Restrictions on Handling by ACP in Japan - Our System Enables Us to Handle Regulated Items

When importing regulated products—such as those subject to the Four Product Safety Acts, including PSE and PSC, the Food Sanitation Act, and the Pharmaceutical and Medical Device Act (including cosmetics)—importers must comply with specific regulatory requirements, labeling rules, and import procedures.
Through our strengthened compliance framework and partnerships, SK Advisory is now able to support non-resident companies as Attorney for Customs Procedures (ACP), Domestic Administrator (sometimes referred to as “Domestic Representative”), and importer for these regulated products.

Support for the Product Safety Acts (PSE / PSC)

Following the amendment of the Four Product Safety Acts, effective December 25, 2025, foreign businesses selling regulated products in Japan through online platforms are required toappoint a Domestic Administrator and submit a formal notification to METI.

SK Advisory provides an integrated solution combining:

• Domestic Administrator (sometimes referred to as “Domestic Representative”) Service under the Four Product Safety Acts (including PSE / PSC)
• ACP Service

This allows non-resident entities to comply with Japanese regulatory requirements while enabling lawful importation and sale.

PSE Domestic Administrator Service

Support for the Food Sanitation Act (Food & Food-contact Products)

Food products and food-contact utensils are regulated under the Food Sanitation Act and require proper filing, inspection, and documentation by a designated domestic importer.

SK Advisory supports these products as the Importer and manages the required procedures to enable compliant importation.

Support for the Pharmaceutical and Medical Device Act (Cosmetics, etc.)

Products regulated under the Pharmaceutical and Medical Device Act require appropriate licenses to import and distribute in Japan.

We coordinate with licensed partner companies to arrange compliant supply chains and ensure lawful importation and sale in Japan.

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Japanese Import-Related Regulations

To help you navigate the import-related regulations and ensure compliance before shipping goods to Japan, we would like to introduce several websites:

• Japan Customs Office: List of import-related laws and regulations
  

Food

• Ministry of Health, Labour and Welfare: Food Sanitation Law

Medicines

• Ministry of Health, Labour and Welfare: Import medicines for personal use

Electrical appliances

• Ministry of Economy, Trade and Industry: PSE related procedures (Electrical Appliances and Materials Safety Act)
• PSE Mark, Mandatory Safety & EMC Approval
• List of Category B Electrical Appliances and Materials (341 Items)
• List of Category A Electrical Appliances and Materials (116 Items)

Plants and their seeds

•  Japan Customs Office: Import restrictions in accordance with the Plant Protection Law

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Please Be Aware

• In cases where foreign corporations (non-residents) without an office in Japan import or export goods, failure to properly prepare an Importer of Record (IOR) or Exporter of Record (EOR) through an Attorney for Customs Procedures (ACP) or similar means can result in goods being held at customs, leading to significant delays and costs. To avoid such risks, please make thorough preparations.
• If an ACP is needed, it is crucial to utilize the services of an experienced ACP well-versed in customs-related laws and regulations. The import and export operations of non-residents/foreign corporations using an ACP are treated as unique cases. Many customs brokers are not familiar with these procedures, leading to incidents where goods are detained for extended periods due to unsuccessful explanations to customs. (Customs will not permit the import if the explanations provided by the importer or customs broker are unsatisfactory, resulting in the goods being detained until customs is convinced.)
• We highly recommend utilizing our services as professional experts in customs, knowledgeable about customs-related laws and regulations. With a proven track record of resolving numerous issues through direct consultations with customs officers and customs brokers, our clients supported as an ACP now exceed 200 companies. We are committed to delivering industry-leading results with our expertise.

Why choose us?

We specialize in navigating complex issues at the intersection of customs procedures and taxation—an area where our ability to offer practical, comprehensive support from both perspectives sets us apart. Understanding the close relationship between customs duties and national taxes (especially, Japan Consumption Tax - JCT), and addressing both in an integrated manner, is crucial in the context of international trade.

• Customs and International Trade Professionals - Our CEO, Mr. Sawada, is a Certified Customs Specialist in Japan. With years of experience providing services in the Trade & Customs field, his leadership at KPMG and the establishment of his own company, SK Advisory, ensures our commitment to excellence and high-quality service.
• Full Adherence to Japanese Customs Law - Our top priority is to maintain full compliance with Japanese Customs Law and safely import / export our clients' goods into / from Japan. We meticulously manage all import compliance aspects, including Japan Importer of Record (IOR) matter, HS code classification and the correct Customs Valuation of goods entering Japan. We support to complete all the necessary shipping documents, such as Invoice, Packing List and BL, on behald of non-resident / foreign Japan IOR.
• Communication in English, Chinese, and Japanese - Our team, with extensive international experience, excels in communication in English, including facilitating English-language meetings, and has earned considerable trust from clients. We also have staff capable of communicating in Chinese, making us equipped to handle Chinese-language support as well. Naturally, as a Japan-based team, we're totally fluent in Japanese, ensuring seamless communication across these three key languages.
• Reputable and Reliable Partner -The growing demand for our Attorney for Customs Procedures (ACP) services is testament to our quality. We proudly serve clients globally, registering over 80 ACP customers annually. Our consistent track record underscores our reliability and credibility. 
• Handling Regulated Products - Our ACP/IOR partnership system facilitates the management of regulated items including cosmetics, PSE-products, foodstuffs, and tableware.
• Recognized ACP Service Provider on Amazon SPN (Service Provider Network) - We are a certified ACP service provider within Amazon's Service Provider Network (SPN), listed under the Trade Compliance category. Many international Amazon Sellers have successfully become Japan Importers of Record (IOR) through our ACP services.

Track Record – Attorney for Customs Procedures (ACP) Services

We have supported import and export operations in Japan for over 200 clients across more than 40 countries.

Examples of International Logistics Partners We Have Worked With

We have a proven track record of working with a wide range of logistics providers. As the Attorney for Customs Procedures (ACP), we handle customs-related responsibilities while logistics companies manage transportation and warehousing operations.

...and many other logistics providers in Japan and around the world.

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Our ACP Service: The Best Solution for the Japan Importer of Record (IOR) and Exporter of Record (EOR)

Attorney for Customs Procedures (ACP) is the best solution for addressing the issue of Japan IOR - Importer of Record. Below is an outline of our primary services and a diagram illustrating the operational structure of the ACP service. Upon successful ACP registration, a foreign entity can become the Japan IOR - Importer of Record.

Basic Scope of Services:

• Consultation with the Japan Customs Office for successful ACP registration.
• Liaising with stakeholders, including Logistics Forwarding Companies and the Customs Offices, on behalf of non-resident clients (i.e., non-resident Japan IOR) to ensure the secure importation of goods.
• Assistance in preparing the necessary documentation for import clearance.
• Support of calculation of Customs Value (Customs Valuation Formula), in accordance with appropriate compliance under the Japan Tariff Customs Law.
• Advance Rulings with Japan Customs, including assistance with HS classification, customs valuation, and rules of origin.
• Import support for regulated products — Domestic Administrator (sometimes referred to as “Domestic Representative”) services for Japan Product Safety Acts (PSE/PSC), and importer service for food and food-contact products (e.g., kitchenware), etc.
• Security Export Control (Classification for List Control, Examination for Catch-All Control, Application of the license to Ministry of Economy, Trade and Industry)
• Documents keeping, required under article 95 - Japan Customs Law
• Providing professional trade/customs advice if any issues arise.

**Both import and export activities can benefit from the use of an ACP (Attorney for Customs Procedures). This support is applicable in scenarios where a non-resident acts as the Importer of Record (IOR) for imports and as the Exporter of Record (EOR) for exports.

Three Steps to Initiate Shipments Under the ACP Program:

1. Quotation Review to Contract Conclusion: Upon receiving your contact details, we will promptly provide a quotation for your review.

2. Commencing the Registration of ACP (Attorney for Customs Procedures) to Japan Customs: This process is generally completed in about two weeks.

3. Initiation of First Shipment, Import/Export

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Japanese Customs System Reform: Clarification of Importer Definitions

Starting October 1, 2023, Japanese Customs has instituted a pivotal reform aimed at addressing the issue of foreign sellers improperly designating third parties (such as forwarders or customs agents) as importers.

This revision necessitates foreign corporations to utilize an Attorney for Customs Procedures (ACP) to assume the role of Importer of Record (IOR) directly in many cases. The practice of merely nominally appointing another entity as the importer is no longer feasible.

Notably, foreign corporations that act as importers themselves, through the engagement of ACP, are eligible for Japan Consumption Tax (JCT) benefits. (link: Consumption Tax Treatment and Benefits of Using ACP).

As a dedicated ACP firm, we ensure compliance with the law to facilitate correct import procedures, allowing you to trust us with your importation requirements confidently. We are eager to engage in further discussions with you.

Revisions Effective October 1, 2023:

Definition of the Importer

• Regarding a cargo imported under import transaction, an importer is equivalent to “a person who imports a cargo” defined in Article 6-1 (1), General Notification of the Customs Act. ….. This means, the Consignee, etc., in the case of imports conducted through normal transactions between an overseas seller and a Japanese buyer
• In the cases other than above, an importer is a Person Having the Right of Disposal of the import cargo at the time of import declaration. If there is another person who acts on the purpose of the import*, that person is also included:

　In case of a cargo imported:
     - under lease contracts, a person who rents and uses the cargo.
     - for consignment sales, a person who sells the cargo in the name of himself/herself (consignee) by accepting the commission.
     - for processing or repairing, a person who processes or repairs the cargo.
     - for disposal, a person who disposes the cargo.

Importer Defined as the “Person Having the Right of Disposal”

One of the most notable aspects of the amendment is the clarification that the “person having the right of disposal” is regarded as the importer under Japan Customs law. The term “right of disposal” is similar to ownership, but not identical. Although there is no explicit definition in the customs-related legislation, according to Japan Customs, it refers to the authority to decide how the goods will be handled after being released into Japan—for example, whether to sell the goods or to enter into a sales contract.

For additional information, please refer to the following resources:

• Japan Customs: Leaflet(English)  Revision of Import Declaration Items and Attorney for Customs Procedure (ACP) System
• English: Announcement from Japan Customs | Mandatory to Use ACP in Many Cases – Attorney for Customs Procedure 

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