A Peruvian manufacturer or exporter can hold the Japan importer position directly, without opening a Japan entity, by appointing a Japan-resident Attorney for Customs Procedures (税関事務管理人) under Article 95 of the Customs Act (関税法). Paired with the Japan-Peru Economic Partnership Agreement (日・ペルー経済連携協定), in force since March 2012, this lets a Peruvian exporter claim preferential tariff treatment on its own declaration, using either a government-issued certificate of origin or the agreement's self-certification option.
What Does ACP Actually Let a Peruvian Exporter Do?#
ACP lets a non-resident company be named as importer of record on a Japan customs declaration (輸入申告) without a Japan branch, subsidiary, or representative office. The non-resident remains the legal importer throughout; the Japan-resident agent, Aplash in this role, is the statutory contact point Japan Customs (税関) reaches for that appointment, and coordinates the declaration filing through a licensed customs specialist (通関士).
For a Peruvian manufacturer selling into Japan through an existing distributor, this matters because the distributor, not the manufacturer, is usually the one named as importer today. That means the distributor sets the declared customs value, controls how any tariff preference under the Japan-Peru EPA is documented, and is the party of record if Japan Customs raises a post-clearance inquiry. Appointing Aplash as ACP lets the manufacturer step into the importer position itself, see its own customs value, and capture the EPA preference directly on its own books instead of through whatever the distributor passes along in its resale pricing.
How Is the Japan-Peru EPA Different From Japan's Other Trade Agreements?#
The Japan-Peru EPA's most distinctive feature is that it lets an exporter choose between two proof-of-origin methods on the same shipment: the conventional certificate of origin issued by a designated third-party body, or a self-certification by the exporter itself under the agreement's approved-exporter mechanism. Most of Japan's other economic partnership agreements default to one method or the other, so an exporter used to a different Japan EPA should not assume the same documentation process applies here. The agreement entered into force in March 2012, per Japan's Ministry of Foreign Affairs; a secondary trade-compliance report puts the exact date at March 1, 2012, following an exchange of diplomatic notes dated January 24, 2012, though that specific day is as reported by that source and has not been confirmed against the primary exchange-of-notes text.
Self-certification removes a step that otherwise sits between the exporter and the preferential rate: no separate government or chamber-of-commerce office has to issue a paper certificate before the shipment moves. An exporter that qualifies as an approved exporter under the agreement's terms can generate its own origin declaration and attach it to the commercial documents. The tradeoff is that self-certification shifts more of the record-keeping and substantiation burden onto the exporter, since there is no third-party certificate standing behind the claim if Japan Customs later asks for support.
Certificates of origin under Japan's EPAs are generally treated as valid for twelve months from their date of issuance, a rule that applies across Japan's EPA framework and is not unique to the Peru agreement. That window matters for a manufacturer that batches shipments against a single certificate rather than documenting origin shipment by shipment; confirm the specific validity treatment that applies to the certificate or self-declaration actually used before relying on it past that window.
What Qualifies as Originating Under the Japan-Peru EPA?#
A good qualifies for the agreement's preferential tariff treatment if it is either wholly obtained in Peru or has undergone a qualifying production process there, as defined by the agreement's product-specific rules of origin for that good's tariff classification. Manufacture in Peru, by itself, does not automatically make a product originating; the applicable rule depends on the specific tariff heading, and some headings set a different test than others. This article states no numeric local-content percentage and no specific rule for any given HS heading, because the rule varies by product and an unverified figure creates real duty exposure on an actual declaration.
A Peruvian exporter should confirm the applicable rule for its own tariff classification against the treaty text and Japan Customs' published guidance before relying on it for a shipment, and should keep the underlying production and sourcing records that would substantiate an origin claim if Japan Customs asks for them later. That substantiation obligation sits with whichever party prepares the origin claim, which under this agreement's self-certification option can be the exporter itself rather than a third-party certifying body.
ACP or IOR: Which Structure Fits a Peruvian Exporter?#
ACP and Importer of Record (IOR) answer the same underlying problem, a non-resident company with no Japan customs identity, with two structurally separate instruments that are never interchangeable on the same shipment. Under ACP, the Peruvian company stays the legal importer and invokes the EPA preference on its own declaration; under IOR, Aplash purchases the goods from the Peruvian exporter and clears them in Aplash's own name, so it is Aplash, not the exporter, that is named importer and that would invoke the preference on that transaction.
A Peruvian manufacturer that wants to keep the customs value, the origin documentation, and the tariff-preference benefit on its own books should look at ACP. A Peruvian exporter that would rather not hold any Japan customs or tax identity at all, whether because shipment volume does not justify the registration overhead or because an existing distributor relationship works better left as-is, fits IOR better, with Aplash sitting in the import position instead. The two services run on different legal bases and are priced and contracted separately; see the IOR, EOR and ACP comparison guide for a fuller side-by-side, the ACP registration and setup guide for how the appointment itself gets filed once a structure is chosen, and the ACP service page for current scope and delivery detail.
What Does the ACP Setup Sequence Look Like?#
The ACP route runs through a fixed filing sequence rather than a single signature. Aplash first files the ACP Notification (税関事務管理人届出書) with the relevant Customs office, establishing the Peruvian company as the named importer for future declarations with Aplash as the statutory procedural contact. In parallel, Aplash can be appointed as the exporter's Tax Representative (納税管理人) with the National Tax Agency (国税庁), since consumption tax (消費税) liability on the exporter's imports begins the moment it becomes named importer, and separately pursue registration as a Qualified Invoice Issuer (適格請求書発行事業者) under Japan's Qualified Invoice System (インボイス制度), which is what lets the exporter credit import consumption tax against output tax on its own Japan B2B sales later.
None of these steps carries a fixed universal timeline; actual processing depends on document readiness, the product involved, and the relevant offices' current workload, and should be confirmed at the time of engagement. A shipment that clears before the Qualified Invoice Issuer registration is confirmed carries import consumption tax that cannot be recovered retroactively, which is usually the step that drives how fast a manufacturer wants the whole sequence to move. A manufacturer already comparing this to how the Chilean ACP structure or Canadian ACP structure works will recognize the shape: the appointment mechanics under the Customs Act are the same regardless of which trade agreement is doing the tariff work, and the Japan EPA and FTA preference utilization guide covers how origin documentation interacts with that appointment across Japan's various agreements.
Three points matter most for a Peruvian exporter weighing this structure:
(a) ACP keeps the Peruvian company as the named importer and the party that invokes the Japan-Peru EPA preference directly, while IOR shifts both the importer position and the preference claim to Aplash.
(b) The EPA's self-certification option can remove the third-party certificate step, but it shifts the substantiation burden for the origin claim onto the exporter, so internal production and sourcing records need to support that claim before it is used.
(c) Consumption tax recovery on an ACP-held import depends on two separate registrations, Tax Representative and Qualified Invoice Issuer, sitting alongside the ACP appointment itself, not on the appointment alone.
Frequently Asked Questions#
Does a Peruvian manufacturer need a Japan company to use ACP?
No. ACP exists specifically for a non-resident company with no Japan branch, subsidiary, or representative office. The Peruvian manufacturer appoints a Japan-resident agent, who becomes the statutory customs contact, while the manufacturer itself stays the named importer on the declaration and remains a non-resident throughout.
Can a Peruvian exporter self-certify origin for every shipment to Japan?
The Japan-Peru EPA allows an approved exporter to self-certify origin as an alternative to the conventional third-party-issued certificate, but qualifying as an approved exporter and substantiating the claim with supporting records is a separate step from choosing the method. An exporter should confirm its own eligibility for self-certification and the applicable rule of origin for its specific tariff classification before relying on either documentation path for a real shipment.
What happens to import consumption tax if a shipment clears before the tax registrations are in place?
Import consumption tax paid before the Tax Representative appointment and Qualified Invoice Issuer registration are both confirmed generally cannot be recovered retroactively. That is the main reason manufacturers moving to an ACP structure tend to sequence the tax registrations alongside, rather than after, the customs appointment itself.
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: November 2026.