IOR, EOR & customs compliance

Japan Importer & Exporter of Record

Assess the named importer or exporter, product rules, invoice chain and declaration route before freight is booked. Our customs specialist reviews the shipment; the named licensed broker or authorised declarant handles the filing.

Direct answer

Can a foreign company import into Japan without establishing a local entity?

Yes, in some cases. A foreign business may use an accepted IOR, remain the importer under an eligible ACP structure, or import through its own Japan entity. For exports from Japan, the named exporter and declaration route must be confirmed. We assess the product, parties, permits and invoice chain before recommending a route.

Route decision

IOR, EOR, ACP or your own entity?

Choose by legal role, ownership and invoice chain, not by acronym.

Shipment responsibility chain

Who provides the facts, who reviews them and who files.

The written scope identifies the client input, Aplash review, named declarant and authority decision for the shipment.

  1. Client team

    Provides the seller, buyer, product, value, origin, end-use and commercial documents used for assessment.

    Confirms the commercial and product facts supplied to the other parties.
  2. Aplash engagement team

    Confirms the proposed importer or exporter, written scope, required applications and named declaration route.

    Accepts only the product and transaction identified in the engagement.
  3. In-house customs specialist

    Reviews the product description, HS-code rationale, valuation, origin, restrictions and document readiness.

    Regulated applications are handled by the administrative scrivener or other responsible professional when scoped.
  4. Licensed broker or authorised declarant

    Submits the declaration, responds through customs clearance and completes the release formalities for the shipment.

    The named declaration party is confirmed before dispatch.
  5. Customs and other authorities

    Review declarations and applications, request inspections or corrections, and decide permits and release.

    Authority decisions are independent of the service engagement.
Product gate

Product coverage is conditional.

A category shown on this page is not automatic acceptance. Eligibility depends on exact model, composition, use, origin, parties, destination, evidence and applicable law.

Potentially eligible

General commercial goods with a clear seller, buyer, consignee, value and end use.

Evidence or application required

Regulated, dangerous, controlled or technically complex goods and products needing a Japan-side responsible party.

Review all product categories and regulatory notes
01

Dangerous Goods

We assess classification, evidence, packing and carrier requirements for dangerous-goods shipments, then confirm the authorised declarant and licensed parties in writing.

IATA DGR / IMDG evidence and carrier acceptance are assessed case by caseReview this category
02

Lithium Batteries

We review UN38.3 evidence, packing instructions, transaction roles and the proposed clearance route before accepting a lithium-battery shipment.

Testing evidence, carrier acceptance and customs release are not guaranteedReview this category
03

Chemical Substances

We assess chemical classification, notification and licence questions, then scope any regulated application and licensed-party handoff before shipment.

Chemical Substances Control Law (化審法): pre-manufacture notification required before import · Poisonous & Deleterious Substances Control Law (毒劇物取締法)Review this category
04

Medical Devices

We assess the device class, marketing-authorisation position, transaction parties and import route. Regulated applications are handled by the responsible licensed professional where scoped.

PMD Act requirements vary by device, intended use and responsible marketing structureReview this category
05

Controlled Electronics

PSE mark coordination and technical conformity management for electrical appliances and radio equipment entering the Japanese market.

Electrical Appliance Safety Act (電安法) · Radio Act (電波法): type approval (型式確認) mandatory before market entryReview this category
06

Food & Supplements

We review ingredients, intended use, labels, inspection history and the importer structure, then confirm the regulatory and licensed-broker workflow.

Food Sanitation Act and labelling requirements are assessed for the specific product and shipmentReview this category
07

Industrial Equipment

Certification coordination for equipment subject to hazardous materials handling and high-pressure gas regulations before entry or deployment.

Fire Service Act (消防法) · High Pressure Gas Safety Act (高圧ガス保安法): hazardous materials handling certification requiredReview this category
08

Dual-Use & Export-Controlled Goods

Applicability determination (該非判定) advisory, end-user screening, and multi-jurisdiction coordination for goods with strategic or export-controlled applications.

Foreign Exchange & Foreign Trade Act (外為法): export controls and applicability determination (該非判定) classification required · ECCN/EAR US jurisdiction overlayReview this category
Shipment sequence

Five checks from product brief to release file.

Each stage produces the document or decision required by the next party.

  1. 01

    Route assessment

    Review the product, parties, transaction chain, origin, destination and intended use; compare IOR, EOR, ACP and own-entity routes.

    Control output: Route recommendation
  2. 02

    Agreement and payment

    Confirm acceptance conditions, responsible parties, declaration route, exclusions, third-party costs and payment terms in writing.

    Control output: Signed scope and accepted transaction
  3. 03

    Evidence and permits

    Collect classification, valuation, origin, test, label, licence and screening evidence. Our administrative scrivener handles regulated applications where scoped.

    Control output: Product and permit checklist
  4. 04

    Pre-shipment gate

    Our in-house customs specialist checks the evidence and readiness conditions. Unresolved gaps stop release to the carrier or customs route.

    Control output: Broker instruction pack
  5. 05

    Declaration, clearance and record pack

    The identified authorised route submits the declaration. Customs decides inspection and release; after completion, the shipment record is assembled and retained.

    Control output: Declaration and release file
Broker handoff

Five documents move the shipment forward.

The shipment file gives the client, reviewer and declarant the same commercial and product facts before dispatch.

Supporting documents are collected through private access after engagement.
  • Transaction sheet

    Seller, buyer, importer or exporter, Incoterms, title transfer, payment flow and declared value.

  • Product sheet

    Model, composition, intended use, origin, product description and HS-code rationale.

  • Permit checklist

    Required tests, labels, notifications, licences and the professional responsible for each application.

  • Broker instruction

    Named declarant, approved document versions, open questions and the conditions to resolve before dispatch.

  • Release file

    Declaration, customs queries, corrections, release evidence and the documents retained after clearance.

Engagement pricing

Quote the shipment you actually have.

Product, value, transaction structure, permits and clearance route determine scope.

Published figures are planning floors only. Freight, testing, certification, broker charges, duties and Japan consumption tax are separate unless the proposal states otherwise.

No shipment is accepted solely from a pricing band. Eligibility and written scope come first, which is why IOR and EOR are engaged through an assessment rather than ordered online. Importers who keep importer-of-record status themselves and need only the Japan-side customs contact can order the ACP appointment online at its published fee. See the ACP route

Reference frameworks

  • Customs Act (関税法)
  • Foreign Exchange and Foreign Trade Act (外為法)
  • Pharmaceuticals and Medical Devices Act (薬機法)
  • Electrical Appliances and Materials Safety Act (電安法)
  • Chemical Substances Control Law (化審法)
  • Food Sanitation Act (食品衛生法)
  • Fire Service Act (消防法)
Common port coverage
  • Tokyo / Yokohama
  • Narita / Haneda
  • Nagoya
  • Osaka / Kobe
  • Fukuoka / Hakata
  • Naha / Okinawa
FAQ

Frequently Asked Questions

Route choice, shipment evidence, clearance roles and realistic outcomes.

The Importer of Record is the party named as importer for an eligible transaction and responsible for the importer obligations assigned by law and the commercial structure. Aplash accepts that position only for products and transactions confirmed in a signed engagement.

Assess my shipment route

Send the product, model, use, origin, destination, value, Incoterms, seller, buyer, importer/exporter plan, target date and available certificates.

Shipment direction
Supporting documents are requested securely after the initial review.

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The Aplash lifecycle

One partner across your Japan journey.

  1. Stage 01Test the marketImport and sell through IOR or ACP with no Japan entity required.You are here
  2. Stage 02IncorporateEstablish a KK or GK once your volume justifies your own entity.Explore
  3. Stage 03OperateRun the business with ongoing tax, visas, and compliance handled.Explore

From the journal.

Field notes on Japan import, export and product-compliance routes.

View all articles
IOR & EOR

Can You Use a Japan IOR to Import Goods Before You Have a Buyer Lined Up? (2026)

Yes. A Japan Importer of Record can bring goods into the country before a downstream buyer is secured, but only as a structured hold, not an open-ended parking arrangement. The importer of record...

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IOR & EOR

Can You Stay the Exporter of Record on a Japan Export? Client-Named-Exporter EOR Explained (2026)

Yes. Under a Client-Named-Exporter EOR structure, your company, or a named non-resident principal, stays the named exporter on the export declaration (輸出申告), and Aplash coordinates the filing as...

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IOR & EOR

How Japan Customs Identifies the Real Importer in 2026: Reseller Deals vs Name-Lending

Japan Customs looks past the name printed on the import declaration (輸入申告) and asks who actually held disposal authority (処分の権限) over the goods at the moment of filing, and whose account bore the...

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IOR & EOR

Does a Japan Importer of Record Have Packaging Recycling Obligations in 2026?

Yes. A business that imports packaged goods for sale in Japan is normally designated a specified business operator (特定事業者) under the Containers and Packaging Recycling Act (容器包装リサイクル法) and bears a...

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IOR & EOR

Can You File a Japan Export Declaration Before the Goods Reach Bonded Storage? (2026)

Yes. Unlike an import declaration, a Japan export declaration can be filed before the goods enter a bonded area (保税地域), and no special approval is needed to do it. The Customs Act (関税法) imposes a...

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IOR & EOR

Who Is the Importer of Record for a Japan Consignment-Sale Import? (2026)

For goods you sell in Japan on consignment, either you as the overseas seller or your Japan-based selling party can be the import declarant, and Japan Customs has published both as acceptable...

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