A Mexican manufacturer of automotive parts, industrial components, agricultural or food products, or electronics assemblies typically already has a Japan-side distributor in place before it ever asks how to structure the customs side of that relationship. The usual pattern: the distributor is named as importer, the manufacturer invoices the distributor at a wholesale price, and the manufacturer has no visibility into, or control over, how the goods are priced once they clear Japan Customs (税関). That arrangement is administratively convenient but it forfeits commercial control the manufacturer may want to keep, and it forfeits the ability to capture a preferential tariff outcome under the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP) directly rather than through the distributor's own resale economics. Mexico is a founding member of CPTPP alongside Japan, which means a Mexican manufacturer has a real preferential-tariff lever available on qualifying goods, distinct from anything negotiated bilaterally between Mexico and Japan, because no bilateral Mexico-Japan economic partnership agreement exists. This post covers the Attorney for Customs Procedures (税関事務管理人) structure that lets a Mexican manufacturer hold the Japan importer position itself without a Japan entity, how that interacts with CPTPP origin preference, and where Importer of Record (IOR) sits as a structurally separate alternative.
Why Title Retention Matters When a Distributor Relationship Already Exists
A manufacturer that has already built a distributor relationship in Japan is not asking "should I sell into Japan." It is asking "how much of the commercial and regulatory position do I want to keep for myself." When a distributor is named as importer, the distributor sets resale pricing, controls the customs value declared, and is the party of record for any post-clearance inquiry from Japan Customs. The manufacturer's only real relationship to the transaction is the invoice it issues at the export side. If CPTPP preference applies to the shipment, it is the distributor, as the named importer, that benefits from the reduced duty, not the manufacturer.
Retaining the importer position, or at minimum retaining title through to the point of sale in Japan, changes that dynamic. The manufacturer sees the actual customs value, controls how the CPTPP origin claim is documented and substantiated, and captures any tariff-preference benefit directly rather than through whatever the distributor chooses to pass along in its own pricing. None of this requires the manufacturer to incorporate a Japan entity. What it requires is a Japan-resident customs contact, because a non-resident cannot file an import declaration (輸入申告) in its own name without one.
Two Structurally Distinct Paths to a Japan Customs Presence
A Mexican manufacturer without a Japan-registered office, residence, or address has two structurally separate ways to solve the "no Japan customs identity" problem. They are never interchangeable and are never presented as a single either/or choice on the same shipment.
**Attorney for Customs Procedures (ACP, 税関事務管理人)**
Under Article 95 of the Customs Act (関税法), a non-resident entity, meaning an entity with no Japan address, residence, or office, may be named as importer of record on a Japan customs declaration by appointing a Japan-resident procedural agent. Aplash serves in that capacity. The Mexican manufacturer remains the legal importer named on the declaration and retains title to the goods throughout the import process. Aplash acts as the statutory customs contact, receiving notices from Japan Customs and coordinating the declaration with a licensed customs specialist (通関士). Because the manufacturer, not Aplash, is the named importer, the manufacturer bears customs duty liability and consumption tax (消費税) liability on the import directly, and it is the manufacturer, not Aplash, that invokes CPTPP preference on its own declaration.
Recovering import consumption tax under this structure depends on two additional registrations sitting alongside the ACP appointment itself. First, a Tax Representative (納税管理人) appointed with the National Tax Agency (国税庁), giving the manufacturer a Japan-resident tax contact for consumption tax matters arising from its imports; Aplash can serve in this role directly. Second, registration 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), which is what allows the manufacturer to credit import consumption tax against output tax on its own Japan sales where those sales are B2B. Without both registrations in place, import consumption tax sits as a permanent, unrecoverable cost on the manufacturer's Japan position. With both complete, a licensed tax accountant (税理士) handles the substantive consumption tax computation and filing that puts the credit into effect. ACP is available only while the manufacturer remains a non-resident of Japan; a manufacturer that later incorporates a Japan entity becomes its own importer and engages a customs broker (通関業者) directly.
**Importer of Record (IOR)**
Under an IOR structure, Aplash purchases the goods from the Mexican manufacturer and clears them through Japan Customs in Aplash's own name. Aplash is the named importer on the declaration, holds title during the import transaction, and bears the customs duty and consumption tax liability that attaches to that position. Because Aplash is the named importer, it is Aplash, not the manufacturer, that would invoke CPTPP preference on a qualifying shipment, and the benefit is reflected in Aplash's cost structure and resale price rather than directly on the manufacturer's own books. IOR suits a manufacturer that would rather not hold any Japan customs or tax identity at all, whether because shipment volume does not justify the registration overhead, or because the manufacturer prefers the existing distributor arrangement to continue absorbing import responsibility while Aplash sits between the manufacturer and that distributor instead of the distributor holding the importer position on its own.
CPTPP Origin Preference: A Distinct Lever From Any Bilateral EPA
Mexico and Japan are both original CPTPP parties, and CPTPP has governed Mexico-Japan preferential trade access since it entered into force for both countries. There is no separate Mexico-Japan bilateral economic partnership agreement, so a Mexican manufacturer should not assume the origin-documentation approach used under the EU-Japan Economic Partnership Agreement, or under any other bilateral instrument covered elsewhere on this blog, applies here. CPTPP's origin framework is its own multilateral instrument with its own rules of origin and its own approach to origin certification, generally understood to allow self-certification by the exporter, producer, or in some cases the importer, rather than requiring a government-issued certificate for every shipment.
In general terms, three structural points matter for a Mexican manufacturer holding the importer position under ACP:
(a) An origin attestation supporting the CPTPP claim must exist and be substantiated before Japan Customs relies on it to apply a preferential rate; it cannot be reconstructed after a shipment has already cleared at the standard rate.
(b) Whichever party prepares the attestation, whether the manufacturer as exporter or producer, or another authorized party in the supply chain, must hold the underlying records demonstrating the good's originating status and be able to produce them on request.
(c) Whether a given product actually qualifies as originating depends on CPTPP's product-specific rules of origin for that product's tariff classification. Manufacture in Mexico alone does not make a good automatically originating; the applicable rule, and whether the specific product satisfies it, is assessed per product.
This article does not state a specific preferential tariff rate, a specific origin-content percentage threshold, or a specific HS classification, because those figures vary by product and change over time, and using an incorrect figure on an actual declaration creates duty and compliance exposure. Confirm the current preferential rate and the applicable rule of origin for the specific product against the official CPTPP text and Japan Customs' published guidance before relying on either for a real shipment.
Setting Up ACP: Practical Sequence and Timing
For a Mexican manufacturer moving from a distributor-as-importer arrangement into an ACP structure, the general sequence runs as follows. None of the steps below carry a fixed fee or fixed processing time in this description; actual timing depends on the manufacturer's product, documentation readiness, and the relevant government offices' current processing windows, and should be confirmed at the time of engagement.
(a) ACP appointment with Japan Customs. Aplash files the Attorney for Customs Procedures Notification (税関事務管理人届出書) establishing the manufacturer as the named importer on future declarations, with Aplash as the statutory procedural contact.
(b) Tax Representative appointment. Aplash is appointed as the manufacturer's Tax Representative (納税管理人) with the National Tax Agency, in parallel with or shortly after the ACP filing, since the consumption tax obligations on the manufacturer's imports begin the moment it becomes named importer.
(c) Qualified Invoice Issuer registration. This registration with the National Tax Agency is what allows the manufacturer to later credit import consumption tax against its Japan output tax. It is frequently the step that drives overall setup timing, since a shipment cleared before this registration is confirmed carries import consumption tax that cannot be recovered retroactively.
(d) Customs broker coordination. Aplash coordinates with a licensed customs specialist (通関士) at a Japan customs broker (通関業者) for the mechanical filing of each declaration, working from the origin documentation and product classification the manufacturer's team has confirmed in advance.
(e) Origin documentation readiness. Before the first shipment moves under CPTPP preference, the manufacturer should have its origin attestation and supporting records prepared and reviewed, not assembled reactively after Japan Customs raises a query.
Sequencing (a) through (c) before the first shipment, rather than in parallel with it, avoids the common failure pattern where goods clear under standard duty and full consumption tax because the tax registrations were still pending when the shipment moved.
Conclusion
A Mexican manufacturer selling into Japan through an existing distributor relationship does not have to accept that the distributor holds the importer position, the pricing control, and the CPTPP duty benefit by default. The Attorney for Customs Procedures structure under Article 95 of the Customs Act lets the manufacturer remain the named importer and retain title without incorporating a Japan entity, provided the tax representative and qualified invoice registrations are completed in sequence. Where the manufacturer would rather not hold any Japan customs identity at all, Importer of Record is the structurally distinct alternative, with Aplash as named importer instead. Either way, CPTPP origin preference runs through its own multilateral rules of origin, separate from any bilateral EPA framework discussed elsewhere, and the applicable rate and rule of origin for a specific product should be confirmed against the official CPTPP text and Japan Customs before a shipment relies on it.
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: 2026-07.