Non-resident manufacturers who have decided they want to remain the named importer on their own Japan customs declarations, rather than handing that role to an Importer of Record, almost always ask the same follow-up question: what does an Attorney for Customs Procedures (ACP, 税関事務管理人) arrangement actually cost. The honest answer has more moving parts than a single number can carry. This post walks through the cost structure so you can budget accurately and ask a prospective provider the right questions, without repeating the mistake of comparing ACP and IOR (Importer of Record) fees as if they were priced on the same basis.
Why ACP Pricing Looks Different From IOR Pricing
ACP and IOR are not two tiers of the same service, so it should not be surprising that their cost structures diverge. Under ACP, your company remains the legal importer named on the import declaration; Aplash acts only as your Japan-resident procedural agent before Japan Customs under the Customs Act (関税法) provision that requires a non-resident importer to appoint a resident agent. Aplash never takes title to the goods, never advances customs duty or import consumption tax (輸入消費税, import JCT) on your behalf, and carries none of the importer liability that sits on an IOR provider. Because the risk profile is fundamentally lighter, the fee structure is built differently: ACP pricing tends toward flat, per-event charges rather than the value-scaled pricing that IOR uses to reflect title risk and capital advance. Treating the two as comparable "which is cheaper" line items without accounting for this difference produces a budget that misses the point of the comparison entirely.
The Cost Components of an ACP Engagement
Four distinct cost categories appear in a typical ACP engagement, and none of them should be assumed to be included in another.
(a) One-time onboarding and appointment setup. Before any shipment moves, the ACP appointment itself must be filed with the relevant Japan Customs office (税関事務管理人届出書), and your company's identity and the underlying transaction substance must be verified. This is a fixed, one-time cost per client relationship, independent of how many shipments follow.
(b) Per-shipment or per-declaration fees. ACP is priced as a flat per-event fee rather than scaled to cargo value, because Aplash is not advancing duty or JCT and is not bearing title risk on the goods. Within this category, providers typically distinguish between a narrower "statutory role only" scope, where your company already has its own customs broker (通関業者) relationship and only needs the ACP appointment itself, and a broader "full service" scope, where Aplash also coordinates the actual import declaration filing through a licensed customs specialist (通関士) partner. The full-service scope costs more because it bundles in the broker's own filing fee, which is a real third-party cost, not a markup.
(c) Retainer or package arrangements for recurring importers. A company that imports regularly, rather than as a one-off, typically moves to a package structure covering appointment maintenance, ongoing KYC continuity, and scheduled compliance review over a fixed term (commonly six months or a year), billed as a base fee plus the applicable per-shipment rate for each shipment that actually occurs. Ask directly whether a quoted package includes any shipments "for free": a base fee with no shipment allowance built in, and separate per-shipment billing for every declaration, is a materially different commitment than a package that bundles a set number of shipments into the base price, and the two should not be compared on the base fee alone.
(d) Additional-port and consumption-tax-recovery setup. If your imports clear through more than one Japan Customs office, each additional port requires its own separate appointment filing and its own fee, because the statutory appointment is filed office by office, not once nationally. Separately, if you intend to recover import JCT (see below), the registrations that make recovery possible carry their own one-time setup cost, distinct from the ACP appointment fee itself.
Ancillary Costs That Sit Outside the ACP Fee
Customs duty (関税) and import JCT are government-mandated amounts assessed on the goods themselves; no ACP provider prices or negotiates them, and they should never be counted as part of the ACP service fee in a budget. Customs broker filing costs, port handling charges, and freight are similarly separate line items that vary by shipment and logistics arrangement. A quote that appears unusually low relative to a competitor's is worth checking against what it actually includes; a "statutory role only" quote that excludes broker filing is not directly comparable to a "full service" quote that includes it.
The JCT Recovery Cost Most Companies Underestimate
Because your company remains the named importer under ACP, it also remains the party that paid import JCT at clearance, and it is the party positioned to recover it. Recovery is not automatic on the ACP appointment alone. It requires two further registrations: appointing a Japan-resident tax agent (消費税の納税管理人) to receive correspondence from Japan's National Tax Agency, and registering as a Qualified Invoice Issuer (適格請求書発行事業者) if your company sells to Japan business buyers. Each carries its own one-time setup cost, and the ongoing consumption tax return filing itself is work performed by a licensed tax accountant (税理士), typically billed as a separate, itemized pass-through rather than folded into the ACP fee. Skipping this step to save the setup cost is usually a false economy: without the tax agent and invoice registrations in place, the import JCT your company pays at the border becomes a permanent, unrecoverable cost rather than a recoverable credit, and the amount forfeited is almost always larger than the setup fee that would have prevented it.
What Drives the Price Up or Down
(a) Shipment volume and recurrence. A single, one-off shipment is priced per event. A recurring import program justifies moving to a package structure, which smooths cost but only pays off once shipment volume clears the package's minimum-utilization floor; below that floor, standalone per-shipment pricing is usually cheaper.
(b) Product regulatory complexity. Goods subject to additional regulatory review, defense-adjacent or restricted end-use screening, or multi-agency clearance requirements carry a higher per-shipment rate than standard commercial goods, because the underlying screening and documentation work is genuinely heavier.
(c) Statutory-only versus full-service scope. Whether your company already has an independent customs broker relationship, or needs Aplash to coordinate the entire filing, is the single biggest driver of the per-shipment rate.
(d) Rush turnaround. Declarations submitted with short notice typically carry a surcharge, since expedited coordination with a customs broker partner has a real cost.
(e) Number of ports of entry. Each additional Customs office in your shipment pattern adds its own setup filing and fee.
What to Provide When Requesting an ACP Quote
To get an accurate, comparable quote rather than a rough estimate, provide: (a) confirmation that your company is genuinely non-resident in Japan, with no Japan address, residence, or office, since this is a hard prerequisite for ACP eligibility; (b) expected shipment frequency and whether the relationship is a one-off or ongoing; (c) whether you already have a Japan customs broker relationship or need full-service coordination; (d) the number of Customs offices your shipments will clear through; and (e) whether JCT recovery is part of your plan, so the tax agent and Qualified Invoice registration costs can be scoped alongside the ACP appointment itself, rather than discovered as a surprise after the first shipment clears.
Conclusion
ACP is priced as a flat, per-event structure that reflects the lighter risk Aplash carries as a procedural agent rather than a title-holding importer, which is why its fee profile looks different from IOR's value-scaled pricing and should not be compared to it on a single number. The full picture of ACP cost includes onboarding, per-shipment or package fees, additional-port setup where relevant, and, for most recurring importers, the JCT recovery registrations that determine whether the 10 percent import consumption tax becomes a recoverable credit or a permanent cost. Request a formal proposal scoped to your actual shipment profile before budgeting against any generic number.
This article is informational only and does not constitute legal, tax, or regulatory advice. Fee structures vary by engagement profile; contact Aplash for a formal proposal tailored to your shipment. Last updated: July 2026. Aplash is a regulatory strategy and market entry firm.