Why Amazon Cannot Be Your “Importer of Record” in Japan
A common misconception among Amazon FBA sellers expanding into Japan is the belief that Amazon can act as their Importer of Record.
The term “Importer of Record” is widely used in global trade. However, Japan does not formally recognize IOR as a single legal designation in the way some other countries do. In practice, what overseas sellers refer to as an Importer of Record in Japan typically involves a structured combination of responsibilities. This often includes the appointment of an Attorney for Customs Procedures for import declarations, and in regulated categories such as cosmetics or medical devices, a licensed entity such as a Marketing Authorization Holder.
Understanding this distinction is critical before shipping inventory into Japan.
Amazon Does Not Assume Import Responsibility
Amazon Japan operates as a marketplace and fulfillment provider. It does not assume customs liability for third-party sellers’ goods. Listing Amazon as the Importer of Record on shipping documentation is not compliant with Japanese customs practice.
When inventory is shipped to Japan under Amazon FBA, customs documentation must accurately reflect the responsible importing party and, where required, the appointed Attorney for Customs Procedures. For regulated products, the appropriate licensed entity must also be in place before import.
If Amazon is incorrectly designated as the importer, shipments are typically halted at customs clearance. This issue often becomes visible only once the goods have arrived in Japan.
What Happens When the Structure Is Incorrect
When importer information does not align with Japan’s customs framework, clearance is suspended. Sellers then receive urgent notifications that their goods cannot be processed due to improper designation.
At that stage, storage windows are limited. Additional fees may accrue. In some cases, inventory must be returned to origin, disrupting launch timelines and increasing cost.
This scenario is common among sellers who rely on overseas freight providers unfamiliar with Japan’s import structure. Documentation may appear acceptable at origin, only to be rejected upon arrival.
The issue is not the marketplace. It is the absence of a properly structured import framework.
Understanding the Combination of ACP and Licensed Entities
For foreign sellers without a Japanese legal entity, an Attorney for Customs Procedures must be appointed to act as the representative for customs declarations. The foreign seller remains responsible for accurate product classification, valuation, and compliance.
In regulated categories, additional licensing obligations apply. For example, cosmetics and medical devices require a Marketing Authorization Holder before import. In these cases, what overseas sellers would call an “Importer of Record” effectively becomes a coordinated structure between customs representation and regulatory licensing.
This combined structure must be defined before goods depart origin.
Market Entry Requires Proper Import Architecture
Before shipping inventory to Amazon Japan, foreign sellers should confirm:
- Who is legally responsible for the import declaration
- Whether an Attorney for Customs Procedures has been properly appointed
- Whether a licensed entity such as an MAH is required for the product category
- That product classification, valuation, and claims comply with Japanese regulations
Amazon can distribute your products. It cannot replace your import and compliance structure.
Entering Japan through Amazon requires more than marketplace registration.
Your import structure must be clearly defined, including customs representation and, where required, regulatory licensing. Establishing this framework before shipment protects your inventory, timeline, and brand credibility.
This article was originally posted on September 18, 2023, and updated with recent information on January 20, 2025.
