Japan: Customs scrutiny of certificates of origin | KPMG | GLOBAL
Share with your friends

Japan: Customs scrutiny of certificates of origin from exporters, manufacturers

Japan: Customs scrutiny of certificates of origin

The Japanese Commerce office in October 2016 published a notice directed towards the Japanese manufacturing and export community, and emphasizing the importance of accurately qualifying products under “economic partnership agreements” and of obtaining certificates of origin. In Japan, exporters and producers must formally request a determination of originating goods and then submit an application for issuance of a certificate of origin from the Commerce office (unless a company is approved for self-certification under certain economic partnership agreements).


Related content

In the notice, the Japanese Commerce office (at times, referred to in English as the “Chamber of Commerce”) inferred that, in certain instances, certificates of origins may previously have been issued to Japanese exporters and producers despite the goods not actually qualifying as originating under the specific economic partnership agreements. The Commerce office further indicated that such inaccurate economic partnership agreement claims may lead to customs authorities in other countries to seek to collect duties owed and possibly to impose penalties for the underpayment of duties. In turn, this could result in customs clearance delays and additional scrutiny by customs authorities in the beneficiary importing country.

Certificates of origin

The development indicates that Japanese Customs may focus with greater scrutiny on certificates of origin of exporters and manufacturers in Japan. To help avoid these complications, the notice from Japan’s Commerce office re-iterated certain essential criteria for adhering to the qualification and other applicable requirements under economic partnership agreements, including but not limited to:

  • Confirming locations of production facilities: To qualify as a Japanese originating product, goods must undergo significant production or processing operations (if not wholly obtained).
  • Supporting economic partnership agreement claims: Exporters and producers must maintain records supporting the economic partnership agreement claim for a period of time (three to five years depending on the economic partnership agreement).
  • Evaluating changes in circumstances: For companies that use economic partnership agreements continuously for the same products, origin qualifications need to be revalidated each time there is a change to any of the elements evaluated for qualification purposes, particularly any changes to production locations and processes. For each revalidation conducted, a new request for a certificate of origin must be made.


For more information, contact a professional with KPMG’s Trade & Customs practice:

Masaharu Umetsuji | +81 3 6229 8070 | masaharu.umetsuji@jp.kpmg.com 

Kozu Takayuki | +81 3 6229 8205 | takayuki.kozu@jp.kpmg.com

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us


Request for proposal