Use IOR when you want Aplash to take title to the goods and act as the importer itself. Use ACP when your own company stays the importer of record and Aplash acts only as your Japan-resident Attorney for Customs Procedures (税関事務管理人) under Article 95 of the Customs Act (関税法第95条). The choice decides who pays customs duty, who can recover Japan consumption tax (JCT), and whether extra registrations are needed before you can ship.
What Changed in the 2023 Customs Reform?#
Japan Customs clarified the definition of "importer" in October 2023. The operative concept: disposition rights (処分権限), the legal authority to decide what happens to goods after customs clearance. The entity that holds this authority is the importer of record (IOR).
This reform had one major consequence: nominee IOR arrangements (名義貸し), where a Japan-resident third party acts as the formal importer while actual economic ownership stays with a foreign entity, were prohibited in most cases.
The only compliant mechanisms for a non-resident to import into Japan are now:
- IOR by a Japan-resident entity that genuinely takes title and bears economic risk (the Aplash IOR service model)
- The non-resident as IOR, represented by an ACP (Attorney for Customs Procedures, 税関事務管理人 under 関税法第95条)
These are not interchangeable. They are structurally different legal arrangements. If your company already has a Japan address, residence, or office, neither the third-party nominee model nor ACP is available to you; see the document checklist for your first IOR or ACP shipment for what a compliant onboarding actually requires under either structure.
What Is IOR (Importer of Record) in Japan?#
Under the IOR service, Aplash is the importer. Aplash buys the goods from the overseas seller at an agreed commercial price, takes legal title, clears customs in Aplash's name as the Japan-resident importer, and re-sells the goods to the Japan buyer.
┌─────────────────┐ sells goods to ┌──────────────────┐ re-sells to ┌──────────────────┐
│ Overseas Seller │ ─────────────────→ │ Aplash (IOR) │ ──────────────→ │ Japan Buyer │
│ (Your Company) │ │ Japan-resident │ │ │
└─────────────────┘ └──────────────────┘ └──────────────────┘
│
Named on 輸入申告
Pays customs duty
Issues qualified invoice (QIS)
What Aplash Takes On
| Responsibility | Aplash |
|---|---|
| Named as importer on 輸入申告 | Yes |
| Pays customs duty at clearance | Yes |
| Issues Japan-qualified invoice (QIS) to buyer | Yes |
| Bears import tax liability | Yes |
| Legal title to goods during clearance | Yes |
Who This Is For
IOR (Aplash as importer) is appropriate when:
- You are an overseas manufacturer or seller supplying a Japan buyer without any Japan presence
- You do not intend to claim Japan JCT (consumption tax) input tax credits on the import
- You want a fully managed Japan import solution with no customs registration or filing on your part
- Your goods are commercial goods where you, as overseas seller, do not need to retain IOR status
A company running shipments through more than one Japanese port faces the same IOR structure at every port; see the multi-port IOR guide if that applies to your shipping pattern.
JCT Under the IOR Structure
Aplash, as the Japan-resident importer, pays import JCT (10%) at clearance and claims it as an input tax credit in Aplash's own JCT filing. Aplash charges domestic consumption tax to the Japan buyer on re-sale. The overseas seller (your company) receives the agreed purchase price with no Japan tax obligations.
What Is ACP (Attorney for Customs Procedures) in Japan?#
Under the ACP structure, your company is the importer. Your entity is named as the IOR on the import declaration (輸入申告) filed with Japan Customs. Because you are a non-resident, no Japan address, residence, or office, you cannot directly interact with Japan Customs.
Japan Customs Act Article 95 provides the mechanism: a Japan-resident entity acts as your Attorney for Customs Procedures (税関事務管理人), liaising with Customs on your behalf. Aplash fills this role. Recording that appointment with Japan Customs is itself a process with its own timeline; see how long an ACP appointment takes to record before assuming you can ship the day you sign an engagement.
┌────────────────────┐ appoints as ACP ┌────────────────────┐ files with ┌────────────────────┐
│ Non-Resident │ ─────────────────→ │ Aplash (ACP) │ ────────────→ │ Japan Customs │
│ Entity (IOR) │ │ 税関事務管理人 │ │ (税関) │
│ Named on 輸入申告 │ │ Japan-resident │ │ Processes │
│ Pays import tax │ │ procedural agent │ │ declaration │
└────────────────────┘ └────────────────────┘ └────────────────────┘
The non-resident prerequisite is strict: the client must have no address, residence, or office in Japan (関税法第95条). If your company has any Japan presence, even a registered branch, the ACP route is not available. You would file directly as a Japan-resident entity.
What Aplash Does Under ACP
| Role | Aplash |
|---|---|
| Named on 輸入申告 as importer | No: client is named |
| Acts as Japan-resident agent (税関事務管理人) | Yes |
| Liaises with Japan Customs on behalf of client | Yes |
| Files customs declarations through NACCS | Yes |
| Pays import duty | No: client pays via Aplash as agent |
JCT Under the ACP Structure: The Core Tax Advantage
When your entity is named as IOR, your entity paid import JCT (10%) at clearance. This creates the ability to recover that JCT, but doing so requires two additional registrations:
| Registration | Purpose | Timing |
|---|---|---|
| Tax Agent (納税管理人) | Japan-resident agent to receive NTA correspondence | Before first import |
| Qualified Invoice System (QIS / インボイス制度) | Enroll as consumption taxpayer to issue and claim JCT | Before first import |
The Tax Agent role is a separate national-tax appointment from the ACP customs appointment; see what a Tax Agent actually does and who can serve as one if you have not yet appointed one. Once both registrations are in place, your entity files a Japan JCT return, recovers the import JCT paid at clearance, and charges domestic JCT on Japan sales.
| Scenario | Import JCT (10%) | Japan Sales JCT | Net JCT Liability |
|---|---|---|---|
| ACP: Non-resident as IOR + QIS | Pay ¥10M | Collect ¥12M | Pay ¥2M only |
| Third-party IOR (prohibited model) | Third party pays ¥10M | You collect ¥12M | Lose ¥10M - no deduction |
Only the entity named on the 輸入申告 as IOR can claim import JCT as an input tax credit. If a third-party holds the IOR status, that deduction is permanently lost to you.
Who This Is For
ACP is appropriate when:
- Your company is the manufacturer or seller and you want to retain IOR status in Japan
- You will have ongoing recurring imports and want to recover import JCT via a Japan filing
- JCT recovery economics are material to your Japan business model
- Your company has no Japan address, residence, or office (hard prerequisite under 関税法第95条)
- You want direct control over customs declarations rather than delegating commercial title to an intermediary
How Do IOR and ACP Compare Side by Side?#
IOR and ACP differ on every dimension that determines cost, control, and tax recovery, summarized below.
| Dimension | IOR (Aplash as Importer) | ACP (Client as Importer, Aplash as Agent) |
|---|---|---|
| Who is named on 輸入申告 | Aplash | Client (non-resident) |
| Who pays customs duty | Aplash | Client (via Aplash as agent) |
| Client Japan presence required | No | No, and no Japan presence must exist |
| JCT deductibility for client | Not available: Aplash deducts | Available after QIS + Tax Agent setup |
| Additional registrations needed | None (Aplash already registered) | Tax Agent (納税管理人) + QIS registration |
| Legal title to goods | Aplash takes title | Client retains title throughout |
| Setup lead time | Short: faster for one-time imports | Medium: appointment plus registration lead time |
| Best fit | One-time or low-volume shipments | Recurring importers with JCT sensitivity |
Which Structure Should You Use? A Decision Tree#
Circumstances change: a client that starts on IOR and later wants JCT recovery, or an ACP client that opens a Japan branch mid-relationship, needs to re-evaluate structure. See the signals that mean it is time to switch between IOR and ACP for what typically triggers that reassessment.
What Does Each Structure Cost?#
IOR Service (Aplash as Importer)
IOR pricing runs on a base fee plus a degressive ad valorem component above a CIF threshold, banded by cargo tier. Indicative Type 2 direct-client figures:
| Cargo Tier | Base Fee | Ad Valorem Above Threshold | Ad Valorem Cap |
|---|---|---|---|
| Standard Goods (EAR99) | $2,500 | Degressive bands from 2.5% down to 0.13% of CIF, above $50,000 | $36,500 |
| Complex Goods | $5,000 | Degressive bands from 4.5% down to 0.25% of CIF, above $50,000 | $70,000 |
| Controlled / Dual-Use Goods | $12,500 | Degressive bands from 7.0% down to 0.33% of CIF, above $100,000 | $91,000 |
Customs duties and consumption tax are always passed through at cost, with no markup. Cargo below the stated CIF threshold pays the base fee only; the ad valorem component scales in with shipment value and is capped at high volumes so large cargo does not scale linearly.
ACP Service
ACP runs on a flat per-shipment or per-declaration basis rather than scaling with cargo value, reflecting that Aplash is a procedural agent rather than the title-holding importer:
| Service | Fee (Indicative) |
|---|---|
| Onboarding / Setup | $500 one-time |
| Per-shipment, standard commercial goods, statutory role only | $300 |
| Per-shipment, standard commercial goods, full customs clearance coordination | $1,200 |
| Additional Customs office setup | $300 per office |
Contact Aplash for current rates on multi-shipment packages, higher-complexity cargo categories, or your specific product mix; the figures above are the standard-tier starting points, not a full quote.
What Do People Get Wrong About IOR and ACP?#
"IOR and ACP are just two names for the same service." They are structurally different legal arrangements. IOR means Aplash is the importer. ACP means your company is the importer. Who is named as importer determines who pays duty, who holds title, and who can deduct JCT.
"I can use ACP even though my company has a Japan branch." No. 関税法第95条 requires the client to have no address, residence, or office in Japan. A branch office disqualifies you. You would file directly as your Japan branch.
"The third-party nominee IOR model still works." The October 2023 Japan Customs reform eliminated compliant use of nominee IOR structures in most cases. Arrangements where a Japan entity acts as formal importer without genuine disposition rights over the goods are no longer acceptable under the reformed definition.
"ACP is cheaper because Aplash is just filing paperwork." ACP setup requires two additional registrations (Tax Agent plus QIS), each with lead time and ongoing compliance obligations. The ongoing benefit, JCT recovery, is substantial for recurring importers. For one-time or low-volume shipments, IOR may be simpler overall.
Regulatory References#
| Law / Rule | Relevance |
|---|---|
| Customs Act Art. 95 (関税法第95条) | ACP legal basis: 税関事務管理人 appointment |
| Customs Act Art. 67 (関税法第67条) | Import declaration (輸入申告) requirements |
| Consumption Tax Act (消費税法) | JCT deductibility: IOR as named entity |
| Qualified Invoice System (インボイス制度) | Prerequisite for JCT recovery under ACP |
| October 2023 Japan Customs Circular | Disposition rights (処分権限) clarification: reformed IOR definition |
Official Sources#
| Source | Link |
|---|---|
| Japan Customs - ACP Leaflet (EN) | customs.go.jp |
| Customs Act (Article 95, EN) | japaneselawtranslation.go.jp |
| NTA - Qualified Invoice System | nta.go.jp |
| Japan Customs - Import Procedures | customs.go.jp/english |
Frequently Asked Questions#
Can I use IOR for some shipments and ACP for others?
Yes, if your company qualifies for both. The two structures are chosen per shipment or per engagement based on whether you want to retain importer status and recover JCT (ACP) or hand off importer status entirely (IOR). What you cannot do is use both structures for the same shipment: Aplash cannot simultaneously be the importer under IOR and the customs agent for a non-resident importer under ACP on one declaration.
What happens to my ACP appointment if I later open a Japan office?
The ACP structure stops being available. Article 95 of the Customs Act requires the client to have no address, residence, or office in Japan, so opening any Japan presence, including a branch, ends eligibility. At that point your entity files customs declarations directly as a Japan-resident importer, without an ACP appointment, or you evaluate IOR instead.
Do I need a customs broker in addition to IOR or Aplash's ACP full-service tier?
No, not separately. Aplash's IOR service and the ACP full-clearance tier both already include coordination with a partner licensed customs specialist (通関士) who prepares and files the actual import declaration. A separate customs broker relationship is only needed if you choose the ACP statutory-only tier, where you retain your own existing broker relationship and Aplash provides only the Article 95 agent appointment.
Conclusion#
IOR and ACP solve the same underlying problem, letting a non-resident company move goods into Japan without a Japan entity, through two structurally different legal arrangements. IOR trades JCT recovery for simplicity by making Aplash the importer; ACP trades additional registrations for JCT recovery by keeping your company as the importer. Confirm your Japan-presence status and JCT recovery priorities before choosing, since both determine which structure is even available to you.
This article is informational only and does not constitute legal, tax, or regulatory advice. Consult a certified customs specialist (通関士) or licensed attorney (弁護士) before acting on the content. Last updated: August 2026.