Import Business in Japan: Customs Clearance, Food and Cosmetics Rules

To import goods into Japan, you bring the cargo into a bonded area (保税地域), file an import (and duty payment) declaration with customs, pay customs duty and consumption tax, and receive import permission. For food, cosmetics and other goods, permits or notifications required under laws other than the Customs Act (other laws and regulations, 他法令) must be completed before import permission is granted. A foreign company without a base in Japan that acts as importer must also notify customs of its customs administrator (税関事務管理人).

The import clearance process

According to Japan Customs, a typical import clearance proceeds in the following order. The importer can file the declaration itself, but it is common to engage a customs broker licensed by the Minister of Finance.

Main documents for the declaration

• Commercial invoice: a document stating the description, quantity, unit price, trade terms and so on
• Bill of lading (B/L) or air waybill (AWB)
• Certificate of origin or similar (when using a tariff rate under an economic partnership agreement)
• Permits under other laws or proof that notifications have been filed

Tariff rates are determined by each item’s tariff classification (HS code). For goods whose classification is unclear, you can make an inquiry in advance under the customs advance ruling system. Imports from China may qualify for tariff rates under economic partnership agreements (EPAs) such as RCEP. To use them, the goods must meet the rules of origin, and this must be proven.

Give the customs broker the product specifications and ingredient lists before the cargo arrives. This allows tariff classification and checks under other laws to proceed in advance, making the time to release more predictable.

Taxes payable on import

The dutiable value for customs duty is, as a rule, the price of the goods plus freight and insurance to the Japanese port or airport (the CIF value).

A taxable business operator can deduct consumption tax paid on import, as an input tax credit, from the consumption tax on its domestic sales. The deduction requires retaining the import permit and other documents issued by customs. The relationship with the Qualified Invoice System (インボイス制度) for domestic transactions is explained in The Qualified Invoice System and foreign companies.

When a foreign company without a base in Japan acts as importer

The importer is the party responsible for paying taxes on the goods and complying with the law. A foreign company without a Japanese subsidiary or branch can still be the importer. In that case, it appoints an individual or company with an address or head office in Japan as its customs administrator and notifies customs in advance (Customs Act, Article 95).

• The customs administrator files import declarations, attends inspections, pays taxes, receives documents and so on.
• The notification form (Customs Form C No. 7500) also serves as the notification of a tax agent for consumption tax and related taxes.
• Under the October 2023 revisions, the form must state the administrator’s relationship with the notifying party and be accompanied by documents clarifying the terms of the mandate. At the same time, the meaning of the “person intending to import the goods”, who files the import declaration, was clarified.
• Care is needed with arrangements that declare as importer a firm that merely handles the procedures, rather than the party to the transaction that actually takes delivery of the goods. Who acts as importer should be decided according to the substance of the transaction.
• From October 2025, a provision has also been introduced allowing the Director-General of Customs to designate a related party in Japan as customs administrator where a non-resident fails to notify one.

For ongoing import and sales, also consider setting up a Japanese subsidiary or branch and acting as importer yourself. Licences such as those for cosmetics presuppose a place of business in Japan, so a domestic base is often needed once sales are taken into account. Types of base are compared in Japan branch vs Japanese subsidiary.

Rules for importing food (Food Sanitation Act)

When importing food for sale or business use, the importer must submit a notification of importation of foods to the quarantine station under Article 27 of the Food Sanitation Act. Food for which notification has not been completed cannot be sold or used in business.

• Scope: food, additives, apparatus, containers and packaging, and toys for infants
• Where to file: the quarantine station with jurisdiction over the place of customs clearance (on paper or online)
• Review: food sanitation inspectors examine whether the ingredients, manufacturing methods, additives and so on meet Japanese standards and decide whether testing is required.
• At customs, the importer presents proof of notification to obtain import permission.

Food containing additives not permitted in Japan cannot be imported. Obtain documentation on ingredients and manufacturing processes from the manufacturer and check them before importing. There are also systems that simplify the procedure for repeated imports of the same food.

At the point of sale, Japanese-language labelling under the Food Labeling Act is required. Meat products, fruit and similar goods may also be subject to animal or plant quarantine separately from the Food Sanitation Act. Importing and selling alcoholic beverages also requires a liquor sales license. For details, see Liquor sales license types and requirements.

Rules for importing cosmetics (Pharmaceuticals and Medical Devices Act)

Importing cosmetics for sale in Japan requires a business licence and notifications under the Act on Securing Quality, Efficacy and Safety of Products Including Pharmaceuticals and Medical Devices (the Pharmaceuticals and Medical Devices Act, 薬機法). Which licence is needed depends on the business model.

• A marketing licence requires systems meeting the Good Quality Practice (GQP) and Good Vigilance Practice (GVP) standards, with designated responsible persons.
• A cosmetics marketing notification must be filed for each product before sale. For imported products, a notification concerning the foreign manufacturer must also be filed first.
• Ingredients must comply with the Standards for Cosmetics (prohibited and restricted ingredients), and a full ingredient list in Japanese is required.

Even when importing products already labelled in Japanese, they must pass through a storage site holding a domestic manufacturing licence, and the marketing licence holder must check their quality and make the shipment release decision. Check the specific procedure in the guidance of the prefectural pharmaceutical affairs division. Quasi-drugs (医薬部外品) that claim effects such as skin whitening or hair growth require approval for each product.

Other key rules and the order of preparation

Goods that infringe intellectual property, such as counterfeit branded goods, are prohibited imports under the Customs Act. If you plan to sell your own brand in Japan, also check your trademark rights in advance.

Under the Product Liability Act, a business that imports products is liable for damage caused by defects in the same way as the manufacturer. Check the quality assurance and indemnity clauses in your contracts with overseas manufacturers, and consider taking out insurance.

Following the order below reduces rework.

1. Identify the tariff classification of the goods and the relevant laws
2. Determine the business licences and notifications required, and the domestic base and staff needed for them
3. Collect ingredient lists, manufacturing process information and other documentation from the manufacturer
4. Sign a contract with a customs broker and confirm the schedule and costs on the first import

Licences involve a review period. If import and sale are not included in the business purposes in your articles of incorporation, these must also be amended. Plan backwards from your target sales launch date.

How TIMOA can help

In an import business, besides customs clearance and taxes, the permits and notifications required under different laws for each product must all be in place before sales begin. For a foreign company, who will act as importer is another issue to settle at the outset.

In cooperation with partner administrative scriveners, customs brokers and certified tax accountants, TIMOA coordinates everything from setting up the importer structure and obtaining food and cosmetics permits and notifications to tax matters, including consumption tax on imports. For details of our services, see Permits & Financial Licenses.