Success Story: Exporting from Japan Using ACP - Attorney for Customs Procedures

Overview

Case Study - Exporting Returns and Unsold Goods

Client Profile:

A German automotive parts manufacturer.

Situation:

After shipping goods to Japan, the client discovered that the Japanese buyer had gone bankrupt, necessitating the return of the shipment to Germany. Foreign corporations without a presence in Japan are not permitted to act as exporters, posing a significant challenge.

Our Approach:

SK Advisory Inc has a proven track record of supporting many foreign corporations with their exports as a professional ACP - Attorney for Customs Procedures. Upon receiving the client’s inquiry, we swiftly finalized the contract. We then initiated the ACP registration process, completing it within approximately one week. We also arranged for an authorized customs broker (DB Schenker) to prepare for the export clearance.

While processing the ACP registration, we prepared the necessary export documents, including invoices and packing lists. Additionally, we took responsibility for the security trade control (export control) procedures, issuing a classification document. After preparing the documents, we coordinated with Schenker for a final review and completed the export declaration.

Outcome:

We have a flawless success rate in completing exports as an ACP. The initial export may take 1-2 weeks due to the ACP registration, but subsequent exports proceed smoothly. It is important to note that security trade control (export control) procedures are required for exports, but our well-established export management system allows us to act on behalf of foreign corporations effectively.

Sending items that have already been imported into Japan (i.e., those removed from a bonded area) overseas is classified as "export." Dispatching items still stored in a bonded area overseas is termed "re-shipment." In both scenarios, foreign corporations can act as exporters or re-shippers by utilizing an Attorney for Customs Procedures (ACP).

In some cases, we can also explore the possibility of import consumption tax refunds in collaboration with our partner tax accounting firms.

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

ACP is an effective solution for addressing Importer of Record (IOR) and Exporter of Record (EOR) requirements in Japan. Through our ACP service, non-resident entities located outside Japan are able to import and export goods as Non-Resident IOR and EOR.

Below is an overview of our basic scope of work, together with a diagram illustrating the operational structure of the ACP service. Once ACP registration is completed, the non-resident entity can act as the Importer of Record (IOR) and Exporter of Record (EOR) in Japan.

Scope of Work – How We Can Assist

• Preparation and filing of all required documents for ACP registration with Japan Customs.
• Coordination and communication with relevant stakeholders, including Japan Customs, logistics providers, and customs brokers to ensure the smooth and compliant import and export procedures.
• Preparation and review of import documentation, including commercial invoices and shipping documents.
  _{^{*Proper customs clearance requires accurate identification of the shipper, consignee / Exporter of Record (EOR), and Importer of Record (IOR) on B/L, AWB, and invoices. We provide practical guidance on correct documentation practices. We also advise on customs valuation (import declaration value) and its supporting documentation, HS classification, and country of origin to ensure compliance with Japanese customs requirements.}}
• Advisory on customs valuation (import declaration value), HS codes, duty rates, and origin (including advance rulings).
• Import compliance support for regulated products, including Domestic Administrator (sometimes referred to as “Domestic Representative”) Services under the Product Safety Acts (PSE/PSC) and food-related products regulated under the Food Sanitation Act.
• Support for security export control, including list-based classification, catch-all control assessment, and assistance with export license applications to the Ministry of Economy, Trade and Industry (METI).
• Maintenance and retention of records required under the Japan Customs Law.
• Provision of professional trade and customs advisory services to address and resolve issues that may arise during import or export operations.

**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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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. Mr. Sawada also serves as an external expert for the World Bank’s B-READY project in the field of 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.

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

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