Neither Amazon nor Rakuten will act as your Importer of Record, so a non-resident seller shipping inventory to an FBA or Rakuten warehouse needs one of two customs structures: an Importer of Record (IOR) who takes title and imports as principal, or an Attorney for Customs Procedures (ACP, 税関事務管理人) who keeps you as the named importer while handling the filing. Which one fits depends on whether you want a third party to hold title, not on cost alone.
Why Can't Amazon or Rakuten Be Your Importer of Record?#
Amazon's own Seller Central guidance states plainly that neither Amazon nor its Japan entities may act as the importer or customs agent on a seller's shipment. A marketplace platform, a freight forwarder, and a licensed customs broker (通関業者) each play a defined role in getting goods to a warehouse, but none of them satisfies the Customs Act (関税法) requirement that whoever appears on the import declaration (輸入申告) hold actual disposition authority (処分権限) over the goods, under Article 67. A platform that only stores and fulfills orders never holds that authority. Ship inventory to an FBA or Rakuten warehouse with no importer named who meets that test, and the shipment sits held at customs until one is supplied.
Importer of Record (IOR): Aplash Takes Title and Imports as Principal#
Under an IOR structure, Aplash purchases the goods from the overseas seller, takes title before the import declaration is filed, clears customs in its own name, and re-sells to the seller or to the seller's nominated recipient. Aplash appears on the declaration because it is, in substance, the buyer of record, bearing commercial risk and holding title rather than acting as anyone's agent. This fits a seller that wants a third party to carry importer liability and the associated compliance exposure, or one whose home structure makes it awkward to be named on a foreign customs filing. See the full comparison in our IOR versus ACP guide.
Attorney for Customs Procedures (ACP): You Remain the Importer, Aplash Files for You#
Under ACP, the non-resident seller stays the legal importer named on the declaration, and Aplash is appointed under Customs Act (関税法) Article 95 as the Japan-resident agent who files the procedural paperwork. Title never transfers to Aplash. This structure is available only while the seller has no Japan address, residence, or office, and it is the more commonly used route for a seller running quarterly or periodic FBA shipments who wants to keep the JCT input-credit chain in its own name (see below) rather than hand importer status to a third party. Our ACP registration guide covers the setup sequence and timeline.
IOR and ACP are never interchangeable and never presented as alternatives in the same breath. Each is a distinct legal structure with its own party named on the declaration, its own liability profile, and its own tax recovery path; the choice turns on whether the seller wants to remain the importer, not on which sounds simpler.
How Is Customs Value Calculated When You Ship to Your Own FBA Warehouse?#
Neither structure changes how customs value is calculated: that question turns on whether there is a sale at the moment of import, not on who is named as importer. A standard import has a buyer and seller agreeing a price, so the Customs Tariff Act (関税定率法) Article 4 transaction-value method applies directly. An FBA or Rakuten inbound shipment has no sale at that point, since the seller is shipping its own inventory to its own warehouse and a customer has not yet bought anything, so transaction value cannot apply. Japan Customs instead works down the Article 4 valuation hierarchy to the deductive value method (控除方式, Article 4-3): starting from the eventual domestic selling price and subtracting the platform's commission and fulfillment fees, import duties and JCT already paid, domestic transport after arrival, and a reasonable profit margin, to arrive at a defensible customs declaration value. There is no generic percentage-of-retail figure that applies across sellers; the deductive calculation depends on each seller's own fee structure and margin, and it should be documented and kept on file before the first shipment, since Japan Customs can request the methodology during a post-clearance audit covering up to five years of import history. For the full valuation hierarchy and audit exposure, see our customs valuation guide.
What Changes Under Japan's 2028 Platform Taxation Reform?#
A reform already enacted shifts JCT liability onto large marketplace platforms rather than individual sellers, phased in two stages. Phase 1, in effect since April 2025, made digital-service platforms above a JPY 5 billion facilitated-transaction threshold the JCT taxpayer in place of the underlying foreign supplier, covering app stores and similar digital services. Phase 2, effective April 1, 2028, extends the same "deemed supplier" mechanism to Type 2 Platform Operators (第2種プラットフォーム事業者) facilitating cross-border B2C physical goods sales above a combined JPY 5 billion threshold, and removes the separate low-value-goods exemption for shipments valued at JPY 10,000 or less. Until the 2028 effective date, an individual FBA or Rakuten seller above the JPY 10,000,000 taxable-sales threshold remains directly responsible for its own JCT registration and filing; the platform does not yet file on the seller's behalf for physical-goods sales.
Recovering Import JCT Under Each Structure#
Import JCT paid at clearance is only recoverable if the credit chain is set up correctly, and the mechanics differ by structure:
(a) Under ACP, the non-resident seller is the importer of record, so it appoints Aplash as its Attorney for Customs Procedures (税関事務管理人) under Article 95, separately appoints Aplash (or another Japan-resident) as 消費税の納税管理人 (JCT tax agent) under the National Tax General Act, and registers as a Qualified Invoice Issuer (適格請求書発行事業者) once its Japan taxable sales cross the JPY 10,000,000 base-period threshold or it needs to issue qualified invoices to Japan B2B customers. Import JCT paid at clearance is then creditable against the JCT collected on domestic Amazon or Rakuten sales, filed under the seller's own registration.
(b) Under IOR, Aplash is the importer and JCT payer of record on that shipment, so the credit chain runs through Aplash's own registration rather than the seller's; the commercial arrangement between Aplash and the seller determines how that cost is passed through in the resale price.
(c) Skipping any step in the ACP path (the Article 95 appointment, the tax-agent appointment, or Qualified Invoice registration) leaves import JCT as an unrecoverable cost rather than a creditable one, regardless of which customs structure is chosen.
Common Mistakes Non-Resident Sellers Make#
The most frequent and most costly error is naming Amazon, Amazon Japan G.K., or a freight forwarder as the importer or consignee on the commercial invoice, packing list, or airway bill; customs rejects or holds the shipment because none of them can lawfully hold that role. A second common mistake is shipping the first FBA inventory batch before the ACP appointment or IOR arrangement is on record with Customs, which stalls the shipment in bonded storage while fees accumulate. A third is applying the deductive valuation method without a documented, contemporaneous calculation methodology, which is exactly the gap a post-clearance audit is built to find. Full company-formation alternatives for sellers who outgrow the non-resident structure are covered in our company setup guide.
Frequently Asked Questions#
Can I use ACP to sell on Amazon Japan without a Japan entity?
Yes, as long as you remain a non-resident with no Japan address, residence, or office. Aplash is appointed under Customs Act (関税法) Article 95 as your Japan-resident agent for customs procedures, and you remain the importer named on the declaration throughout.
Do I need a different customs structure for Rakuten than for Amazon Japan?
No. The IOR and ACP structures, and the deductive valuation method for self-storage inventory, apply the same way regardless of which Japan marketplace receives the goods. The practical difference between the two platforms is in fulfillment and seller-support infrastructure, not in the customs or tax structure required to import.
Will the 2028 platform taxation reform mean I no longer need to register for JCT myself?
Not for a typical FBA or Rakuten physical-goods seller before April 1, 2028, and even after that date the reform only shifts JCT liability to the platform for operators that themselves cross the JPY 5 billion combined threshold. Until your registered platform meets that threshold and takes on deemed-supplier status for physical goods, you remain responsible for your own JCT registration and filing once your taxable sales cross JPY 10,000,000.
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.