Yes. A non-resident company can be the named exporter on a Japan export declaration by appointing a Japan-resident customs procedure agent (税関事務管理人) under Article 95 of the Customs Act (関税法第95条). The non-resident stays the legal exporter throughout; a licensed customs broker (通関業者) physically files the declaration, because filing on someone else's behalf requires a customs brokerage license.
What Is a Customs Procedure Agent (税関事務管理人) Under Article 95?#
A customs procedure agent is a Japan-resident party a non-resident appoints to handle customs procedures on its behalf when the non-resident itself cannot maintain a standing presence before Japan Customs. Article 95 of the Customs Act (関税法第95条) sets out this consequence provision generally: a non-resident who must perform Japan customs procedures may appoint an agent, and the agent notification is filed on Customs Form C No. 7500 (税関様式C第7500号). That notification must be on record before the first export declaration; there is no retroactive fix once a shipment has already moved.
This structure is most commonly discussed on the import side, where a non-resident importer appoints an agent to remain the named importer on the import declaration. Our Exporter of Record (EOR) explainer and our IOR vs ACP comparison cover that import-side mechanics in depth. The export-side use of the same Article 95 appointment is a separate, less-discussed application of the same statute, and this post is scoped to that side only.
Who Actually Files the Export Declaration?#
The customs procedure agent does not file the export declaration. Only a licensed customs broker (通関業者), acting through its licensed customs specialist (通関士), may prepare and submit a declaration on a party's behalf, because that act is regulated separately under the Customs Brokerage Act (通関業法). An entity performing declaration filing without that license would be operating outside its registration.
This is a structural boundary, not a gap in service. The customs procedure agent's role is the standing appointment: it is the point of record Customs has on file for the non-resident principal, and it handles procedural correspondence and compliance oversight around the appointment. The actual mechanical act of submission on each shipment sits with the licensed broker's customs specialist, working from the exporter's shipment documentation. A reader evaluating this structure for a specific transaction should treat the two roles as always paired, never merged: one holds the standing appointment, the other executes the filing.
Does the Non-Resident Exporter Need a Japan Import/Export Code?#
A non-resident exporter without a Japan corporate number (法人番号) needs a customs-issued import/export code (税関発給輸出入者コード) before its first filing. Domestic filers typically identify themselves to Customs using their corporate number; a non-resident without one has no equivalent identifier on file, so Customs issues a dedicated code in its place. This is arranged as part of onboarding the customs procedure agent appointment, ahead of the first declaration, alongside the Form C No. 7500 notification.
Who Carries Export-Control Compliance Liability, the Exporter or the Agent?#
Export-control classification (該非判定) and any license obligation under the Foreign Exchange and Foreign Trade Act (外為法, FEFTA) belong to the named exporter, not the customs procedure agent. Article 70 of the Customs Act (関税法第70条) can require proof of compliance with other applicable laws at the point of export declaration, and that proof obligation runs to whoever is named as exporter. A customs procedure agent handles the procedural appointment and correspondence with Customs; it does not absorb or share that classification and licensing liability.
This allocation matters because it is the reason the structure works cleanly on the export side. A non-resident that takes on the named-exporter role is also taking on full responsibility for correctly determining whether its goods or transaction require an export license, and for holding one if they do. Nothing in this article determines whether any specific product or transaction requires a license; that determination depends on the goods, the end use, and the end user, and it has to be made on the facts of the actual shipment, not from a general framework description.
Key points:
(a) The non-resident stays the named exporter on the declaration; the customs procedure agent (税関事務管理人) is a procedural standing appointment under Customs Act Article 95 (関税法第95条), notified on Customs Form C No. 7500 (税関様式C第7500号) before the first filing.
(b) The declaration itself is filed by a licensed customs broker (通関業者) under the Customs Brokerage Act (通関業法); a customs procedure agent that filed declarations directly would need a brokerage license it does not hold.
(c) Export-control classification and any license obligation under FEFTA (外為法) stay with the named exporter; the agent does not carry that compliance liability, and Article 70 of the Customs Act (関税法第70条) can require the exporter to prove compliance at the point of declaration.
How Does This Differ From the Import-Side ACP Role?#
The two sides of the same Article 95 appointment behave differently because government enforcement priorities differ between import and export. On export, the named exporter carries compliance liability for license adherence and end-use control, so a non-resident holding that role directly, with an agent handling procedure, fits the regulatory design cleanly. On import, the concern is revenue collection and a clean chain of disposition authority, which is why the import-side use of the same appointment is far more constrained in practice.
We cover the import-side constraints, and the related question of when a client's own name rather than Aplash's should appear as exporter of record, in our Client-Named-Exporter EOR explainer. That post addresses a different structural question and should not be read as extending the export-side mechanism described here to the import side, or vice versa. A company evaluating either direction should confirm which side of the transaction it sits on before assuming either pattern applies.
Where a non-resident company has confirmed it needs a Japan-resident agent for its customs procedures, whether on the export or the import side, the appointment mechanics and required filings are set out on our customs procedure agent service page.
Frequently Asked Questions#
Can my company appoint a customs procedure agent and still be the exporter on the declaration?
Yes. Appointing a Japan-resident customs procedure agent under Customs Act Article 95 (関税法第95条) does not transfer exporter status. Your company remains the named exporter throughout; the agent's role is the standing appointment before Customs, not a substitution as exporter.
Does the customs procedure agent file my export declarations?
No. Filing an export declaration on behalf of another party requires a customs brokerage license under the Customs Brokerage Act (通関業法). A licensed customs broker's customs specialist (通関士) files the declaration; the customs procedure agent handles the standing appointment and procedural correspondence.
Who is responsible if an export license was required and wasn't obtained?
The named exporter carries that responsibility, not the customs procedure agent. Export-control classification and any license obligation under the Foreign Exchange and Foreign Trade Act (外為法) attach to the party named as exporter on the declaration, and Article 70 of the Customs Act (関税法第70条) can require proof of that compliance at the time of filing.
Conclusion#
A non-resident company does not need a Japan-resident entity acting as exporter to move goods out of Japan in its own name. Appointing a customs procedure agent under Customs Act Article 95, pairing that appointment with a licensed customs broker for the actual filing, and keeping export-control compliance liability where the law places it, with the named exporter, is a statutorily available and workable structure. Getting the roles right at setup avoids confusion later about who is answerable to Customs for what.
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.