Japan Customs Compliance for Foreign Enterprises

Importer & Exporter of Record in Japan: For Regulated, Hazardous, and Controlled Goods

We assume full legal responsibility for your cross-border shipments into and out of Japan — delivering clearance certainty, regulatory peace of mind, and a single point of accountability for hazardous, controlled, and regulated goods.

Without a compliant Importer of Record on file, shipments to Japan face seizure at the border, customs fines under 関税法, indefinite holds — or destruction of goods at your cost.

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Scope of responsibility is defined in our engagement terms.

Two Distinct Services. One Trusted Partner.

Whether your goods are entering or departing Japan, Aplash holds the legal designation required to ensure full compliance at every stage of the customs process.

IOR

Importer of Record

What it means

Aplash becomes the Importer of Record — assuming all statutory obligations imposed upon the importing entity under Japanese customs law.

Aplash bears direct responsibility as Importer of Record; customs declarations are executed in practice by our licensed customs broker partners.

Who requires this

Foreign enterprises without a registered Japanese legal entity, or those importing regulated, licensed, or controlled goods requiring specialist designation.

What we do
  • Full customs declaration and clearance — filed under 関税法 第67条 in Aplash's name as Importer of Record
  • Customs duties and consumption tax settled — no direct engagement with Japanese authorities required
  • Import permits secured — 薬機法, 電安法, 食品衛生法 compliance managed by Aplash as Importer of Record
  • Legal importer registration — Aplash formally designated with Japanese Customs as Importer of Record
  • Statutory document retention and audit readiness maintained throughout the engagement
EOR

Exporter of Record

What it means

Aplash becomes the Exporter of Record — ensuring all export control obligations under Japanese and international trade law are thoroughly discharged.

Aplash bears direct responsibility as Exporter of Record; customs declarations are executed in practice by our licensed customs broker partners.

Who requires this

Companies exporting goods from Japan who require export control compliance, classification advisory, or end-user verification before shipment.

What we do
  • Export declaration filed in Aplash's name — 外為法 第48条 輸出管理 obligations fully discharged as Exporter of Record
  • Export control classification advisory — 該非判定 determination handled by our specialists
  • ECCN / EAR compliance review — United States export administration requirements assessed and managed
  • Legal exporter registration — Aplash formally designated with competent Japanese authorities as Exporter of Record
  • End-use and end-user verification — due diligence conducted to protect your regulatory standing

Which Structure Fits Your Situation?

IOR, ACP, and own-entity import are three structurally distinct legal frameworks under 関税法 (Customs Act). Pick the one that matches your Japan presence and your invoicing chain.

Use IOR when:

You want Aplash to act as the legal Importer of Record. Aplash purchases the goods from your overseas supplier under Contract ①, clears Japan customs in Aplash's name, and on-sells the goods to the Japan-side buyer under Contract ② at landed cost + duties + Japanese consumption tax (JCT). The Japan-side buyer receives Aplash's 適格請求書 (qualified invoice) and recovers JCT through their own filing. Aplash bears full importer liability under 関税法 (Customs Act). Use this structure when there is a Japan-side buyer to receive the goods.

Use ACP when:

Your company is the legal importer named on the import declaration. Aplash acts as your 税関事務管理人 (Tax Customs Administrator) under 関税法第95条 (Customs Act Article 95). Available only to non-resident entities (no Japan address, residence, or office). Japanese consumption tax (JCT) recovery requires separate appointment of 消費税の納税管理人 (Tax Administrator for Consumption Tax) and Qualified Invoice Issuer registration.

You may not need either:

If your company has a registered Japan entity (KK / GK / Branch), you typically file customs in your own name. We can still coordinate compliance, permits, and 通関士 partner work without acting as IOR.

Commodity Expertise

We specialise in commodity types that require specialist permits, licences, or multi-agency regulatory coordination — managed as a single, accountable engagement.

Dangerous Goods

Classification, documentation, and customs declaration for shipments governed by IATA DGR and IMDG Code — fully managed for both air and sea freight.

IATA DGR / IMDG-classified shipments cleared under 関税法 (Customs Act) with Aplash as named importer.

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Lithium Batteries

UN38.3 testing compliance and Section II / IA packing instruction management handled end to end, including declaration and clearance by Aplash as Importer of Record.

UN38.3-certified lithium-ion, lithium-metal, and lithium-polymer batteries: Section II and Section IA handled.

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Chemical Substances

Import management for chemical substances subject to pre-manufacture notification and toxic materials controls — permit acquisition included.

化審法 (Chemical Substances Control Law) and 毒劇法 (Poisonous and Deleterious Substances Control Law) import notification and permit coordination.

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Medical Devices

Class I through IV device designation, import permit acquisition, and customs clearance — the complete 薬機法 pathway managed by Aplash as Importer of Record.

薬機法 (Pharmaceutical and Medical Device Act) Class I and Class II import; Class III and IV are restricted scope.

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Controlled Electronics

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

PSE (電気用品安全法) and 技適 (Radio Act type certification) with Aplash as Notifying Supplier on label.

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Food & Supplements

Customs clearance and regulatory support for food, beverages, supplements, and functional foods — notification obligations managed by Aplash as Importer of Record.

食品衛生法 (Food Sanitation Act) import notification per shipment; 機能性表示食品 (functional food) notification coordination.

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Industrial Equipment

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

消防法 (Fire Service Act) and 高圧ガス保安法 (High Pressure Gas Safety Act) permits and ATA Carnet temporary admission.

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Dual-Use & Export-Controlled Goods

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

外為法 (Foreign Exchange and Foreign Trade Act) 該非判定 (applicability determination) and end-user verification; pre-engagement assessment required before quoting.

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Our network of licensed 通関士 and regulatory specialists accepts shipments that standard freight forwarders routinely decline. For commodity types not listed here, contact our team for a confidential assessment.

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Electronics track — teaser

IOR alone is not enough for regulated electronics. Aplash provides the full stack.

For PSE-regulated electronics and Radio Act devices specifically, the IOR engagement is one of three stacked roles in Aplash's scope. The other seven commodity tracks above use their own compliance stack — see the relevant subpage.

Layer 1

Importer of Record

Aplash as named importer; buy-and-sell contract chain; 適格請求書 (qualified invoice) issued to Japan-side buyer.

Per-shipment fee, CIF-banded
Layer 2

Notifying Supplier (PSE / Radio Act)

Aplash as METI (経済産業省 / Ministry of Economy, Trade and Industry) registered responsible party on the PSE label; ongoing record-keeping and audit-readiness.

Initial certification + annual maintenance
Layer 3

Distribution Coordination

Aplash invoices the Japan-side buyer and coordinates collection; transparent service-fee disclosure in the engagement letter.

Distribution coordination fee, % of CIF

Pricing Transparency

Public floor pricing only. Engagement-specific quotes confirmed in the engagement letter; full pricing matrix is shared after the commodity assessment.

Standard

EAR99 IT equipment, no dual-use flag

from $2,800 per shipment

+ customs duties and Japanese consumption tax (pass-through at cost).

Regulated

PSE / Radio Act / complex goods

from $4,800 per shipment

+ per-layer compliance fees (PSE notification, 技適, food notification, permit coordination).

Controlled

Dual-use / FEFTA-controlled / Case D

from $13,000 per shipment

Restricted scope. Pre-engagement assessment required before quoting. ITAR, weapons, ammunition, nuclear are out of scope.

Customs duties and JCT pass through at cost. Aplash earns no margin on the goods, only on the service.

Frequently asked questions

Eight questions covering structure choice, regulated commodities, certification stacking, and engagement scope. Full Q&A depth lives on each commodity subpage.

Do I need a Japan entity to import goods into Japan?

No. With IOR you do not need a Japan entity. Aplash acts as the legal Importer of Record under 関税法 (Customs Act), buys the goods from your overseas supplier, clears customs, and on-sells to your Japan-side buyer. Foreign companies with no Japan presence can ship into Japan in days.

What is the difference between IOR and ACP in Japan?

IOR means Aplash becomes the legal importer named on the customs declaration. ACP means you remain the importer and Aplash acts as your 税関事務管理人 (Tax Customs Administrator) under 関税法第95条 (Customs Act Article 95). They are structurally distinct frameworks; see the Decision Panel above.

Can Aplash act as IOR for IT equipment imports?

Yes. IT equipment is one of Aplash's defensible specialties: AC adapters, networking gear, computing hardware, and wireless peripherals. Most IT equipment triggers PSE (電気用品安全法) or 技適 (Radio Act type certification), and Aplash stacks IOR with Notifying Supplier registration.

Does IOR include PSE certification?

No. PSE certification and IOR are separate functions. Aplash provides both in one engagement: Aplash imports as named IOR and registers with METI as Notifying Supplier so its name appears on the PSE label. See the three-layer synergy section.

Do wireless products need separate certification before IOR?

Yes. Any product with Wi-Fi, Bluetooth, cellular, NFC, or RF transmission requires 技適 (Giteki, Radio Act type certification) before commercial use in Japan. Aplash coordinates the certification via TELEC or another 登録証明機関 (Registered Certification Body) in parallel with customs clearance.

How long does IOR setup take in Japan?

Most engagements complete the engagement-letter, KYC, and documentation phase in 2 to 4 weeks, with first commercial shipment cleared within 6 weeks. Wireless products requiring fresh 技適 testing extend the timeline to 8 to 12 weeks.

Can Aplash handle dual-use or FEFTA-controlled goods?

Yes, subject to pre-engagement assessment. 該非判定 (applicability determination) is reviewed against 外為法 (Foreign Exchange and Foreign Trade Act) List Items and Catch-All criteria using the manufacturer's parameter sheet. ITAR-controlled goods, weapons, ammunition, nuclear, and radiological items are out of scope.

Can Aplash IOR for military-adjacent or defense supply chain shipments?

Limited. Civilian-buyer chains with potential military end-use (Case D) may be acceptable with valid EUC (End-Use Certificate) and KYC. Direct defense-end-user transactions, weapons, and ammunition are out of scope. All defense-adjacent inquiries undergo pre-engagement assessment before quoting.

Built on Japanese Law

Every engagement is conducted in strict accordance with Japanese customs, trade control, product safety, and international regulatory frameworks.

🇯🇵関税法 · 外為法 · 薬機法 · 電安法 · 化審法 · 食品衛生法 · 消防法
🌐IATA DGR · IMDG Code · ECCN/EAR · Incoterms 2020

Ground-Level Expertise at Every Port

We collaborate with licensed 通関士 (customs specialists), bonded freight forwarders, and regulatory professionals embedded at Japan's principal ports of entry and departure.

01

Tokyo

Narita International · Haneda Airport · Yokohama Port

02

Nagoya

Chubu Centrair International · Port of Nagoya

03

Osaka / Kobe

Kansai International · Port of Kobe · Osaka Port

04

Fukuoka

Fukuoka Airport · Hakata Port

05

Naha

Naha Airport · Naha Port — Okinawa Free Trade Zone

Our Engagement Process

A disciplined, five-stage framework designed to deliver clarity, legal certainty, and operational efficiency at each juncture.

01

Shipment Assessment

HS Code classification and commodity eligibility confirmed — regulatory obligations identified before a single document is filed.

02

Compliance Review

All required permits, licences, and export control positions confirmed — no surprises at the point of customs.

03

Partner Assignment

Engagement structured to match your port of entry, commodity profile, and regulatory requirements — the right specialists, in position.

04

Filing & Clearance

Customs declaration submitted and cleared — duties and taxes settled so you never interact directly with Japanese customs authorities.

05

Documentation

A complete, audit-ready record retained for the statutory period — your compliance position protected.

Aplash is a regulatory-strategy and Japan market-entry firm — not a freight forwarder. Aplash is not a freight forwarder, customs broker, or logistics provider. We are a regulatory-strategy and Japan market-entry firm that assumes the legal importer position — and the statutory liability under 関税法 (Customs Act) that comes with it — so foreign companies can ship regulated goods into Japan without a local entity.

Frequently Asked Questions

Frequently Asked Questions

An Importer of Record (IOR) is the legal entity responsible for ensuring imported goods comply with all Japanese import regulations and for paying applicable duties and taxes. When a foreign company cannot act as IOR in Japan, Aplash steps in as the IOR on your behalf, assuming full legal import responsibility under the Customs Act (関税法).

An Exporter of Record (EOR) is the entity listed on export documentation as the legal exporter. This is required when a foreign company needs goods exported from Japan but lacks a Japanese legal presence. Aplash serves as EOR, handling export clearance under the Foreign Exchange and Foreign Trade Act (外為法).

IOR (Importer of Record) assumes full legal import liability -- Aplash becomes the legal importer and owns import compliance risk. ACP (Attorney for Customs Procedures) is a representative role where you remain the owner and payer; Aplash handles customs declarations on your behalf. IOR is suited for regulated, complex, or high-liability goods; ACP is lighter and lower-cost for general e-commerce and Amazon FBA.

Aplash IOR handles dangerous goods (IATA DGR / IMDG), lithium batteries (UN38.3), chemical substances (化審法), medical devices (薬機法), controlled electronics (PSE / 電安法), food and supplements (食品衛生法), industrial equipment, and dual-use goods (外為法 / ECCN). Contact us to confirm coverage for your specific commodity.

Aplash covers all major Japanese ports and airports: Tokyo (Narita International, Haneda, Yokohama), Nagoya (Chubu Centrair, Port of Nagoya), Osaka/Kobe (Kansai International, Port of Kobe, Osaka Port), Fukuoka (Fukuoka Airport, Hakata Port), and Naha/Okinawa (Naha Airport, Naha Port).

No. That is the core purpose of the service. Aplash acts as your IOR/EOR, allowing your foreign company to import or export through Japan without establishing a Japanese subsidiary or branch office.

Initial engagement and documentation typically takes 3 to 7 business days. Once onboarded, Aplash can process shipments on an ongoing basis. Timeline varies by commodity type and required ministry filings.

Key regulations include the Customs Act (関税法), Foreign Exchange and Foreign Trade Act (外為法), Pharmaceutical and Medical Device Act (薬機法), Electrical Appliance Safety Act (電安法), Chemical Substances Control Law (化審法), Food Sanitation Act (食品衛生法), and Fire Service Act (消防法). International standards such as IATA DGR, IMDG Code, ECCN/EAR, and Incoterms 2020 also apply.

Scaling your Japan imports?

Establish a Japanese Entity for Long-Term Cost Savings

IOR removes the entity requirement for market entry — but as your Japan import volume grows, establishing a KK or GK unlocks lower per-shipment costs, direct customs relationships, and full operational independence in the market.

Explore Company Setup (KK / GK)
Shipping standard goods to Amazon FBA Japan?

ACP may be a faster, simpler fit

For general consumer goods without ministry filings -- fashion, electronics accessories, sports goods -- ACP (Attorney for Customs Procedures) provides a lighter-touch path to Japan market entry at lower cost.

Explore ACP Service

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Non-Resident IOR vs. Full Entity - Cost-Benefit Analysis

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E-Commerce IOR - Selling on Amazon Japan & Rakuten as a Non-Resident

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IOR & EOR in Japan - Enter the Market Without an Entity

Test Japan Demand Before Full Incorporation: Importer of Record and Employer of Record Explained

Importing Dangerous Goods to Japan — IATA, IMDG & Regulatory Compliance Guide 2026

Lithium Batteries, Compressed Gases, Chemicals, and Hazardous Materials: What Japan Requires Before Your Shipment Clears Customs

Japan HS Code Classification — Determine the Right Tariff Code for Your Imports

Why the Wrong HS Code Costs More Than Just the Duty Rate

When Your Import Is Too Complex for a Standard ACP

Most ACP providers handle customs declarations. But when your shipment triggers FEFTA, Radio Act, or HS advance rulings — standard ACP stops and regulatory execution starts.

IOR vs ACP — Which Do You Need for Japan Imports?

Choosing the wrong import structure in Japan can cost you millions of yen in unrecoverable tax. Here's how to decide between IOR and ACP — and when you need both.

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