China is Japan's largest import source by volume. The customs arrangements that historically governed the China-Japan trade flow were built around a model that the October 2023 Japan Customs clarification has since made non-compliant in the majority of standard supply chain configurations. Chinese manufacturers who are not aware of that change, or who are relying on their Japanese trade partner's assurances that the old arrangement still works, are importing under a customs structure that creates declaration risk and permanently destroys the consumption tax (消費税) recovery their Japan sales should generate.
This article is written for Chinese manufacturers exporting to Japan: companies that produce and sell goods to Japanese buyers and want to understand their options for managing the Japan import declaration correctly. The Attorney for Customs Procedures (税関事務管理人) structure is the mechanism that enables a non-resident manufacturer to be named as importer of record (輸入者) on Japan customs declarations without a Japan entity. This article explains what that structure is, why Chinese manufacturers have strong commercial reasons to use it, what the setup process involves, and the Japan-specific customs valuation issues most commonly encountered in China-Japan trade flows.
Why Chinese Manufacturers Are Affected by the October 2023 Reform
The October 2023 Japan Customs clarification introduced a stricter standard for who qualifies as the importer of record (輸入者) on a Japan import declaration (輸入申告). The standard now requires the named importer to hold genuine disposition rights (処分権限) over the goods: the legal authority to decide what happens to the goods after customs clearance, including who they are sold to, at what price, and through which channels.
Before 2023, it was standard practice for Chinese manufacturers to ship goods to Japan under arrangements where the Japanese logistics company, freight forwarder, trading company (商社), or distributor was named as the formal importer on the customs declaration, even when the Chinese manufacturer retained commercial control over the goods. This was operationally convenient. The Japanese party handled the declaration paperwork. The Chinese manufacturer delivered the goods and collected payment. The customs compliance question received little attention.
The 2023 clarification ends the permissibility of this arrangement in the most common versions of it. Where the Chinese manufacturer sets the sale price to the end Japanese buyer, retains title to the goods during the clearance process, or directs how and to whom the goods are distributed after clearance, the manufacturer holds disposition rights and should be named as importer. A Japanese party that is merely facilitating the clearance without independent commercial control over the goods does not qualify as the importer.
The consequence of continuing under a non-compliant arrangement is exposure under the Customs Act (関税法) for a false import declaration, which carries both criminal and administrative penalties. It also results in the permanent loss of import consumption tax deductibility, since only the party named as importer on the declaration can claim import consumption tax as an input tax credit.
The Two Compliant Structures for Chinese Manufacturers
A Chinese manufacturer exporting to Japan has two structurally distinct compliant options. These are not interchangeable; they have different implications for title, tax recovery, and ongoing obligations.
Option 1: The Japanese buyer as importer. If the Chinese manufacturer sells goods to a Japanese company that genuinely purchases them outright, takes title before declaration, and has full commercial freedom to resell, redistribute, or retain those goods independently, the Japanese company holds genuine disposition rights and qualifies as importer of record. This is a compliant arrangement under the post-2023 standard, provided the distribution agreement actually reflects a genuine buy-sell relationship rather than a consignment, agency, or logistics arrangement dressed up as a purchase.
For Chinese manufacturers whose Japan relationship is a genuine full buy-sell distribution relationship where the Japanese distributor takes title and bears commercial risk, Option 1 requires no change to the existing import structure. The assessment question is whether the distribution agreement, as actually structured, meets the disposition-rights standard. Many arrangements that look like buy-sell from the outside involve recourse provisions, price-protection commitments, stock-return rights, or direction from the Chinese manufacturer over resale pricing that undercut the distributor's genuine independence.
Option 2: Chinese manufacturer as importer via ACP. If the Chinese manufacturer's commercial arrangement with Japan does not involve a genuine buy-sell distributor, or if the manufacturer has commercial reasons to maintain its own importer identity in Japan, the Attorney for Customs Procedures (税関事務管理人) structure is the mechanism. Under the Customs Act (関税法) Article 95, a non-resident entity with no Japan address, office, or residence can be named as the importer of record on Japan customs declarations by appointing a Japan-resident agent as its Attorney for Customs Procedures. The attorney acts as the statutory contact point for Japan Customs, accepts service of notices, and coordinates the clearance process. Aplash provides this service.
The Chinese manufacturer is named on the import declaration (輸入申告) as the legal importer. The manufacturer pays customs duties and import consumption tax as the named importer. Title to the goods remains with the manufacturer throughout the clearance process. After clearance, the manufacturer sells or delivers the cleared goods to the Japan buyer per whatever commercial arrangement the parties have agreed.
Setup Process for a Chinese Manufacturer
Setting up the ACP structure requires three registrations with two separate Japanese authorities. All three must be in place before the first import declaration is filed under the manufacturer's name.
First registration: ACP Notification with Japan Customs. Aplash files the ACP notification (税関事務管理人届出書) with the relevant Japan Customs office, formally recording the appointment of Aplash as the Chinese manufacturer's Attorney for Customs Procedures. The notification names the non-resident importer (the Chinese manufacturer), identifies Aplash as the Japan-resident ACP agent, and specifies the customs office or offices where the manufacturer intends to file import declarations. Each port of entry requires a separate notification; a single filing covering one port does not extend to others.
Second registration: Tax Representative Appointment with the National Tax Agency. The Chinese manufacturer must appoint a Tax Representative (納税管理人) with the National Tax Agency (国税庁) under the Consumption Tax Act (消費税法). This registration establishes who Japan's tax authority can contact for consumption tax matters arising from the non-resident's import activity. In practice, Aplash typically serves as both ACP and Tax Representative for the same client, but the two appointments are legally distinct filings with different authorities.
Third registration: Qualified Invoice System Registration. The Chinese manufacturer must register 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) administered by the National Tax Agency. This registration is required to claim import consumption tax paid at clearance as an input tax credit and to issue compliant invoices to Japan buyers. The NTA's processing window for QIS applications runs approximately four to six weeks. QIS registration must be completed before the first shipment clears under the manufacturer's name; import consumption tax paid before QIS registration is complete cannot be credited retroactively.
The ACP notification and Tax Representative appointment can be processed in parallel. QIS registration is the critical-path item because of the NTA's processing time. The practical sequence is to initiate QIS registration at or before the engagement start, not after the ACP notification has been filed.
Document requirements for Chinese manufacturers. Chinese corporate documents require authentication for submission in Japan. The business license (营业执照) and any corporate authorization documents require apostille certification from Chinese authorities or authentication through the Chinese consulate or embassy in Japan, depending on what Japan Customs and the NTA require. Aplash coordinates the document authentication requirements at onboarding. Certified Japanese or English translations of Chinese-language corporate documents are also typically required. Allowing additional lead time for the document preparation and authentication step is advisable; incomplete or improperly authenticated documents are the most common cause of registration delays.
The total timeline from engagement to first compliant import declaration is typically six to eight weeks for Chinese manufacturers, slightly longer than for manufacturers in countries where corporate document authentication is straightforward.
Customs Valuation Issues in China-Japan Trade Flows
Customs valuation in China-Japan import transactions raises several issues that are more commonly encountered in this trade corridor than in others, both because of the volume and complexity of China-Japan supply chains and because Japan Customs has historically maintained active oversight of declared values in China-origin imports.
Related-party pricing. Many Chinese manufacturers export to Japan through related-party arrangements: a Chinese parent supplying a Japan subsidiary, a Chinese manufacturer selling to a Japan affiliate under the same holding structure, or a Chinese manufacturer-controlled trading entity selling to the Japan end buyer at transfer prices. Where the seller and buyer in the import transaction are related within the meaning of the Customs Act (関税法), Japan Customs requires the manufacturer to demonstrate that the relationship did not influence the declared price. The primary tests are whether the declared price is close to test values established through sales to unrelated Japan buyers, the deductive value method, or the computed value method. Related-party Chinese manufacturers should document the basis for their Japan transfer prices and be prepared to explain the pricing methodology to Japan Customs if asked.
Royalties and licence fees in the transaction value. Chinese manufacturers that pay royalties or licence fees to related or unrelated parties for technology, patents, brand use, or design rights associated with the goods being imported may have those payments added to the declared transaction value by Japan Customs if the royalties relate to the imported goods and are a condition of the sale. This is a common issue in electronics, consumer goods, and industrial equipment supply chains where Chinese manufacturers produce under licence from Japanese or Western IP holders.
Assists. Materials, tools, moulds, or designs provided by the Japan buyer to the Chinese manufacturer free of charge or at reduced cost for use in producing the imported goods are assists that Japan Customs may add to the transaction value. Chinese manufacturers working under OEM or ODM arrangements where the Japan buyer supplies tooling, moulds, or proprietary materials should assess whether an assist calculation is required before declaring the invoice price as the customs value.
Post-sale adjustments and rebates. Pricing arrangements in China-Japan trade that include volume rebates, year-end adjustments, or post-sale price corrections may affect the final customs value for affected shipments. Japan Customs takes the position that the customs value reflects the final price actually paid or payable, which may differ from the invoice price at the time of clearance if adjustments are made later.
None of these issues prevents the ACP structure from working. They are valuation-layer questions that exist regardless of which import structure is used. Under the ACP structure, where the Chinese manufacturer is the named importer, the manufacturer carries the valuation risk directly on the customs record. Engaging a licensed customs specialist (通関士) who understands China-Japan transfer pricing and the customs valuation rules for the relevant product category is advisable before the first shipment.
Consumption Tax Recovery: The Commercial Case for ACP
The financial justification for setting up and maintaining the ACP structure is consumption tax recovery. A Chinese manufacturer importing goods into Japan pays import consumption tax (輸入消費税) at 10% of the declared customs value plus duty. For a manufacturer exporting ¥500M of goods to Japan annually, that is ¥50M in consumption tax paid at the border each year.
Under an arrangement where a Japanese trading company or distributor is the named importer, the Japanese party pays and recovers the import consumption tax. The Chinese manufacturer receives only the invoice proceeds net of whatever margin the Japanese party takes. The Chinese manufacturer's consumption tax exposure is zero, but so is its recovery.
Under the ACP structure, the Chinese manufacturer is the named importer and pays import consumption tax directly. It can then recover that ¥50M as an input tax credit through its Japan consumption tax filing, offset against output consumption tax charged on Japan domestic sales (B2B invoices to Japanese buyers). At scale, the recovery is a significant cash flow item. The setup cost of the ACP, Tax Representative, and QIS registration is typically recovered within the first year of operation for manufacturers with meaningful Japan import volumes.
The break-even assessment is straightforward: if annual import consumption tax on Japan-bound shipments is material, and the Japan program is expected to be ongoing, the consumption tax recovery under ACP is commercially justified. If the Japan program involves one or two test shipments before a commercial commitment is made, starting with Aplash as IOR under a buy-sell arrangement (where Aplash handles all Japan-side compliance) is the lower-overhead first step.
What to Expect Once the Structure Is Operational
Once all three registrations are in place, the ongoing operational flow for each shipment is as follows.
The Chinese manufacturer's export documentation, including the commercial invoice, packing list, and bill of lading or airway bill, is prepared with the Chinese manufacturer named as the shipper and consignee information reflecting the Japan delivery destination. Aplash coordinates with the Japan customs broker (通関業者) to prepare and file the import declaration (輸入申告) in the Chinese manufacturer's name through NACCS (輸出入・港湾関連情報処理システム, the Nippon Automated Cargo and Port Consolidated System).
Customs duties and import consumption tax are assessed and paid. Aplash handles any Customs examination or documentation requests on the manufacturer's behalf as ACP. Upon clearance, the goods are released from bonded storage to the Japan buyer per the commercial arrangement between the manufacturer and the Japanese party.
Import consumption tax paid at each clearance is recorded and periodically credited against output consumption tax from domestic B2B sales in Japan, processed through the NTA via the Tax Representative. Aplash maintains the ACP notification record, manages any updates required for changes in corporate details, and provides ongoing customs administration throughout the engagement term.
This article is informational only and does not constitute legal, customs, or tax advice. Import requirements, customs valuation rules, and consumption tax procedures in Japan are subject to change. Before acting on the content of this article, consult a qualified licensed customs specialist (通関士), licensed tax accountant (税理士), or attorney (弁護士) with Japan import and China-Japan trade experience. Last updated: June 2026.