Dual-Use & Export-Controlled Goods Importer of Record in Japan (外為法)
Need to import dual-use or export-controlled equipment into Japan without a local entity? Aplash can act as your Importer of Record once the regulatory path is cleared. These goods fall under the Foreign Exchange and Foreign Trade Act (外為法), Japan's export and import control law. First, the manufacturer's applicability determination (該非判定) confirms whether the goods are subject to control. Aplash reviews those materials, coordinates any licence applications with the Ministry of Economy, Trade and Industry (METI, 経済産業省), and files as Importer of Record only after the path is cleared. Every engagement in this category goes through a pre-engagement assessment before we quote.
How it works
An Importer of Record (IOR) is the company legally responsible for bringing goods through customs. Aplash takes that role so you can sell into Japan without a local entity.
- 1Free commodity assessmentSend your product details. We confirm whether Aplash can be your importer and give you a quote, at no cost.
- 2We import as your Importer of RecordAplash clears customs in its own name under the Customs Act (関税法) and arranges any permits or certifications your goods need.
- 3Delivered to your Japan buyerWe hand the goods to your Japan-side buyer and invoice transparently, so you sell in Japan with no company of your own there.
What Aplash handles
- Review applicability determination (該非判定, Hi-Higaisan-Tei) materials against the Foreign Exchange and Foreign Trade Act (外為法) List Items and Catch-All criteria. Aplash checks the manufacturer's parameter sheets against the latest control list. Final classification responsibility stays with the manufacturer and with METI.
- Coordinate export licence and import licence applications under the Foreign Exchange and Foreign Trade Act (外為法) with METI.
- Provide ECCN / EAR (US Export Administration Regulations) analysis as an advisory overlay. Authoritative US classification rests with the Bureau of Industry and Security (BIS); Aplash's role is advisory only.
- Run end-user verification: entity-list screening, sanctioned-party screening, an end-use questionnaire, and End-Use Certificate (EUC) coordination for Case D, meaning a civilian buyer whose chain carries potential military end-use.
- Act as Importer of Record for goods confirmed Catch-All-cleared, or list-controlled with a valid licence already in hand.
What we do not handle
- ITAR-controlled goods (US Munitions List): decline.
- Weapons, ammunition, defense articles: decline. Aplash holds no defense security clearance.
- Nuclear, radiological, explosive items: decline.
- Sanctioned-country or sanctioned-entity destinations: decline.
- Issue authoritative BIS ECCN rulings: that determination is US authority only.
- Provide rush IOR (under 3 business days) on Case D shipments without a prior standing EUC and completed KYC.
Applicability determination (該非判定) process, explained
Applicability determination (該非判定, Hi-Higaisan-Tei) is the manufacturer-led process of checking whether a good falls under Foreign Exchange and Foreign Trade Act (外為法) List Items or Catch-All control. Aplash reviews the manufacturer's parameter sheet against the latest control list. The manufacturer stays the data owner and the final classifier, not Aplash. We sequence the customs filing only after that determination is documented.
ECCN / EAR advisory overlay
The US Export Administration Regulations can apply when goods contain US-origin content or US-origin technology, or transit US jurisdiction. Aplash's role here is advisory only; authoritative classification rests with the Bureau of Industry and Security (BIS). We flag potential US-side gating early so the manufacturer can bring in US export counsel if needed.
End-user verification
Every engagement includes entity-list screening, sanctioned-party screening, and an end-use questionnaire, which confirms who the buyer is and what they intend to do with the goods. Where the civilian-buyer chain carries potential military end-use exposure (Case D), an End-Use Certificate (EUC) is required. Aplash provides templates aligned to METI's expectations and checks the EUC against the end-user before filing.
Pricing band
Controlled tier (single shipment, single-list 外為法 List Item, EUC in hand): from $13,000 per shipment. ECCN-contested re-verification or Case D scenarios add $2,000 to $3,000 re-verification cost plus a percentage CIF surcharge. All engagements undergo pre-engagement assessment before quoting.
Customs duty and Japanese consumption tax (JCT) are passed on at cost. Aplash earns no margin on the goods, only on the service.
Not sure if your goods qualify?
Send the product details. We confirm whether Aplash can import it and quote against the public pricing band before you commit.
Frequently asked questions
What is applicability determination (該非判定, Hi-Higaisan-Tei)?
It is the manufacturer-led process of checking whether a good falls under Foreign Exchange and Foreign Trade Act (外為法) List Items or Catch-All control. Aplash reviews the manufacturer's parameter sheet against the latest control list, but the manufacturer remains the data owner and final classifier.
Does Aplash handle ITAR-controlled goods?
No. ITAR-controlled items (US Munitions List) fall outside Aplash's IOR scope. We can refer the inquiry to a specialist with the relevant US export licensing and Japan-side defense clearance.
Can Aplash IOR for defense contractor goods?
Limited. A civilian buyer with a military-end-use chain (Case D) may be acceptable with a valid End-Use Certificate (EUC) and completed KYC. Weapons, ammunition, and direct defense-end-user transactions fall outside scope. All defense-adjacent inquiries undergo pre-engagement assessment before quoting.
How long does a Foreign Exchange and Foreign Trade Act (外為法) import licence take?
It is case-by-case: multi-week to multi-month, depending on the specific List Item, end-use, and the depth of Catch-All review needed. Aplash sequences customs filing only after the licence is granted; we do not pre-clear goods.
Do I need an End-Use Certificate (EUC)?
Yes, for any shipment with military-end-use chain potential (Case D) and for many Catch-All scenarios. Aplash coordinates EUC preparation with the end-user and provides templates aligned to METI's expectations.
Applicable law and standards
- Customs Act (関税法)
- Foreign Exchange and Foreign Trade Act (外為法)
- ECCN / EAR (US Export Administration Regulations): International standard with US jurisdiction.
Related pages
Engagement starts with an applicability determination (該非判定) review and end-user screening. Submit the manufacturer's parameter sheet and we confirm IOR feasibility before quoting.