Vietnamese manufacturers exporting to Japan are frequently routed through a Japan-based trading company or intermediary that appears as the importer of record on the customs declaration. That arrangement can obscure the manufacturer's ability to claim preferential tariff treatment under Vietnam's own trade agreements with Japan, and it removes the manufacturer from the customs valuation chain entirely. For a Vietnamese manufacturer that already holds genuine commercial disposition rights over the goods it exports, there is a structural alternative: Attorney for Customs Procedures (税関事務管理人), which allows the manufacturer's own name to appear on the Japan import declaration without establishing a Japan entity.
Vietnam's Position in Japan's Trade Agreement Network
Vietnam sits in an unusual position among the countries covered in this series: it is a member of both the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP) and the Regional Comprehensive Economic Partnership (RCEP), and Japan is a party to both agreements as well. This means qualifying goods manufactured in Vietnam and exported to Japan may be eligible for preferential tariff treatment under either agreement, depending on which rules of origin the goods satisfy and which agreement's cumulation and processing rules are more favorable for the specific product line.
This is a framework-level point, not a rate quotation. The applicable preferential rate depends on the HS classification of the goods, the origin criteria met, and the specific tariff schedule under CPTPP or RCEP in force at the time of import; no specific percentage is asserted here. What is structurally consistent across both agreements is the documentation requirement: to claim preferential treatment, the importer must be able to produce a certificate of origin or an origin declaration that satisfies the rules of the agreement being invoked. A Vietnamese manufacturer that is not itself named as the importer has materially weaker control over whether that origin documentation is correctly matched to the declaration and correctly claimed. When an intermediary is the importer of record, the manufacturer is dependent on that intermediary to file the correct origin claim, with limited visibility into whether it was filed at all.
Why ACP Fits Manufacturers With Existing Disposition Rights
Japan Customs' importer-of-record standard, covered across our other ACP country guides, requires that the party named as importer on the customs declaration be the party that actually holds disposition rights (処分権限) over the goods, meaning substantive commercial authority to decide their use or resale, not a paperwork placeholder. A Vietnamese manufacturer that sells directly to a Japan buyer under its own commercial terms, retains title through the point of sale, and bears the commercial risk of the transaction is exactly the profile this standard describes.
For that manufacturer, ACP is a better structural fit than routing through a trading company or a buy-and-sell importer, for a specific reason: the manufacturer keeps its own name on the declaration and its own transaction price as the customs valuation basis, rather than having an intermediary's resale margin folded into the import chain. This matters directly for CPTPP or RCEP origin claims, because the party making the origin claim on the declaration should be the party that can substantiate the underlying transaction and origin facts. It also matters for ordinary commercial reasons: the manufacturer's brand, pricing discipline, and customer relationship in Japan are not intermediated by a third party appearing as the legal importer.
ACP is not the only structure available to a non-resident manufacturer. Aplash's separate Importer of Record service, where Aplash takes title through a buy-and-sell arrangement and is itself the named importer, exists for manufacturers that want to be removed from the import chain rather than named in it. The two are structurally distinct and are never interchangeable; the comparison is covered in depth in our IOR vs ACP guide. This post addresses the manufacturer that wants its own name on the declaration, which is the ACP case.
The ACP Mechanism: Article 95 of the Customs Act
Attorney for Customs Procedures (税関事務管理人) is a procedural appointment, not a change of ownership. Under Article 95 of the Customs Act (関税法), a non-resident importer, meaning a company with no address, residence, or office in Japan, appoints a Japan-resident agent to handle customs procedures on its behalf. The Vietnamese manufacturer remains the legal importer named on the import declaration (輸入申告). The Japan-resident ACP agent files the appointment notification with the relevant Customs office, acts as the statutory point of contact for Customs inquiries, and manages post-clearance documentation obligations. No title to the goods passes to the ACP agent at any point. This is the same Article 95 framework covered in our Southeast Asian manufacturers, China manufacturers, and ACP registration guides; the mechanism does not change by country of origin, only the origin-documentation and authentication practicalities do.
Practical Documentation: Vietnamese Corporate Entities
A Vietnamese manufacturer engaging an ACP agent needs to produce corporate documentation establishing the entity's existence and authority to appoint an agent, typically including a business registration certificate and a board resolution or power of attorney naming the ACP agent. The question that matters practically is how that documentation gets authenticated for use in Japan.
Vietnam's participation in the Hague Apostille Convention has been reported as being in transition as of mid-2026, with accession completed but entry into force reported for later in the year. Until Vietnam's apostille regime is confirmed as operative, the applicable authentication path for Vietnamese corporate documents intended for use in Japan should be treated as the traditional consular authentication chain through the Japanese Embassy or Consulate in Vietnam, not an apostille. Because this status is actively changing, Aplash recommends confirming the current authentication requirement directly with the Japanese Embassy or Consulate before finalizing any ACP appointment documentation, rather than relying on either the pre-accession or post-accession assumption by default.
JCT Recovery Under the ACP Route
Recovering Japan consumption tax (JCT) paid at import follows the same framework covered across our ACP country guides, at the framework level rather than a fixed price point. The non-resident Vietnamese manufacturer, having appointed an ACP agent under Article 95, separately appoints a Tax Agent (納税管理人) to handle its Japan tax filings, and registers as a Qualified Invoice Issuer (適格請求書発行事業者) if it intends to issue qualified invoices for downstream Japan sales. Import JCT paid at clearance becomes creditable against output JCT once this structure, ACP agent, Tax Agent, and Qualified Invoice Issuer registration, is in place. The consumption tax return itself is filed by a licensed tax accountant (税理士); the underlying agent appointments and registrations do not require a tax accountant's license to establish.
Conclusion
For a Vietnamese manufacturer that already meets Japan Customs' disposition-rights standard for the importer of record, ACP is the structure that lets it claim that role directly, in its own name, while capturing CPTPP or RCEP preferential treatment under its own origin documentation rather than an intermediary's. The mechanism itself, Article 95 of the Customs Act, is identical to the framework applied for manufacturers in other jurisdictions. What differs for Vietnam specifically is the document-authentication path, which is in transition and should be confirmed against current embassy or consular guidance before an ACP appointment is finalized.
This article is informational only and does not constitute legal, tax, or regulatory advice. Vietnam's document authentication requirements are subject to change during its Apostille Convention transition; confirm current requirements with the Japanese Embassy or Consulate before acting on this content. Consult a qualified advisor before acting on the content. Last updated: 2026-07.