For goods you sell in Japan on consignment, either you as the overseas seller or your Japan-based selling party can be the import declarant, and Japan Customs has published both as acceptable routes. The deciding fact is not who holds the goods physically. It is who holds genuine authority to dispose of them, meaning the right to sell, redirect, recall, or reprice them, at the moment the import declaration is filed.
What Makes Consignment-Sale Imports Different From an Ordinary Purchase Import?
An ordinary import has a completed sale: a foreign supplier sells goods to a Japan buyer, and the buyer's purchase price is the customs value. A consignment-sale (委託販売) import has no completed sale at the point of entry. The overseas party still owns the goods, and a Japan-based party will sell them later, on the owner's behalf, for a commission or margin. Because the goods enter Japan before the sale that will eventually happen, Japan Customs cannot use the ordinary transaction-value method, and it also has to decide who is legally entitled to act as the importer for a shipment where the "buyer" does not yet exist.
Option 1: IOR, Where Aplash Buys the Goods Outright
The cleanest way to remove the ambiguity entirely is to convert the arrangement into a genuine sale before the goods reach Japan. Under Aplash's IOR service, Aplash purchases the goods from the overseas owner at a defensible transaction value and becomes the importer of record in its own right, then resells domestically as the consignment draw-downs happen. Once Aplash holds title, there is no consignment question left to answer for customs purposes, because an actual sale has occurred and Customs Tariff Act (関税定率法) Article 4 transaction value applies in the normal way. Our consignment and VMI structuring guide covers how the buy-and-resell mechanics work once IOR is in place.
Option 2: ACP, Where the Overseas Owner Stays the Importer
Japan Customs' own published case examples confirm that a non-resident consignor can remain the import declarant for consignment-sale goods, appointing a customs procedures agent (税関事務管理人 / ACP) under Customs Act (関税法) Article 95, rather than converting to a buy-sell structure. This route is conditioned on one fact: the non-resident owner must genuinely hold disposal authority (処分権限) over the goods at the moment of declaration. Title retention, the right to recall or redirect the shipment, control over pricing, and who bears the risk while the goods sit in Japan are the facts that establish this. A Japan-based party's day-to-day custody of the goods, or its role in physically arranging the sale on the shelf or the platform listing, does not by itself defeat the overseas owner's disposal authority.
Option 3: The Japan-Based Seller Files as Declarant Instead
Japan Customs' published guidance also names a second route that does not involve Aplash at all: the Japan-based party that will sell the goods in its own name can be the import declarant, on the basis that it is the one performing the act of import for the eventual sale. This route exists because some consignment structures genuinely do transfer enough control to the Japan-based seller that treating it as the importer reflects reality better than keeping the overseas owner on the declaration. It is a legal alternative worth knowing about, not a service Aplash provides, since it requires the client's own Japan entity or platform account to be the declarant of record.
How Do You Know Which Option Actually Fits Your Structure?
Look at where disposal authority actually sits, not at who is named in the consignment contract's introductory paragraph. If the overseas owner can recall unsold stock, dictate the resale price, or redirect goods to a different Japan buyer without the local party's consent, that points toward the ACP route. If the Japan-based party effectively controls what happens to the goods once they land, regardless of how the contract labels the arrangement, that points toward either the Japan-party-as-declarant route or, more cleanly, converting to IOR so the sale is real rather than characterized after the fact. A mismatch between the paperwork and the actual commercial control is exactly what a post-clearance audit is built to surface.
Key points:
(a) A completed sale is not required before goods enter Japan, but the customs declarant for a consignment-sale import must be either the disposal-authority-holding overseas owner (via ACP) or the Japan-based selling party, not whoever is simply named as consignee on the shipping documents.
(b) Disposal authority turns on title retention, recall and redirect rights, pricing control, and risk-bearing, not on which party physically holds or displays the goods in Japan.
(c) Converting to an IOR structure removes the consignment-declarant question entirely by making Aplash the actual buyer before the goods clear customs.
(d) A structure where the contract names one party as the seller of record while a different party actually controls the goods is the fact pattern a post-clearance audit is designed to catch.
For the broader distinction between a shipping "consignee" and the legal importer of record, which is a related but separate question from the consignment-sale declarant issue covered here, see our importer of record vs consignee guide.
Frequently Asked Questions
Can my company stay listed as the importer for goods a Japan retailer is selling on consignment for us?
Yes, provided your company genuinely retains disposal authority over the goods, meaning the right to recall, redirect, or reprice them, at the moment the import declaration is filed. You would appoint a customs procedures agent (税関事務管理人 / ACP) under Customs Act Article 95 rather than having the Japan retailer file as the importer.
Does the Japan retailer automatically become the importer just because it physically holds and sells the goods?
No. Physical custody and shelf-level selling activity are not by themselves the deciding facts. Japan Customs looks at who holds genuine authority to dispose of the goods, so an overseas owner that retains title, recall rights, and pricing control can remain the declarant even while a Japan-based party handles the actual retail sale.
What if we can't tell whether we or our Japan partner actually control the goods once they arrive?
That uncertainty is itself the reason to convert the arrangement to an IOR structure, where Aplash purchases the goods outright before they clear customs. That removes the disposal-authority question entirely, since an actual completed sale replaces the ambiguous consignment characterization.
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.