Customs Clearance Procedures for People Living Abroad

Japan Customs Requirements for Non-Residents Exporting Goods from Japan

This article explains Japanese customs procedures for people who live outside Japan and need to export goods from Japan.

It is primarily intended for cases in which a person residing overseas purchases goods in Japan, or owns goods located in Japan, but the Japanese seller or other party involved in the transaction is unable or unwilling to act as the exporter.

This article is not intended for people moving out of Japan and shipping their household goods or unaccompanied personal effects as part of a relocation. Different customs procedures may apply to such shipments.

Can a Person Living Outside Japan Be an Exporter?

Yes. A person residing outside Japan can be involved as the exporter of goods from Japan.

However, when a person living abroad needs to carry out customs procedures in Japan, Japanese Customs generally requires that person to appoint a Customs Procedure Agent in Japan.

The Japanese term for a Customs Procedure Agent is 税関事務管理人.

Older English-language materials sometimes referred to this position as an “Attorney for Customs Procedures” or similar expressions. The terminology currently used by Japan Customs is “Customs Procedure Agent.”

When Is a Customs Procedure Agent Needed?

A Customs Procedure Agent becomes relevant when a person or company residing outside Japan needs to conduct customs-related procedures in Japan.

A typical example is the following:

A person living in the United States, Europe, Australia or another country purchases goods from a retailer in Japan. The retailer sells the goods domestically but does not provide an international export service and will not act as the exporter for an ocean or air freight shipment.

In such a case, the overseas purchaser cannot simply assume that the Japanese retailer will become the shipper/exporter for customs purposes.

If the overseas purchaser needs to act as the exporter, a Customs Procedure Agent in Japan will generally have to be appointed so that Japanese customs procedures can be carried out properly.

Typical Situations

The Customs Procedure Agent system may be relevant in situations such as the following:

• A person living overseas purchases expensive goods from a Japanese retailer that only sells domestically.
• A non-resident purchases machinery, furniture, equipment or other goods in Japan and arranges international freight independently.
• A person living overseas purchases goods from several Japanese sellers and consolidates them into one international shipment.
• A foreign company purchases goods in Japan but does not have an office or other establishment in Japan to handle customs procedures.
• A Japanese seller agrees to sell the goods but does not agree to act as the exporter or shipper for international freight purposes.

Whether a Customs Procedure Agent is necessary depends on who is acting as the exporter and how the transaction and export declaration are structured.

If a Japanese manufacturer or seller agrees to act as the exporter and arranges the export documentation in its own name, the overseas buyer would not normally need to appoint a Customs Procedure Agent merely because the buyer resides outside Japan.

The problem typically arises when the Japanese seller is only making a domestic sale and the overseas purchaser must arrange the export independently.

A Domestic Purchase Is Not Automatically an Export Transaction

This distinction is particularly important when purchasing goods from large Japanese retailers, department stores, electronics stores or online shops.

A retailer may be perfectly willing to sell an item to a foreign customer and issue a receipt or ordinary sales invoice. This does not necessarily mean that the retailer will:

• act as the exporter of record for Japanese customs purposes;
• prepare an export commercial invoice;
• provide information required for an export declaration;
• deal with a customs broker;
• respond to Customs inquiries regarding the export; or
• be shown as the shipper/exporter on international freight documents.

Therefore, before purchasing goods in Japan for international shipment, it is important to establish who will act as the exporter and whether the seller is willing to cooperate with the export procedures.

What Does a Customs Procedure Agent Do?

A Customs Procedure Agent is a person or company located in Japan who has been formally appointed to handle specified customs-related matters on behalf of a person residing outside Japan.

Depending on the authorization given, the Customs Procedure Agent may handle matters such as:

• communications with Japan Customs;
• receiving documents and notices from Customs;
• dealing with matters relating to export or import procedures;
• attending customs inspections when necessary;
• handling certain payments or refunds; and
• acting as the person in Japan through whom Customs can communicate with the overseas party.

The Customs Procedure Agent must have an address or residence in Japan. In the case of a corporation, its head office or principal office must be located in Japan.

A Customs Procedure Agent Is Not Necessarily a Customs Broker

This is an important distinction.

A Customs Procedure Agent and a licensed customs broker are not necessarily the same thing.

The Customs Procedure Agent represents the overseas person in relation to specified Japanese customs matters.

A licensed customs broker, on the other hand, is authorized under Japanese law to provide customs brokerage services professionally, including preparing and filing export or import declarations on behalf of customers.

If a Customs Procedure Agent does not hold a customs brokerage license, the Customs Procedure Agent cannot provide customs brokerage services as a business simply by virtue of being appointed as a Customs Procedure Agent.

In practice, therefore, an overseas exporter may need both:

• a Customs Procedure Agent to satisfy the requirements applicable to a non-resident conducting customs procedures in Japan; and
• a licensed customs broker to prepare and submit the actual export declaration and handle the customs clearance professionally.

In some cases, the same organization may be able to perform both functions if it meets the applicable legal requirements.

How Is a Customs Procedure Agent Appointed?

The appointment must be notified to Japan Customs in advance.

The applicable form is:

Customs Form C No.7500 – Notification on the Appointment of the Customs Procedure Agent

This is a notification procedure rather than an application for permission to become eligible to export.

Japan Customs assigns a Notification Receipt Number when the notification is accepted.

The Customs Procedure Agent system was revised in October 2023, and more detailed information regarding the relationship between the overseas person and the Customs Procedure Agent is now required.

Documents Required for the Notification

Japan Customs currently requires supporting documentation when the appointment of a Customs Procedure Agent is notified.

Documents may include:

• a power of attorney or other document showing the details of the agency arrangement;
• documents confirming the identity or existence of the overseas individual or company;
• documents confirming the identity or existence of the Customs Procedure Agent in Japan;
• a commercial or transaction flow chart explaining how the transaction is structured; and
• additional documents requested by Customs depending on the circumstances.

The exact documents required can vary depending on whether the overseas party is an individual or corporation and on the nature of the transaction.

Do Not Wait Until the Goods Are Ready to Ship

Although appointing a Customs Procedure Agent is a notification procedure rather than an export license application, the arrangements should be started well before the planned shipping date.

Time may be required to:

• determine who will legally act as the exporter;
• appoint the Customs Procedure Agent;
• prepare the necessary power of attorney and supporting documents;
• prepare a transaction flow chart;
• obtain information from the Japanese seller or manufacturer;
• appoint a licensed customs broker;
• prepare the commercial invoice and other export documents; and
• check whether the goods are subject to regulations under laws other than the Customs Act.

It is therefore advisable to investigate the customs requirements before purchasing expensive goods in Japan when the seller will not arrange international export.

A Receipt Is Not Necessarily Enough for Export Customs Clearance

Another common problem is documentation.

A domestic Japanese retailer may issue a receipt, credit-card statement, order confirmation or ordinary sales invoice. These documents may establish that the goods were purchased, but they do not necessarily contain all of the information required for international freight and export customs clearance.

Depending on the goods and the circumstances, customs clearance may require information such as:

• full name and address of the seller;
• full name and address of the purchaser/exporter;
• detailed description of the goods;
• manufacturer;
• model number;
• quantity;
• value and currency;
• country of origin; and
• other information required for tariff classification or regulatory purposes.

For certain products, additional technical specifications, catalogues, certificates, permits or approvals may also be necessary.

Some Goods Require More Than Ordinary Customs Clearance

Appointment of a Customs Procedure Agent does not mean that every product can automatically be exported from Japan.

Japanese Customs also checks compliance with other laws and regulations when applicable.

Depending on the product, additional regulations may apply to items such as:

• medical devices;
• pharmaceutical products;
• chemicals;
• food products;
• plants and animal products;
• products containing endangered species or materials regulated under CITES;
• cultural property;
• strategic goods and certain advanced technologies; and
• other controlled or restricted products.

If another Japanese law requires a permit, approval, certificate or other regulatory procedure, those requirements must generally be satisfied before Customs can permit the export.

Personal Use Does Not Necessarily Mean Personal Effects

Another frequent source of confusion is the meaning of “personal use.”

A product does not automatically become a personal-effects shipment simply because the purchaser intends to use it personally and does not intend to resell it.

For example, a person living overseas may purchase a brand-new piece of furniture, machine, electronic product or other high-value item from a Japanese retailer for use in his or her own home.

The item may be for personal use, but if it is a newly purchased product being exported as freight, it may still have to be handled as ordinary general cargo for export customs purposes.

This is different from household goods that a person has actually owned and used while residing in Japan and subsequently ships abroad as part of a relocation.

Check the Export Arrangement Before Buying

If you live outside Japan and are considering purchasing goods in Japan for shipment overseas, it is advisable to confirm the following before completing the purchase:

• Will the Japanese seller act as the exporter?
• Will the seller prepare an export commercial invoice?
• Will the seller cooperate with the customs broker if additional information is required?
• If the seller will not act as exporter, who will?
• Will a Customs Procedure Agent be required?
• Has a licensed customs broker agreed to handle the shipment?
• Are there any export restrictions applicable to the product?
• Are there import restrictions in the destination country?

Finding out after the goods have already been purchased and delivered to a warehouse that no party is prepared to act as exporter can result in substantial delays, storage charges and additional expenses.

Summary

A person living outside Japan can export goods from Japan, but when that person needs to conduct Japanese customs procedures, a Customs Procedure Agent may have to be appointed in Japan.

The Customs Procedure Agent should not be confused with a licensed customs broker. The former represents the non-resident in specified customs matters, while the latter professionally handles customs clearance procedures such as export declarations.

If a Japanese seller agrees to act as exporter and handles the export transaction, this arrangement may not be necessary for the overseas purchaser. However, if a domestic retailer simply sells the goods and does not act as exporter, the overseas purchaser should establish the customs arrangement before arranging international freight.

For this reason, people living overseas who plan to purchase expensive goods in Japan should discuss the export structure with a freight forwarder and customs broker before completing the purchase.

Reference: Customs Act Article 95; Japan Customs – Customs Procedure Agent System (Customs Form C No.7500)