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Japan ACP

Japan Attorney for Customs Procedure (ACP) is specific to foreign eCommerce sellers. 
For non-regulated products, you only need an ACP for import. However, regulated products will require an organization in Japan with the required licenses.

Most Japan ACPs are limited in scope to the ACP procedure only. This also limits our competition’s expertise. COVUE is direct license holder for the broadest range of product imports in Japan. We know compliance better than anyone.

Japan ACP is required for all eCommerce products. 
Non-regulated products don’t need extra licenses, however, regulated products will require an organization in Japan with the required licenses.

COVUE is licensed for Medical devices, Pharmaceuticals, Quasi-drugs, Supplements, Food, Food Apparatus, Industrial Salts & Fertilizers, Cosmetics & Personal Care, and Electronics.
Our licenses extend far beyond importing and include, Manufacturing, Sales & Marketing, Marketing Authorization Holder (MAH), Repair & Installation, Product Recalls, Call Center Support, Tax Representation and Japan Register Invoice issuance.

Non-regulated

No. Customs clearance is a procedure. To perform this procedure, the person or company handling your customs clearance will require the IOR’s approved documentation (COVUE Shipping Invoice).

COVUE can preform customs clearance when COVUE is the Japan IOR. This procedure can only be performed when COVUE takes over the Japan Inbound Logistics, known as JIL (Japan Port – Customs Clearance – Last Mile Delivery).

Yes. You may use your current shipping company.

Yes. COVUE partners with many international shipping providers to support Door-to-Door services which can integrate with our IOR and Customs Clearance services. We provide a single source solution of Japan import and delivery.

Certain non-regulated products like textiles, clothing will require a product label for sale in orde3r to be compliant with the Household Goods Quality Labelling Act of Japan (Consumer Affairs). 

If you are selling your products across e-Commerce channels and marketplaces, you are required to follow Japan Consumer Affairs labelling regulations.

Japan has many rules and regulations when selling products in Japan. Example: Mattresses, infant clothing, general clothing and wood products require specific product labelling under Japan Consumer Affairs.

If discovered by Japan Consumer Affairs, your IOR will be notified. A product label will need to be applied immediately. Failure to comply will result in financial penalties. Repeated notifications will result in your product being removed from the Japan market. To avoid issues, COVUE ensures full compliance before shipping your products.

Taxes

Your Shipping Invoice will reflect your online selling price. A Foreign Online Sellers Report (FOSR), which reflects your online sales pricing, will be included with your shipping invoice.

Japan Customs will verify your report against your actual account listings.

Example:

Your Shipping Invoice will reflect in coterms DDP.

SKU 1234

Unit Price: 1000 JPY

Qty: 10

Total: 10,000

Subtotal: 10,000 

FOSR will reflect Online Sales Listing Pricing (must match your Shipping invoice)

COVUE will handle your inbound Japan logistics (JIL) = Port pick up, customs clearance, last mile delivery. COVUE will bill you for this service including the tax payment (1000).

Note: This is also the same if COVUE is handling the Door-to-Door shipping, pick up home country location, and JIL.

At customs clearance, COVUE will pay 10 tax (1,000 JPY) on behalf of your company to Japan Tax during customs clearance.

14 days after receiving clearance, an official receipt is issued for the tax payment by Japan Customs.  This document is uploaded to your COVUE account in MY FILES.

For product pricing to your retailer, your Sales Invoice will specify “includes 10% Japan Consumption Tax (JCT)” 

Example:

SKU 1234

Unit Price: 1000 JPY

Qty: 10

Total: 10,000

Subtotal: 10,000

JCT 10%: 1,000

Total: 11,000

Your distributor will transfer 11,000 to you for payment.

Your Shipping Invoice will reflect in coterms DDP.

SKU 1234 

Unit Price: 1000 JPY 

Qty: 10

Total: 10,000

Subtotal: 10,000 

COVUE will handle your inbound Japan logistics (JIL) = Port pick up, customs clearance, last mile delivery. We will bill you for this service including the tax payment (1000).

Note: This is also the same if COVUE is handling the Door-to-Door shipping, pick up home country location, and JIL.

At customs clearance, COVUE will pay 1,000 JPY on behalf of your company to Japan Tax during customs clearance.

14 days after receiving clearance, an official receipt is issued for the tax payment by Japan Customs.

This document is uploaded to your COVUE account in MY FILES.

You can email a copy of this document to your distributor. They can use this document with their sales invoice to claim back the tax paid.

If you have a single distributor (or same distributor), and will be holding stock, the JCT will be paid at customs clearance based on the contract agreement or pricing agreement with your distributor.

If you have more than one distributor with multiple pricing models, COVUE will work with Japan Tax and Customs Clearance to establish an Average Transfer Price base on the actual distributor pricing agreements. This will be the official import declaration. The same receipts will be issued and the distributor will use this receipt and their Sales invoice to claim back the actual JCT Tax paid to you.

Cosmetics & Personal Care

No. If you wish to add more products after receiving approval, you will need to submit a new application to the PMDA (Pharmaceuticals and Medical Devices Agency).

We advise you to include all products in the first import application.

No. As part of the application process it is required to send two samples of each parent product to COVUE. General lab testing is included with your application and covers 99% of all testing requirements.

On rare occasions, the PMDA can request for special testing of a product outside of the normal testing parameters. Please note that such special testing includes additional charges.

No. Japan law requires regulated products to be received at the location of registration for Incoming Quality Control (IQC) inspections. This includes compliance label verification and random lab testing.

There is no additional fee for lab testing. COVUE will only charge a fee for label application.

Medical Device

Yes. If the distributor is licensed, they may perform the import notification. However, the distributor will control your product’s import rights.

Yes. For most PMDA requirements, ISO 9001:13485 is required or highly advised to receive approval.
No. Japan approval is not related to other countries.
Yes. Most products will require one or more OEM post-sale compliance services. Examples: Customer Care, Adverse reporting call center, installation, field service, deport repair, parts logistics, preventive maintenance services.
Shelf Stable Food

Due to unfortunate events and deaths from imported milk products in the past, Japan has strict rules and regulations for milk and powdered milk as a food or ingredient. When using milk as an ingredient, Japan will seek additional information about your manufacturer including company name, source of milk, manufacturing flow process, etc.

Failure to provide the information will result in the rejection of the product or application.

Yes. We partner with local manufacturers to finish or produce products locally. We extend our license over the producer. Our teams actively manage the entire quality and product process. This includes any plant refitting, enhancement or modification.
Lab Testing
You may submit internal testing data with your import application. However, this will not prevent MHLW testing at customs.

We are unable to share these as MHLW has not released this information. 

This is the detailed process from harvest to final product. It includes every step and parameters for completing the product. Example: A photo to confirm stems and seed. Also, heating, extracting and filter information.

It will be classified as an illegal drug shipment and cannot be recovered. You may face penalties and can also be blocked from the Japan market.

Electronics (Japan Radio)

No. The certification is actually a license issued to the manufacturer (Plant specific). The product will be pulled from the market or blocked from import if there is no certification.

No. The certification/license completes the process. You will only need an Importer of Record, ACP or Distributor for importing.
Any product that emits a radio wave is required to comply with Japan Radio. Examples: GPS location, mobile devices using cellular signals, Bluetooth, WIFI, hotspot, radio communication devices (drones, radio-controlled toys).

Products that only received signals do not require Japan Radio. Example: A GPS map device that only receives a GPS signal.

Electronics (PSE)

Japan METI requires the part or component subject to PSE to be tested before being sold in the Japanese market. The parameters are determined by METI at the time of application. The testing can be completed by the manufacturer or PSE IOR (COVUE).

Yes, there are some ways to avoid PSE requirements.

  1. Do not include the wall charger with the product. Include only a USB cable. This will avoid PSE requirements.
  2. If the LI battery is accessible to the user, change the design to make the LI battery not accessible.
  3. Source your wall charger or LI battery within Japan.

The Japan PSE IOR’s information and the PSE mark.

The test results must be provided to the Japan PSE IOR. The documents must be kept on file for a period of 5 years.
Yes, however, the products cannot be transferred to any Japan 3PL/FBA without testing data and customs clearance.
If you are holding title to the product for e-commerce sales, you are required to provide a Japanese product label.
Your distributor can perform the PSE testing if they are qualified. Your distributor can hire a qualified PSE testing company to perform the testing. The distributor will be responsible for maintaining the testing data.

No, METI will require a new application for the product. It is better to register all your available products in the application even if you are not shipping some of those products now.

Food Apparatus

Food apparatuses (or food contact materials) such as utensils, dishes, packaging, etc. must comply with the Food Sanitation Act (FSA), implemented by the Ministry of Health, Labor and Welfare (MHLW).

This includes compliance with regulations regarding material composition, the potential for toxic substance leaching, and more.

Baby Products & Toys

No. Stainless steel, glass porcelain and other similar materials usually do not require material testing.

However, MHLW reserves the right to require lab testing for any reason.

Yes. MHLW requires an application and approval for every shipment. COVUE is able to replicate applications for follow-up shipments on prior approved products. COVUE does not charge an application fee for application replication. 

Food/Food Supplement

COVUE provides product pre-checks prior to opening an import application. 

Japan has strict rules for packaging claims. Example: You cannot claim a product prevents heart attack or anti aging. COVUE can assist with product claim localization to ensure your product is fully compliant.

Japan has strict rules for pill shape, color and size to ensure consumers do not mistakenly take the wrong product. If your product was rejected because of the size, shape or color, the product will need to be modified to comply with Japan regulations. COVUE can support any size, shape or color modification.
Yes. We partner with local manufacturers to finish or produce products locally. We extend our license to the producer. Our teams actively manage the entire quality and product process. This includes any plant refitting, enhancement or modification. We partner with SMEs’ supporting local communities facing economic challenges.

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