When Do You Need a Licensed Importer or Local Representative in Japan?

Imagine your products are sitting at a Japanese port. You have spent thousands of dollars on shipping. Suddenly, customs officials stop everything. They ask for your “Licensed Importer.” You don’t have one. What happens next?

Many businesses see Japan as a massive opportunity. However, its import laws can feel like a maze. The most important rule is simple: Every shipment must have a Japanese entity responsible for it. You cannot just “ship and hope” for the best.

This is where the “Gatekeeper” comes in. Japan requires a local person or company to stand behind your goods. This article will help you understand the difference between a shipping partner and a legal representative. You will learn how to avoid seized goods and costly delays.

The Legal Requirement: Why You Can’t Just “Ship and Sell”

Many businesses believe shipping to Japan is like shipping to Europe or the US. It isn’t. In Japan, the law is very specific about who “owns” the risk.

The Importer of Record (IOR) Requirement

In most countries, a foreign company can be the importer. In Japan, you generally cannot. To import goods, you must have a physical presence or a registered office in Japan.

Recent changes in 2023 made this even stricter. You can no longer just use a friend’s company name as a “nominal” importer. If you don’t have a local office, you are legally stuck at the border.

The Japan Customs Act and the ACP

If you don’t have a Japanese office, you need an Attorney for Customs Procedures (ACP). Under Article 95 of the Customs Law, an ACP is a local person or company that acts for you.

They don’t “own” your goods. They just handle the paperwork and talk to customs. Think of them as your legal voice in Japan. Without an ACP, a non-resident cannot pay duties or clear shipments legally.

The Product Liability (PL) Act

Japan takes consumer safety very seriously. The Product Liability (PL) Act says the importer is responsible if a product hurts someone.

Because of this, the government wants someone in Japan they can talk to if something goes wrong. If your product has a defect, the local importer is the one held accountable. This protection for Japanese citizens is a core reason why the “Gatekeeper” system exists.

When a Licensed Importer is Mandatory (Regulated Goods)

Shipping simple items like clothes is relatively easy. However, if your products touch the skin, are eaten, or plug into a wall, Japan’s “Gatekeeper” rules become much stricter. For these “regulated goods,” you don’t just need an agent; you need a licensed partner.

Pharmaceuticals & Medical Devices (PMDA)

If you sell medical tools or health supplements, you must navigate the PMDA. Foreign brands cannot register these products alone. You must appoint a Marketing Authorization Holder (MAH) or a Designated MAH (D-MAH).

• The MAH takes full legal responsibility for your product’s safety.
• The D-MAH allows you to “own” the product license while they handle the local compliance and inspections.

Cosmetics & Quasi-Drugs

Japan treats cosmetics differently than the US or EU. Even a simple face cream requires a licensed importer who holds two specific licenses: a Manufacturing License and a Marketing License.

• They must check every ingredient against Japan’s “negative list.”
• They ensure your labels are translated accurately into Japanese.
• In 2026, the scrutiny on “Quasi-Drugs” (like medicated whitening creams) is higher than ever.

Electronics (METI & PSE Mark)

Most electronics must follow the Electrical Appliances and Materials Safety Act. To sell these, your product needs a PSE Mark.

• As of 2026, new rules require foreign sellers to appoint a “Japan-based Domestic Manager.” * This person must be a resident of Japan. They act as the point of contact for METI (the Ministry of Economy, Trade and Industry) if your product causes a fire or safety issue.

Food & Kitchenware

Under the Food Sanitation Act, every food shipment requires an import notification.

• Important for 2026: Japan has fully implemented the “Positive List System” for food containers and kitchenware.
• If your spatulas or lunchboxes use plastic, the materials must be on the approved list. A local representative helps you verify these technical specs before your shipment is rejected at the docks.

When a Local Representative is Recommended (E-commerce & B2B)

Even if your products aren’t strictly regulated, a local representative is often the difference between a successful launch and a quiet failure. In Japan, business is built on trust and commitment.

Selling on Amazon Japan (FBA)

If you use Fulfillment by Amazon (FBA) in Japan, Amazon will not act as your Importer of Record (IOR). This is a common trap for new sellers.

• To send stock to a Japanese warehouse, someone in Japan must sign for the shipment and pay the duties.
• As of 2026, Amazon and other large platforms are now required to collect and remit Japanese Consumption Tax (JCT) for certain sellers.
• To manage this properly and claim back the tax you pay at the border, you need an Attorney for Customs Procedures (ACP) or a fiscal representative.

Tax Compliance and the 2026 Reform

The tax landscape in Japan is changing rapidly. The government has tightened the rules on the Qualified Invoice System.

• If you sell to Japanese businesses, they will likely demand a JCT-compliant invoice so they can claim tax credits.
• Without a local tax representative (known as a Nouzei Kanrinin), it is nearly impossible for an overseas company to navigate these filings accurately.
• Having a representative ensures you don’t overpay tax at the border while keeping your Japanese customers happy.

B2B Trust and “Local Commitment”

Japanese B2B buyers are famous for their caution. They often avoid dealing directly with foreign entities because of language barriers and fears about after-sales support.

• A local representative acts as your “face” in Japan.
• They provide a local contact number and address, which signals that you are here for the long term.
• In the B2B world, having a local partner is seen as a badge of reliability. It turns a “risky” foreign purchase into a “safe” local transaction.

Key Roles Defined: Which One Do You Need?

Choosing the right partner depends on your business model and the type of goods you sell. Here is a simple breakdown of the three most common roles.

Importer of Record (IOR)

The IOR is the “official” face of your shipment.

• Role: They are legally responsible for all duties, taxes, and compliance at the point of entry.
• Who it’s for: Companies that have a Japanese branch or a local partner willing to take on full legal liability for the goods.
• Note: Since 2023, you cannot simply use a third party’s name as a “favor.” The IOR must be a legitimate business entity in Japan.

Attorney for Customs Procedures (ACP)

The ACP is your legal proxy in Japan.

• Role: They handle the paperwork and talk to customs so you don’t have to. Unlike an IOR, the ACP does not take ownership of the goods.
• The Advantage: By using an ACP, you (the foreign company) remain the “owner” of the goods. This is crucial for JCT (Japanese Consumption Tax). If you use a regular IOR service, you often cannot claim back the 10% tax you pay at the border. With an ACP, you can.
• Who it’s for: E-commerce sellers and B2B exporters who want to maintain control and optimize their taxes.

D-MAH (Designated Marketing Authorization Holder)

This is a specialized role for medical and beauty brands.

• Role: A D-MAH handles the strict safety and quality checks required by the PMDA.
• The Advantage: If you use your distributor as your MAH, they own your product license. If you break up with that distributor, you lose your license! A D-MAH allows you to keep the license while they handle the compliance.
• Who it’s for: Anyone selling cosmetics, medical devices, or pharmaceuticals who wants to protect their brand’s future.

Bridging the Gap with Kizunax: Your Local Partner in Japan

Entering the Japanese market doesn’t have to be a multi-year struggle. While the regulations are strict, they are also predictable. The challenge is often the language and cultural “gap” that separates international brands from Japanese authorities.

Who is Kizunax?

Kizunax is a premier local representative and compliance partner designed to be your “boots on the ground” in Japan. Think of them as your strategic bridge. They help international companies navigate the complex world of Japanese business without the massive overhead of a traditional office.

Comprehensive Services Provided

Kizunax simplifies the entry process by managing the heavy lifting of compliance. Their services include:

• IOR/ACP Support: Navigating the “Non-Resident Importer” rules so your goods clear customs without a hitch.
• Regulatory Filings: From checking food ingredients to managing PSE mark documentation for electronics.
• Strategic Matching: Connecting you with the right local distributors who actually understand your product’s value.

The Kizunax Advantage

What makes Kizunax different? It is their mastery of “Gengo” (local nuances).

• Cultural Translation: They don’t just translate words; they translate the intent and expectations of the Japanese market.
• Cost-Effective: Establishing a physical branch office in Tokyo can cost tens of thousands of dollars. Kizunax offers a lean, agile alternative that provides the same legal and operational benefits.
• Seamless Communication: They act as a single point of contact between your global team and Japanese customs, ensuring nothing gets lost in translation.

Checklist: Do You Need a Representative?

Not sure if you need a local partner yet? Use this quick checklist to evaluate your current situation. In 2026, Japan’s customs and tax authorities are more vigilant than ever, making compliance a “must-have” rather than a “nice-to-have.”

• [ ] Are you selling regulated goods? (Examples: Cosmetics, supplements, electronics, toys, or anything that comes into contact with food).
• [ ] Are you shipping to an Amazon FBA warehouse? Amazon will not act as your importer; you must have a local entity to sign for the stock.
• [ ] Do you lack a registered physical office in Japan? Without a local address, you cannot legally act as the Importer of Record.
• [ ] Do you need to issue JCT-compliant invoices? To provide tax-deductible invoices to Japanese business customers, you need a local tax representative.
• [ ] Is your shipment value over JPY 10,000? With the 2026 tax reforms, almost all commercial shipments now require formal tax handling and duty payments.

The Verdict: If you checked any of these boxes, you require a partner like Kizunax. Attempting to bypass these requirements often leads to seized shipments, permanent bans from platforms, and heavy legal fines.

Conclusion: Securing Your Japan Entry

Japan is a rewarding market, but it does not forgive shortcuts. As of 2026, customs enforcement is stricter than ever. Ignoring the “Gatekeeper” rules can lead to seized shipments, heavy fines, or even a permanent ban from the market.

Choosing a local representative isn’t just a legal box to check it’s an investment in your brand’s longevity. By securing the right partnership, you ensure your products move smoothly from the port to the customer’s hands.

Contact Kizunax for a Compliance Audit . Don’t let your Japanese expansion stall at the border. Whether you are shipping electronics, cosmetics, or selling on Amazon, the rules are complex and changing.