Question 1: What kind of method shall be applied to the calculation of the Customs Value of the import goods?

The "Transaction Value Based Method (Actually paid or payable + Additional costs)" under the Japan Customs Tariff Law is the primary method that should be initially considered for application.

Please bear in mind that the Invoice Value is not always equal to the Customs Value.

This Primary method is to calculate the Customs Value based on the "Value of the Import Transaction".

The definition of "Value of the Import Transaction" is that, when the import transaction of the import goods has made, the price actually paid or payable regarding the import transaction by the buyer to or for the benefit of the seller for the import goods, and adjusted by certain additional costs such as transportation costs, to the extent that such costs have not been included in the price actually paid or payable for the imported goods.

 

Customs value  ＝  Transaction value  ＝  Actually paid or payable※1  ＋  Additional costs※2

※1： The price actually paid or payable is the total payment made or to be made by the buyer to or for the benefit of the seller for the imported goods. It includes a settlement by the buyer whether in whole or in part, of a debt owed by the seller and other indirect
payment for the seller by the buyer. In principle, the price actually paid or payable shall not include the following charges or costs, provided that they are distinguished from the price actually paid or payable for the imported goods:
1) Charges for construction, erection, assembly, maintenance or technical assistance is undertaken after importation of the imported goods;
2) Transportation costs after importation;
3) Duties and taxes imposed on the imported goods in Japan.
However, if the price actually paid or payable will not be able to be grasped by the whole amount including the above costs, then it shall be the total amount including such costs.

※2：For instance, transportation fee and insurance fee (CIF basis), commissions, etc.

In case of calculating the Customs value based on the transaction value, the calculation of the customs value should be based on invoice and other documents which are able to verify the price actually paid or payable of the imported goods and to be adjusted certain additional costs such as the transportation costs.

 

You can check what is the "Import Transaction" in Question 2.

 

Q&A for Customs Valuation

Q1 - Primary Method of Customs Valuation

Q2 - "Import Transaction" in Customs Valuation

Q3 - Identical or Similar Goods Value Method for Customs Valuation

Q4 - Deductive Value Method for Customs Valuation

Q5 - Computed Value Method for Customs Valuation

Q6 - Fall-Back Method for Customs Valuation

Q7 - Customs Valuation Method for E-Commerce Goods

 

 

 

Reference: Customs Tariff Law, Japan Customs

Japan Customs: Customs Valuation System

Japan Customs: Details of Japan Customs Valuation System

 

FTA/EPA, Customs and International Trade Advisory Services

ACP Service for Importer of Record (IOR)

ACP Service for Exporter of Record (EOR)

Customs Audit Support

Customs Support for Transfer Pricing Adjustments

 

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 - Led by our CEO, Mr. Sawada—Certified Customs Specialist and former KPMG professional—SK Advisory provides expert-level support in Customs and international trade.
  • Full Compliance with Japanese Customs Law - We ensure full adherence to Japanese Customs Law, including Importer of Record (IOR) structure, HS code classification, and customs valuation. We assist in preparing all essential shipping documents for non-resident entities.
  • One-Stop Support for ACP and JCT Tax Representative Services - In collaboration with trusted partner tax accountants, we provide comprehensive support for both customs procedures through the Attorney for Customs Procedures (ACP) and Japan Consumption Tax (JCT) filings through the JCT Tax Representative.
  • Multilingual Communication - Our team communicates fluently in English, Japanese, and Chinese, offering smooth coordination with global clients and authorities in Japan.
  • Support for Regulated Products - Our ACP/IOR partnership system can manage regulated items, including cosmetics, PSE-products, foodstuffs, and tableware.
  • Trusted by Global Clients - Serving around 100 ACP clients annually, including many Amazon sellers, we’re a certified provider on Amazon SPN (Service Provider Network) under Trade Compliance.

     

 

 

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.

  • Apex International
  • Brink's
  • CEVA Logistics
  • Crane Worldwide Logistics
  • DB Shenker
  • DGX（Dependable Global Express）
  • DHL Express
  • DHL Global Forwarding
  • Dimerco
  • DSV Air & Sea
  • Expeditors
  • FedEx Express
  • FERCAM
  • Harumigumi
  • Herport
  • ICL Logistics
  • JAS Forwarding
  • Kintetsu Express
  • Kokusai Express
  • Kuehne + Nagel
  • Mitsubishi Logistics
  • MOL Logistics
  • Nankai Express
  • Nippon Express
  • OIA Global
  • PGS
  • Rhenus Group
  • Röhlig
  • Sankyu
  • Sanyo Logistics
  • Scan Global Logistics
  • Seino Schenker
  • SEKO Logistics
  • Shin-Ei gumi
  • Sumitomo Warehouse
  • UPS
  • UPS Supply Chain Solutions
  • Yamato Transport

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

 

 

 

 

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:

 

 

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

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.
  • 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 Procedure) to Japan Customs: This process is generally completed in about two weeks.
  3. Initiation of First Shipment, Import/Export