Under new Japanese Customs laws and regulations effective October 1, 2023, foreign companies that import into Japan without a sales transaction generally no longer can use a separate local company to act as Importer of Record (IOR).
Responding to an apparent increase in Customs noncompliance associated with e-Commerce imports, the Japanese Customs authority has tightened the definition of IOR to bring more nonresident companies under Customs’ direct supervision. The revised definition provides new requirements for IORs. Specifically, an IOR that imports goods into Japan without a sales transaction must ‘have a right to dispose’ or ‘to act for the purpose of import.’
If the nonresident company’s current IOR no longer will qualify as the IOR under the revised IOR definition, the nonresident entity must be the IOR moving forward, requiring compliance with substantial administrative procedures.
Source PwC
