A regulatory storm is brewing over cross-border e-commerce, with Japan's customs authorities preparing to implement sweeping changes that could fundamentally alter how goods are imported and taxed. Starting October 12, 2025, Japan will enforce new regulations requiring precise tracking of every e-commerce shipment entering the country, potentially rendering current tax avoidance practices obsolete.
Policy Background: Closing Regulatory Loopholes
The upcoming measures represent a significant enhancement to Japan's existing "ACP+JCT" declaration system, first implemented on October 1, 2023. The system requires:
- JCT (Japanese Consumption Tax) numbers for valid invoicing
- ACP (Customs Procedure Agent) designation showing importer details
While designed to combat tax evasion and regulate import flows, many Chinese logistics companies circumvented these requirements through:
- Under-declaration of values
- Misclassification of goods
- Fixed-tax schemes
The new policy aims to strengthen oversight by implementing full supply chain visibility for all imported goods.
Key Policy Components: Tracking Goods Movement
The regulations introduce three critical reporting requirements:
1. Final Destination Reporting
Importers must declare:
- The ultimate domestic destination of goods
- Recipient names (including individuals)
- Special reporting for multiple destinations within single shipments
2. E-Commerce Goods Declaration
All imports must be classified as:
- E-commerce goods (including B2B transactions)
- FBA (Fulfillment by Amazon) goods
- Other goods
3. Platform Identification
For e-commerce goods, importers must specify:
- Marketplace names (Amazon, Rakuten, etc.)
- Independent website URLs for direct-to-consumer sales
- Seller names when platform details are unavailable
Potential Industry Impacts
1. Overseas Warehouse Operations Face Overhaul
The policy particularly targets fulfillment centers that:
- Receive bulk shipments for relabeling
- Serve multiple FBA accounts
- Operate as nominal importers
Warehouses handling disproportionate volumes will likely face increased scrutiny, forcing operators to either consolidate client bases or implement costly distribution networks.
2. Fixed-Tax Schemes Under Threat
Current tax minimization strategies including:
- Value under-declaration
- Mixed classification
- Shell importers
will become increasingly risky as customs gains visibility into final destinations and importer patterns.
3. Compliance Becomes Mandatory
The phased implementation of:
- Reverse calculation methods
- JCT+ACP requirements
- Destination tracking
signals Japan's determination to enforce proper taxation. Larger sellers must establish local entities, while smaller operators face rising compliance costs.
Outstanding Questions
1. Consequences of Misclassification
Labeling e-commerce goods as "other" may trigger:
- Increased importer audits
- Penalties for discrepancies
2. Air Freight Implications
The policy likely extends to small parcels, potentially accelerating:
- Duty-free exemption removal
- Stricter commercial shipment controls
3. General Trade Loopholes
Goods cleared as general trade but later sold online may require:
- Multi-layer distribution
- Complex paper trails
to avoid detection, significantly increasing operational complexity.