Yes. Under a Client-Named-Exporter EOR structure, your company, or a named non-resident principal, stays the named exporter on the export declaration (輸出申告), and Aplash coordinates the filing as procedural agent only. This is different from Buy-and-Sell EOR, where Aplash itself takes title to the goods and becomes the named exporter. The two structures price on entirely different logic because the underlying liability differs.
What Is Client-Named-Exporter EOR?
Client-Named-Exporter EOR is the structure where your own company's name, or that of a named non-resident principal, appears as exporter on the Japan export declaration, while Aplash handles the customs-side coordination without ever taking title to the goods. This role is granted directly under Aplash's IOR/EOR service agreement and applies only to the export declaration itself. Aplash does not buy, sell, invoice for, or hold title to the exported goods at any point in this structure.
Because Aplash carries no title and no named-exporter liability in this shape, the engagement is priced flat per declaration rather than scaled to cargo value. This is a different EOR from Employer of Record labor compliance in Japan, which addresses employment structuring, not customs declarations; the two share an acronym and nothing else. If you are researching whether a non-resident seller can stay named on the paperwork versus handing that role to a Japan-based principal, see also IOR versus ACP, which structure applies for the equivalent decision on the import side.
Is Client-Named-Exporter EOR the Same as an Article 95 Customs Agent Appointment?
No. Client-Named-Exporter EOR is granted under Aplash's own IOR/EOR service agreement and covers the export declaration only. It is a separate arrangement from the Attorney for Customs Procedures (税関事務管理人) role under Article 95 of the Customs Act (関税法第95条), which Aplash provides for a non-resident importer on an import declaration.
The two roles sit on different sides of the transaction and under different Aplash agreements. Where a non-resident client needs to remain the named party on both legs of a movement, the import side runs through the Attorney for Customs Procedures appointment where applicable, and the export side runs through Client-Named-Exporter EOR under the separate service agreement. Treat them as two distinct engagements with two distinct scopes rather than one label applied to both directions.
How Does Client-Named-Exporter EOR Differ From Buy-and-Sell EOR?
The two structures differ on who is named as exporter, who carries title, and how the fee is calculated. Both key off exposure under the Foreign Exchange and Foreign Trade Act (外為法) on controlled exports, but the pricing model each uses reflects a different risk profile entirely.
Key points:
(a) Named exporter and title. In Client-Named-Exporter EOR, the client or a named non-resident principal is the exporter of record and holds title throughout; Aplash never takes title and acts only as procedural coordinator on the export declaration. In Buy-and-Sell EOR, Aplash takes title to the goods and becomes the named exporter itself.
(b) Liability carried. Buy-and-sell EOR carries a criminal-liability tail specific to being the named exporter of an unlicensed controlled export, because that liability attaches to whoever is named on the declaration. Client-Named-Exporter EOR does not carry that exposure for Aplash, because Aplash is never the named party.
(c) Pricing model. Client-Named-Exporter EOR is flat-fee per declaration, because the coordination work does not scale with cargo value. Buy-and-sell EOR is priced on a base fee plus a five-band degressive percentage of the FOB export declaration value (輸出申告価格), capped, because title-holding and named-exporter exposure scale with the value of the goods.
How Much Does Client-Named-Exporter EOR Cost?
A standard Client-Named-Exporter export declaration runs a flat fee per declaration, with a distinct, higher flat fee tier where the export requires a METI export licence under controlled or FEFTA-restricted categories. Neither figure moves with the FOB value of the shipment, which is the structural point of this pricing model.
Buy-and-Sell EOR runs on the opposite logic: a base fee plus an ad valorem percentage of FOB value that steps down across five bands as value increases, with the percentage rate itself rising by tier (standard, complex, controlled) and a cap on the total ad valorem component. In both structures, the fee prices title-holding and named-exporter liability only. FEFTA screening, METI export licence application work, and end-user screening are separate line items in either structure, never folded into the base or ad valorem figure.
What Happens on Re-Export Under Temporary Admission?
Where the export leg is the re-export half of a Temporary Admission movement, meaning goods brought into Japan temporarily and later sent back out, it prices as a flat re-export fee rather than a fresh full export declaration. The re-export pairs with the earlier import leg on the same goods, because that import leg already carried the relevant customs review; charging a full ad valorem export fee on the same goods a second time would be double pricing the same exposure.
For a non-resident bringing goods into Japan temporarily and later re-exporting them, the import leg is often the one that requires a non-resident importer to be named on the import declaration, which is the Attorney for Customs Procedures scenario referenced above. If your movement is a trade show or exhibition shipment, see the Japan trade show and exhibition import guide covering temporary admission and ATA carnets for how the import leg and carnet mechanics work before the re-export leg comes into play.
Frequently Asked Questions
Can a non-resident company keep its own name on a Japan export declaration without setting up a Japan entity?
Under a Client-Named-Exporter EOR engagement, the client or a named non-resident principal remains the named exporter on the export declaration while Aplash coordinates the filing as procedural agent. This is a structural role granted under Aplash's own service agreement covering the export declaration; it is not a statement that any non-resident automatically qualifies for the role in every case, and the specific facts of a shipment should be confirmed before filing.
Is Client-Named-Exporter EOR cheaper than Buy-and-Sell EOR?
It depends on the value of the shipment. Client-Named-Exporter EOR is flat-fee per declaration regardless of cargo value, which is typically the lower-cost option for higher-value shipments, while Buy-and-Sell EOR's ad valorem component scales with FOB value and reflects the criminal-liability tail Aplash carries as the named exporter taking title. For a low-value shipment the two can land close together; for a high-value shipment the flat fee structure is materially lower because it is not tied to cargo value at all.
Does Client-Named-Exporter EOR cover the METI export licence application itself?
No. The Client-Named-Exporter EOR fee, in either the standard or the controlled/FEFTA-licensed tier, prices the coordination of the export declaration only. A METI export licence application, FEFTA screening, and end-user screening are separate, distinctly quoted line items regardless of which EOR structure applies, and the controlled/FEFTA-licensed declaration tier reflects the added declaration complexity, not the licensing work itself.
Conclusion
Client-Named-Exporter EOR and Buy-and-Sell EOR answer the same question, who is named as exporter, with opposite structures and opposite pricing logic. Choosing between them starts with whether your company can and should remain the named party on the export declaration, or whether Aplash taking title and the associated liability is the better fit for the shipment. Either way, the export leg of a temporary admission movement is priced as a flat re-export fee tied to the paired import leg, not as a fresh declaration.
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: September 2026.