The EU-Japan Economic Partnership Agreement (commonly known as JEEPA) eliminated or significantly reduced import tariff rates on a wide range of European manufactured goods entering Japan. European manufacturers who ship to Japan can claim these preferential rates rather than paying standard Most-Favoured-Nation (MFN) rates, and for high-value goods the savings are material. The structural challenge is that without a Japan office or subsidiary, European manufacturers cannot directly file the import declaration (輸入申告) in Japan. This post explains how the Attorney for Customs Procedures (税関事務管理人) appointment under the Customs Act (関税法) solves that problem, how it interacts with EU-Japan EPA preference claims, and when the simpler Importer of Record structure is the better fit.
The EU-Japan EPA Opportunity
JEEPA entered into force in February 2019 and has been progressively reducing or eliminating tariffs across a broad range of product categories. European manufacturers of machinery, precision instruments, automotive parts, luxury consumer goods, chemicals, and processed food products are among those who benefit. The applicable rate on a qualifying JEEPA shipment appears on Japan's EPA tariff schedule rather than the standard customs tariff table.
The savings are only realised if the EPA preference is correctly claimed at import. A preference claim requires the right documentation, must be declared on the import declaration at the time of clearance, and must be supported by proof of origin issued or prepared in the EU before goods ship. If the preference is not claimed at the time of import, recovering it retroactively involves a separate application process and is not guaranteed.
The first question for any European manufacturer is therefore not simply "do our goods qualify?" but "who will file the import declaration in Japan, and how will the preference be claimed on it?"
Two Structures for European Manufacturers Without a Japan Entity
European manufacturers who have no Japan-registered office or subsidiary cannot directly file a Japan import declaration in their own name. Two distinct legal structures address this situation. They are structurally different and are never interchangeable.
**IOR (Aplash as Importer of Record)**
Under the Importer of Record structure, Aplash purchases the goods from the European manufacturer and clears them through Japan Customs in Aplash's own name. Aplash is the named importer on the import declaration. Aplash can claim EPA tariff preferences on qualifying shipments, because Aplash is the importer of record and controls the declaration.
The tariff savings flow through Aplash's cost structure, not directly to the European manufacturer. In practice, the benefit passes through the commercial price at which Aplash resells the goods onward to the Japan buyer. This structure is administratively simple for the European manufacturer: no Japan customs registration is required, and no ongoing compliance obligations arise on the European side. The manufacturer ships to Aplash; Aplash handles everything in Japan.
IOR is the right structure when the European manufacturer wants no Japan customs identity, ships at low frequency or low value, or whose distribution arrangement places import responsibility on the Japan distributor rather than the manufacturer.
**ACP (European Manufacturer as Importer via Attorney for Customs Procedures)**
Under the Attorney for Customs Procedures structure, the European manufacturer is the named importer on the Japan import declaration. The manufacturer appoints Aplash as its Japan-resident agent, the 税関事務管理人, under Article 95 of the Customs Act (関税法). Aplash acts as the procedural agent before Japan Customs on the manufacturer's behalf; the manufacturer holds the legal import identity.
Because the manufacturer is the named importer, the manufacturer claims EPA tariff preferences directly on its own import declaration. The tariff savings belong to the manufacturer, not to an intermediary. JCT (consumption tax / 消費税) recovery is also available under this structure, with the correct registrations in place.
This structure requires ACP registration with Japan Customs before the first shipment. It adds ongoing compliance obligations on the manufacturer's side, but for manufacturers who ship regularly to Japan in their own name, it gives them full visibility into their landed costs and direct ownership of the duty and tax recovery position.
ACP is available only to non-residents of Japan. A European manufacturer with no Japan address, residence, or office qualifies. If the manufacturer has an incorporated Japan entity, it is its own importer and engages a licensed customs broker (通関業者) directly; neither ACP nor IOR from Aplash applies.
These two structures serve different commercial needs. A manufacturer's choice between them depends on the distribution agreement, the manufacturer's tax recovery goals, its compliance posture, and its strategic trajectory in Japan.
EPA Origin Documentation Under ACP
When the European manufacturer claims EPA preferences as the named importer, Japan Customs requires proof of origin. The EU-Japan EPA provides three accepted methods:
(a) A movement certificate EUR.1 issued by a European Union customs authority. The exporting party applies for this document from the customs office in the EU member state of export. EUR.1 certificates are standard for commercial shipments where the exporter does not hold approved exporter status.
(b) A statement on origin prepared by an approved exporter. EU member states designate approved exporters who may make out a statement on origin on any commercial document for shipments of any value. The statement text follows the format prescribed in the EU-Japan EPA; the exporter's approved exporter number is included.
(c) A statement on origin by any exporter for shipments valued at or below EUR 6,000. For lower-value consignments, any exporter may prepare the statement without approved exporter status.
The origin document must be presented at Japan Customs alongside the import declaration. It must exist before goods ship; it cannot be reconstructed after clearance. European manufacturers who have not previously exported under EPA preference should confirm which method applies to their situation before the first shipment, because the format and issuing process differ across the three methods.
Rules of origin must also be satisfied. Not every European product qualifies simply because it was manufactured in the EU. The goods must meet the product-specific rules of origin defined in the EU-Japan EPA, which prescribe criteria such as substantial transformation, value-added thresholds, or tariff heading change requirements depending on the product category. Verifying rules of origin eligibility is a prerequisite step, not a formality.
ACP and EPA Preferences Are Compatible
A question that arises regularly is whether ACP registration and EPA preference claims can be used together. They are fully compatible. They address different questions.
ACP under Article 95 of the Customs Act (関税法) addresses the procedural question: who handles customs administration on behalf of a non-resident importer? It designates Aplash as the resident agent so that Japan Customs has a local point of contact and the manufacturer can lawfully be named as the importer of record without having a Japan presence.
EPA preference addresses the tariff rate question: at what rate are the goods assessed? This is determined by the goods' origin and the applicable trade agreement, not by the importer's residency status or the procedural agent arrangement.
A European manufacturer can hold ACP status (with Aplash appointed as its 税関事務管理人), file import declarations in its own name, and simultaneously claim EPA tariff preferences on each qualifying shipment. The two mechanisms operate on separate legal tracks and do not constrain each other.
JCT Recovery for European Manufacturers Under ACP
Under the ACP structure, the European manufacturer is the importer of record and pays consumption tax (消費税) at the Japan border as part of import clearance. With the correct registration chain in place, that tax is recoverable.
Three registrations are required:
(a) ACP appointment with Japan Customs: the 税関事務管理人届出書 filed by Aplash on the manufacturer's behalf, which establishes the manufacturer as the named importer.
(b) Consumption Tax Payment Administrator appointment with the National Tax Agency (国税庁): the manufacturer appoints a Japan-resident party as its 消費税の納税管理人. Aplash can serve in this role. This registration gives the manufacturer a tax-side presence in Japan and enables filing of consumption tax returns.
(c) Qualified Invoice System (インボイス制度) registration: the manufacturer registers as a qualified invoice issuer. This registration enables the manufacturer to issue and receive qualified invoices (適格請求書), and the import consumption tax paid at the border becomes creditable against the manufacturer's output tax obligations on Japan sales.
With all three registrations in place, import consumption tax is not a permanent cost. It flows through the manufacturer's Japan tax position and is offset against output tax.
For European manufactured goods in categories such as industrial machinery, precision instruments, or high-value consumer products, the combination of EPA duty reduction and JCT recovery can produce a significant improvement in Japan landed cost compared to importing on MFN rates without tax recovery.
When to Use IOR Instead of ACP
ACP is not always the right structure. European manufacturers should consider IOR when:
The manufacturer wants no Japan customs identity at all and prefers to keep the import process entirely off its own compliance register. The manufacturer ships at low frequency or low value and the registration overhead of ACP is disproportionate to the benefit. The distribution agreement with the Japan buyer places import responsibility on the buyer or a Japan-side distributor, making it commercially simpler for Aplash or the distributor to be the importer of record. The manufacturer's legal or treasury team is not ready to establish and maintain Japan tax registrations.
ACP adds registration steps and ongoing compliance obligations: the 税関事務管理人届出書 must precede any filing, the tax registrations require ongoing maintenance, and if the manufacturer later establishes a Japan entity, the ACP relationship must be re-evaluated. IOR is administratively simpler at the cost of the manufacturer not appearing on the declaration and the EPA preference flowing through Aplash's books rather than the manufacturer's own.
Common Mistakes to Avoid
Assuming EPA eligibility without checking rules of origin. Not all European goods qualify for JEEPA preference. The product-specific rules of origin must be satisfied, and this requires product-level analysis before the first shipment, not after clearance.
Preparing origin documentation in the wrong format. EUR.1 certificates must be issued by the relevant EU customs authority and follow the prescribed format. Statements on origin have specified wording under the EU-Japan EPA. Submitting documentation that does not conform to the agreement's requirements will result in the preference claim being rejected.
Attempting to ship under ACP before the appointment is on file. The 税関事務管理人届出書 cannot be filed retroactively. Any shipment filed before the ACP appointment is registered with Japan Customs will be declared under a different importer identity, creating a gap in the manufacturer's import record and potentially triggering customs queries.
Omitting one of the three JCT registration steps. Without all three registrations (ACP appointment, 消費税の納税管理人 designation, and Qualified Invoice System / インボイス制度 registration), import consumption tax is an unrecoverable cost.
Timeline: What to Allow
ACP registration with Japan Customs typically takes 2 to 4 weeks from the time the completed 税関事務管理人届出書 is filed. EU origin documentation must be prepared in Europe before goods ship; EUR.1 certificates require an application to the relevant EU customs authority, and approved exporter statements require the exporter to hold approved exporter status in advance.
From engagement start to first compliant EPA-claiming shipment under ACP, European manufacturers should allow 6 to 8 weeks. This window covers the ACP appointment filing, origin documentation preparation, initial HS classification review to confirm EPA eligibility, and any JCT registration steps the manufacturer wishes to initiate in parallel.
Manufacturers with existing JEEPA export experience who already hold approved exporter status and have confirmed HS codes may be able to compress the timeline on the origin documentation side, but the Japan ACP registration lead time remains the binding constraint.
This article is informational only and does not constitute legal, customs, or tax advice. EU-Japan EPA rules of origin and Japan customs procedures are subject to change. Consult a qualified advisor before acting on the content. Last updated: June 2026.