the size of my shipment or hire matter for which structure I need? It affects pricing and, for goods, whether a de minimis exemption removes the need for either IOR or ACP entirely on very low-value shipments. It does not change which structure is the right one once you are above that threshold; the underlying decision logic is the same regardless of scale.
What should I have ready before asking for a proposal? For goods: a product description or HS code, approximate shipment value, expected frequency, and any product-specific regulatory flags (electrical safety, radio certification, food, medical, or export-control adjacency). For hiring: the role, expected start date, and whether visa sponsorship is needed. Providers can scope an accurate proposal far faster with this in hand than from a general inquiry.
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: July 2026. Aplash is a regulatory strategy and market entry firm.