Japan — Rules of Origin & FTAs

Japan applies non-preferential rules of origin to determine the country of origin for purposes other than granting preferential tariff treatment under an Economic Partnership Agreement (EPA) or the Generalized System of Preferences (GSP). Non-preferential origin determinations are required for the application of WTO (most-favored-nation) tariff rates, anti-dumping duties, safeguard measures, trade statistics, and country-of-origin marking under Article 71 of the Customs Act.

## Statutory basis

Non-preferential rules of origin are codified in the Cabinet Order for the Enforcement of the Customs Act (関税法施行令, Kanzei-hō Sekō-rei) and the Finance Ministry Ordinance for the Enforcement of the Customs Act (関税法施行規則, Kanzei-hō Sekō Kisoku). These domestic regulations implement Japan's obligations under the WTO Agreement on Rules of Origin, which requires WTO members to apply transparent and predictable non-preferential origin rules.

The Customs Act itself (Act No. 61 of 1954, as amended) does not define origin criteria in detail; Article 68 of the Act requires importers to declare the country of origin in the import (customs duty payment) declaration, and the subordinate Cabinet Order and Ministry of Finance Ordinance supply the operative tests.

## Two-tier origin criteria

Under the Finance Ministry Ordinance for the Enforcement of the Customs Act, the country of origin of imported goods is determined by one of two criteria:

1. Wholly obtained goods

Goods wholly obtained or produced in a single country or area are originating in that country. The definition of "wholly obtained" is provided in the Finance Ministry Ordinance and is substantially the same as the wholly obtained definition used in Japan's EPAs and GSP scheme. It includes:

• goods harvested, extracted, or gathered in that country (minerals, plants, live animals born and raised there);
• marine products taken from the territorial sea or exclusive economic zone of that country;
• goods manufactured in that country exclusively from goods falling within the categories above.

2. Goods undergoing substantial transformation

When production involves materials from more than one country, the country of origin is the country where the goods last underwent a manufacturing or processing operation that qualifies as substantial transformation, as defined in the Finance Ministry Ordinance for the Enforcement of the Customs Act.

Substantial transformation is assessed by reference to:

• change in tariff classification at the chapter (two-digit), heading (four-digit), or subheading (six-digit) level of the Harmonized System, depending on the product; or
• specific manufacturing or processing operations prescribed for particular goods.

Japan Customs does not publish a single consolidated table of product-specific substantial-transformation rules for non-preferential purposes in the manner that it does for EPAs. Importers and exporters may request an advance ruling on origin under the procedures set out on the Japan Customs website to obtain a binding written determination, valid for three years, on whether a particular manufacturing process confers Japanese (or foreign) origin under the non-preferential framework.

## Procedural requirements

For non-preferential origin determinations, Japan Customs does not require submission of a certificate of origin or other formal proof-of-origin document at the time of import declaration. The country of origin is confirmed by the commercial invoice or other related import documents (such as bills of lading, packing lists, or supplier declarations). Customs retains the authority to request additional documentation or verification if the declared origin is in doubt, but the default procedure is documentary review rather than third-party certification.

This stands in contrast to preferential origin claims under EPAs or GSP, which require submission of a certificate of origin issued by the competent authority of the exporting country, an origin certification document completed by the importer/exporter/producer, or (under certain newer EPAs such as the Japan-EU EPA and Japan-UK EPA) a statement on origin made out by the exporter on a commercial document.

## Advance rulings and transparency

Japan Customs discloses advance rulings on origin that have been issued in writing, to enhance transparency and predictability for importers. The disclosed rulings are available (in Japanese) on the Japan Customs website. Importers and other related parties may submit a written request for an advance ruling on the origin of a good prior to importation using Customs Form C-1000-2. The ruling is valid for three years and is respected by Customs at the time of import declaration if a copy of the written ruling is submitted, provided the actual imported good matches the description in the ruling, the ruling has not expired, applicable laws have not been amended, and there was no error in the application of law.

Oral or email inquiries are also accepted but are provided for reference only and do not bind Japan Customs.

Source: Outline of Rules of Origin, Customs and Tariff Bureau, Ministry of Finance, Japan Source: FAQ 1521: Outline of Rules of Origin, Japan Customs Source: Overview of Rules of Origin, Japan Customs Source: Advance Ruling on Origin, Japan Customs

Japan has negotiated and brought into force Economic Partnership Agreements (EPAs) with over twenty countries and regions, including bilateral EPAs with Singapore, Mexico, Malaysia, Chile, Thailand, Indonesia, Brunei, the Philippines, Switzerland, Viet Nam, India, Peru, Australia, Mongolia, the European Union, and the United Kingdom, as well as plurilateral agreements including the ASEAN-Japan Comprehensive Economic Partnership Agreement (AJCEP), the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP or TPP11), and the Regional Comprehensive Economic Partnership (RCEP). These agreements provide for preferential tariff treatment (reduced or eliminated customs duties) for goods that qualify as originating under the rules of origin set out in each EPA.

Under the Customs Act, the provisions on rules of origin in each EPA are directly applied, and importers claiming preferential tariff treatment must submit documentary evidence of origin to Japan Customs at the time of import declaration. Japan's EPAs employ three distinct origin certification systems, and the applicable system varies by agreement.

## 1. Third-party certification system

Under the third-party certification system, the exporter applies for a certificate of origin (CO) to the CO-issuing authority of the exporting country and sends the CO to the importer. The importer makes the claim for preferential tariff treatment by submitting the CO issued by the competent authority of the exporting country at the time of import declaration.

All of Japan's EPAs, as well as the Generalized System of Preferences (GSP), apply this system. The list of competent authorities authorized to issue certificates of origin for each EPA is published on the Japan Customs Rules of Origin portal.

The certificate of origin must fulfill the format and data-element requirements set out in the respective EPA. Certificates of origin are valid for twelve months from the date of issuance and must be submitted to Japan Customs at the time of import declaration (except for consignments whose aggregate customs value does not exceed 200,000 yen, discussed below).

When using the third-party certification system, the only additional document required beyond the standard import declaration documents is the certificate of origin itself; Japan Customs does not require submission of additional explanations or materials beyond the CO, though importers remain responsible for verifying that the goods are originating goods.

Applicable EPAs under the third-party certification system include: Japan-Singapore, Japan-Mexico, Japan-Malaysia, Japan-Chile, Japan-Thailand, Japan-Indonesia, Japan-Brunei, Japan-ASEAN, Japan-Philippines, Japan-Switzerland, Japan-Viet Nam, Japan-India, Japan-Peru, Japan-Australia, and Japan-Mongolia.

## 2. Self-certification system (importer, exporter, or producer)

Under the self-certification system, the importer declares that the goods are originating goods by submitting an origin certification document completed by either the importer, exporter, or producer of the goods. No third-party governmental issuing authority is required.

This system was first introduced under the Japan-Australia EPA alongside the third-party certification system and is now also available under the CPTPP (TPP11), the Japan-EU EPA, the Japan-UK EPA (Comprehensive Economic Partnership Agreement), the Trade Agreement between Japan and the United States, and the RCEP Agreement.

The origin certification document may be prepared in any format, provided that it contains the minimum information requirements (data elements) stipulated in the relevant EPA annex. The document is valid for one year from the date of completion.

When claiming preferential tariff treatment under the self-certification system, the importer generally must also submit an explanatory sheet (or "attachment") describing the originating status of the good, including the production process, materials used, and how the applicable rule of origin is satisfied. This requirement is codified in Article 68 of the Customs Act and paragraphs 68-5-0 to 68-5-23 of the Basic Notice of the Customs Act.

Japan Customs may waive submission of the explanatory sheet when:

• the importer is claiming the waiver under the 200,000-yen de minimis rule (see below);
• a relevant advance ruling on origin has been obtained in writing and the advance ruling registry number is listed on the import declaration form; or
• wholly obtained or produced good status can be ascertained from invoices and other standard commercial documents (in which case the importer writes "EPA WO" on the import declaration form).

Under RCEP, the importer self-certification (self-declaration) system can only be used in relation to imports into Japan (not for Japanese exports to RCEP partners), whereas the exporter self-certification and third-party certification systems are available bidirectionally.

## 3. Approved exporter self-certification system

Under the approved exporter self-certification system, the importer presents the origin of the good by submitting an origin declaration made by an approved exporter on an invoice or other commercial document. The exporting country certifies their exporters as eligible to make an origin declaration and informs Japan of the approved exporters.

This system is applied under the Japan-Switzerland EPA, the Japan-Peru EPA, and the Japan-Mexico EPA, alongside the third-party certification system.

The prescribed text to appear in the origin declaration is set out in the respective EPA. The origin declaration is valid for one year from the date it is made.

## Documentary requirements and timing

In principle, the certificate of origin, origin declaration, or origin certification document must be submitted to Customs at the time of import declaration. However, Japan Customs may allow for postponement of the submission if there is an unavoidable reason for delay, such as a natural disaster, or when the importer has obtained advance approval for a "before-permit release" (importation before payment system, or BP).

For a consignment whose aggregate customs value does not exceed 200,000 yen, importers are not required to submit the certificate of origin, origin declaration, or origin certification document when claiming preferential tariff treatment under an EPA. This de minimis waiver is codified in Article 61 of the Cabinet Order for Enforcement of the Customs Act and paragraph 3-1 of the Basic Notice of Treaties and Agreements.

## Consignment criteria (direct shipment)

To be eligible for preferential tariff treatment under an EPA, the goods must also satisfy the consignment criteria (or direct-shipment requirement). Goods must be transported directly from the exporting country to Japan. When goods are transported through the territory of a third country for the purpose of transit or temporary storage, the importer must submit a document such as a through bill of lading (B/L) or a certificate of non-manipulation issued by the customs authority of the third country to prove that the goods did not undergo additional manipulation and that the consignment criteria of the EPA are satisfied.

## Statutory basis

The requirements for claiming preferential tariff treatment under EPAs are codified in Article 68 of the Customs Act (Act No. 61 of 1954, as amended), paragraphs 1 and 4 through 8 of Article 61 of the Cabinet Order for Enforcement of the Customs Act, paragraphs 68-5-0 to 68-5-23 of the Basic Notice of the Customs Act, and paragraphs 3-1 through 3-20 of the Basic Notice of Treaties and Agreements. Each EPA's rules of origin and certification requirements are directly incorporated by reference into Japanese customs law.

Source: Origin Certification Procedure, Japan Customs Source: FAQ 1524: Origin certification procedures in making a claim for preferential tariff treatment under an Economic Partnership Agreement (EPA), Japan Customs Source: EPA's Customs procedure & Tariff classification code, Japan Customs Source: Outline of Rules of Origin, Customs and Tariff Bureau, Ministry of Finance, Japan (PDF) Source: Guide to obtaining preferential tariff treatment when importing goods under the RCEP Agreement, Japan Customs

Under the Regional Comprehensive Economic Partnership (RCEP) Agreement, which entered into force for Japan on 1 January 2022, goods may qualify for preferential tariff treatment if they meet one of three origin criteria set out in Article 3.2 of Chapter 3 of the Agreement: (a) wholly obtained or produced goods; (b) goods produced exclusively from originating materials; or (c) goods that satisfy the applicable product-specific rule (PSR) set out in Annex 3A to Chapter 3.

Most goods that contain non-originating materials qualify under criterion (c) — the product-specific rule. Japan Customs publishes guidance explaining how to apply RCEP PSRs when claiming preferential tariff treatment for imports into Japan.

## Structure of Annex 3A product-specific rules

Annex 3A to Chapter 3 of the RCEP Agreement sets out product-specific rules organized by Harmonized System (HS) Code at the six-digit subheading level. Each PSR specifies the minimum transformation required for a good produced with non-originating materials to acquire originating status. The PSRs are applied to the HS Code of the finished good being imported, not to the materials used in production.

RCEP PSRs employ three types of criteria, which may appear singly or in the alternative (joined by "or"):

1. Change in tariff classification (CTC)

A change in tariff classification requires that all non-originating materials used in the production of the good have undergone a specified degree of tariff shift. RCEP uses three levels of tariff shift, identified by abbreviation:

• CC (Change in Chapter): all non-originating materials must be classified in a different two-digit HS chapter from the finished good.
• CTH (Change in Tariff Heading): all non-originating materials must be classified in a different four-digit HS heading from the finished good.
• CTSH (Change in Tariff Subheading): all non-originating materials must be classified in a different six-digit HS subheading from the finished good.

When a PSR specifies a change in tariff classification, the importer must identify the HS classification of all non-originating materials and confirm that each material differs from the finished good at the required level (chapter, heading, or subheading). Japan Customs guidance emphasizes that demonstrating a CTC rule does not always require the identification of the full six-digit subheading of every material; for example, if the PSR is "CC," the importer need only confirm that a non-originating material is classified outside the two-digit chapter of the finished good and need not identify the precise four-digit heading or six-digit subheading of the material.

Some CTC rules are qualified by additional requirements or exceptions. For instance, a PSR may read "CTSH, except from Subheading 2905.31," meaning that the change-in-subheading rule does not confer origin if a non-originating material is classified in Subheading 2905.31. In such cases, the importer must verify that no non-originating materials fall within the excepted subheading.

2. Regional value content (RVC)

A regional value content rule requires that the value of originating materials (or, equivalently, the value added within the RCEP region) meet a specified percentage threshold. RCEP RVC rules are expressed as "RVC40" or "RVC45," denoting a 40 per cent or 45 per cent regional value content requirement.

The formula for calculating RVC under the RCEP Agreement is set out in Article 3.5 of Chapter 3. The build-down method is:

RVC = [(FOB – VNM) / FOB] × 100

where:

• FOB is the free-on-board value of the good (the customs value under the WTO Valuation Agreement, adjusted to an FOB basis);
• VNM is the value of non-originating materials used in production.

Alternatively, the build-up method may be used:

RVC = [VOM / FOB] × 100

where VOM is the value of originating materials.

When a PSR specifies "CTSH or RVC40," the good qualifies if it satisfies either the change-in-subheading requirement or the 40 per cent regional value content threshold. The importer may select the method that requires the lesser burden of proof.

3. Specific process rules (SP)

Some PSRs require the performance of a specific manufacturing or processing operation rather than (or in addition to) a tariff shift or value-content threshold. These rules are product-specific and may include chemical-reaction tests, weight-percentage requirements for particular inputs, or operations such as spinning, weaving, dyeing, or assembly. Specific process rules are less common in RCEP than CTC and RVC rules but appear for certain textile, chemical, and food products.

## De minimis (tolerance) rule

Article 3.7 of Chapter 3 of the RCEP Agreement provides a de minimis rule that allows a good to qualify as originating even if certain non-originating materials fail to satisfy the applicable CTC requirement, provided the value or weight of those materials is insignificant.

The de minimis thresholds are:

• For goods classified in HS Chapters 1 to 97 (except Chapters 50 to 63): the value of non-originating materials that did not undergo the required change in tariff classification must not exceed 10 per cent of the FOB value of the finished good.
• For goods classified in HS Chapters 50 to 63 (textiles and apparel): the weight of non-originating materials that did not undergo the required change in tariff classification must not exceed 10 per cent of the total weight of the finished good. Alternatively, importers may elect to apply the 10 per cent value test instead of the weight test for goods in Chapters 50 to 63.

The de minimis rule does not apply to PSRs that are based solely on regional value content (RVC), nor does it waive the requirement that the finished good be produced entirely in a Party.

## Cumulation

Article 3.4 of Chapter 3 provides for cumulation of origin. Goods and materials that comply with the origin requirements of Article 3.2 and are used in another RCEP Party as materials in the production of another good are considered originating in the Party where working or processing of the finished good has taken place. This means that an originating material produced in RCEP Party A and then incorporated into a good in RCEP Party B is treated as if it were an originating material of Party B, allowing the value or status of the material to count toward the origin determination of the finished good.

As of the date of entry into force of the RCEP Agreement, cumulation is limited to originating materials (diagonal cumulation). The Agreement contemplates a future review to consider extending cumulation to non-originating materials (full cumulation), but that review has not yet resulted in an amendment.

## Minimal operations and processes

Article 3.6 of Chapter 3 and Article 2.6.5 of Chapter 2 of the RCEP Agreement specify that certain minimal operations or processes do not confer origin even if the applicable PSR is satisfied. Minimal operations include simple packaging, labeling, sorting, washing, cutting to length or size, dilution, and assembly of parts when the assembly does not involve substantial transformation. A good that has undergone only minimal operations in a Party is not considered an originating good, irrespective of whether it meets the technical requirements of the PSR.

## Procedure for applying product-specific rules

When claiming preferential tariff treatment for an import into Japan under RCEP, the importer must:

1. Identify the six-digit HS subheading of the finished good using Japan's tariff schedule.
2. Look up the applicable PSR in Annex 3A to Chapter 3 of the RCEP Agreement (the full text of Annex 3A is linked from the Japan Customs RCEP portal).
3. Determine whether the good satisfies the PSR by applying the CTC, RVC, or specific process test specified in the rule. Japan Customs guidance provides worked examples showing how to apply CTC rules (e.g., pickles classified in Subheading 2001.90 with a PSR of "CC") and RVC rules (e.g., propylene glycol classified in Subheading 2905.32 with a PSR of "CTSH or RVC40").
4. Consider alternative pathways to origin if the good fails the PSR on its face: cumulation (if originating materials from other RCEP Parties were used), de minimis (if the value or weight of non-compliant materials is below the 10 per cent threshold), or classification as a good produced exclusively from originating materials under Article 3.2(b).

Japan Customs emphasizes that selecting the method that requires the lesser burden of proof is advisable when multiple pathways to origin are available. For example, demonstrating that a good satisfies a PSR under Article 3.2(c) often requires less documentation than proving that all materials used in the final stage of production are originating goods under Article 3.2(b).

## Statutory basis and amendment procedure

The product-specific rules set out in Annex 3A are directly incorporated into Japanese customs law as part of the RCEP Agreement. Article 3.34 of Chapter 3 provides that the RCEP Joint Committee may amend or transpose the PSRs to reflect updates to the Harmonized System nomenclature. Any transposed PSRs adopted by the Joint Committee are published by Japan Customs on the RCEP portal and apply automatically to import declarations filed after the effective date of the amendment.

Source: Guide to obtaining preferential tariff treatment when importing goods under the RCEP Agreement, Japan Customs Source: Step 2: Confirm that the good was produced in a Party and is treated as an originating good under the RCEP Agreement, Japan Customs Source: Alternative pathways to originating status under Step 2, Japan Customs

Japan has concluded Economic Partnership Agreements (EPAs) with multiple countries and regional economic blocs, covering both bilateral and plurilateral frameworks. These agreements establish preferential tariff treatment for qualifying originating goods and, in most cases, include chapters on services trade, investment protection, intellectual property, government procurement, and regulatory cooperation.

Japan's EPA network includes two major plurilateral agreements — the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP) and the Regional Comprehensive Economic Partnership (RCEP) Agreement — as well as bilateral EPAs with key trading partners across Asia, Oceania, the Americas, and Europe.

## Plurilateral Economic Partnership Agreements

Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP)

The CPTPP was signed on 8 March 2018 by eleven countries and entered into force for Japan on 30 December 2018, the date the agreement entered into force for the first six ratifying parties (Australia, Canada, Japan, Mexico, New Zealand, and Singapore). The CPTPP is the successor to the Trans-Pacific Partnership (TPP) Agreement signed in February 2016, which did not enter into force following the withdrawal of the United States in January 2017.

Original CPTPP signatories (March 2018): Australia, Brunei Darussalam, Canada, Chile, Japan, Malaysia, Mexico, New Zealand, Peru, Singapore, and Viet Nam. The United Kingdom subsequently acceded to the CPTPP; unable to confirm as of 2026-06-01 the precise entry-into-force date for the UK accession.

The CPTPP includes comprehensive rules of origin set out in Chapter 3 of the Agreement, with product-specific rules in Annex 3-D organized by HS subheading. The agreement applies a self-certification system under which the importer, exporter, or producer may complete an origin certification document without requiring third-party governmental issuance.

Regional Comprehensive Economic Partnership (RCEP) Agreement

The RCEP Agreement was signed on 15 November 2020 by fifteen countries and entered into force for Japan on 1 January 2022, the date it entered into force for the first ten ratifying parties (Japan, Brunei Darussalam, Cambodia, Lao PDR, Singapore, Thailand, Viet Nam, China, Australia, and New Zealand). The RCEP Agreement is the world's largest free-trade area by population and accounts for approximately 30 per cent of global GDP, global trade, and global population.

Countries where the RCEP Agreement has entered into force (as confirmed by Japan Customs): Japan, Australia, Brunei Darussalam, Cambodia, China, Indonesia, Republic of Korea, Lao PDR, Malaysia, New Zealand, the Philippines, Singapore, Thailand, and Viet Nam. Myanmar signed the RCEP Agreement but has not yet ratified it; the Agreement has not entered into force for Myanmar.

The RCEP Agreement includes rules of origin set out in Chapter 3, with product-specific rules in Annex 3A. The agreement applies both third-party certification and self-certification (importer, exporter, or producer) systems. For imports into Japan, importer self-certification is available alongside the exporter and third-party certification methods.

## Bilateral Economic Partnership Agreements — Asia-Pacific

Japan has concluded bilateral EPAs with the following Asia-Pacific countries. Entry-into-force dates are drawn from Ministry of Foreign Affairs (MOFA) Diplomatic Bluebook publications and Japan Customs guidance where directly stated:

• Japan-Singapore EPA: Entered into force 30 November 2002. Japan's first EPA.
• Japan-Mexico EPA: Entered into force 1 April 2005. (A revised protocol entered into force 1 April 2012, per Diplomatic Bluebook references.)
• Japan-Malaysia EPA: Entered into force 13 July 2006.
• Japan-Chile EPA: Entered into force 3 September 2007.
• Japan-Thailand EPA: Entered into force 1 November 2007.
• Japan-Indonesia EPA: Entered into force 1 July 2008.
• Japan-Brunei Darussalam EPA: Entered into force 31 July 2008.
• Japan-Philippines EPA: Entered into force 11 December 2008.
• Japan-Viet Nam EPA: Entered into force 1 October 2009.
• Japan-India EPA: Entered into force 1 August 2011 (formally titled the Comprehensive Economic Partnership Agreement between Japan and the Republic of India).
• Japan-Peru EPA: Entered into force 1 March 2012.
• Japan-Australia EPA: Entered into force 15 January 2015. Japan's first EPA to introduce the self-certification system (alongside the third-party certification system).
• Japan-Mongolia EPA: Entered into force 7 June 2016.

The ASEAN-Japan Comprehensive Economic Partnership Agreement (AJCEP), a plurilateral framework covering Japan and the ten ASEAN member states, entered into force for Japan on 1 December 2008. The First Protocol to Amend the AJCEP entered into force for Japan on 1 August 2020.

Unable to confirm as of 2026-06-01 the precise entry-into-force dates for Japan-Malaysia, Japan-Chile, Japan-Thailand, Japan-Indonesia, Japan-Brunei Darussalam, Japan-Philippines, Japan-Viet Nam, Japan-India, Japan-Peru, Japan-Australia, and Japan-Mongolia EPAs from the specific primary sources cited in this section; the dates listed above are drawn from general references in MOFA Diplomatic Bluebook materials and Japan Customs summaries but are not verifiable to official gazette or diplomatic-note citations accessible via the URLs provided.

## Bilateral Economic Partnership Agreements — Europe

• Japan-Switzerland EPA: Entered into force 1 September 2009. First EPA to apply the approved-exporter self-certification system (per Japan Customs origin-certification guidance).
• Japan-EU EPA (formally titled the Agreement between the European Union and Japan for an Economic Partnership): Entered into force 1 February 2019. The Japan-EU EPA entered into force following the exchange of diplomatic notes on 21 December 2018, with entry into force on the first day of the second month thereafter. The Japan-EU EPA applies the self-certification system (importer, exporter, or producer). A Protocol amending the Japan-EU EPA to include provisions on the free flow of data entered into force 1 July 2024.
• Japan-UK Comprehensive Economic Partnership Agreement (CEPA): Entered into force 1 January 2021. Concluded following the United Kingdom's withdrawal from the European Union to replace the Japan-EU EPA framework for UK trade. The Japan-UK CEPA is substantially based on the Japan-EU EPA but includes higher-level rules in areas such as electronic commerce and financial services, and a stand-alone chapter on gender and trade.

## Japan-United States Trade Agreement

The Trade Agreement between Japan and the United States of America and the Japan-US Digital Trade Agreement entered into force on 1 January 2020 (per MOFA EPA index). These are limited-scope agreements covering tariff elimination on certain agricultural and industrial products (Trade Agreement) and digital-trade rules (Digital Trade Agreement). A Protocol amending the Trade Agreement to modify agricultural safeguards on U.S. beef entered into force in January 2024 (per Diplomatic Bluebook 2024).

The Japan-US agreements are not comprehensive EPAs and do not include rules of origin chapters in the manner of Japan's other EPAs. For goods covered by the Trade Agreement, preferential tariff treatment is claimed by declaring the country of origin (United States) and submitting the commercial invoice and other import documents; no certificate of origin or origin certification document is required.

## EPAs under negotiation

The MOFA EPA/FTA index page lists the following EPAs as under negotiation or study (as reflected in materials current as of the cited MOFA and Bluebook sources):

• Japan-Colombia EPA: Negotiations launched December 2012; status as of 2026-06-01 unable to confirm.
• Japan-China-Republic of Korea Free Trade Agreement (FTA): Negotiations launched March 2013; sixteen rounds of negotiations held as of December 2021 (per Diplomatic Bluebook 2022); status as of 2026-06-01 unable to confirm.
• Japan-GCC (Gulf Cooperation Council) EPA, Japan-Canada EPA, Japan-Bangladesh EPA, Japan-Türkiye EPA, Japan-UAE EPA, and Japan-Republic of Korea EPA are listed on the MOFA EPA/FTA index page; current negotiation status as of 2026-06-01 unable to confirm.

## Statutory framework and tariff schedule

Japan's EPA preferential tariff rates are codified in the Customs Tariff Act (Act No. 54 of 1910, as amended) and the Cabinet Order for the Enforcement of the Customs Tariff Act. The Japan Customs Tariff Schedule is maintained by the Customs and Tariff Bureau of the Ministry of Finance and is available in searchable format on the Japan Customs website. Each tariff line in the schedule that is subject to preferential treatment under one or more EPAs displays the applicable preferential rate and the abbreviation of the EPA (e.g., "CPTPP," "RCEP," "EU," "UK," "AUS").

Importers claiming preferential tariff treatment under an EPA must satisfy three conditions:

1. A preferential tariff rate is stipulated for the good under the applicable EPA;
2. The good is an originating good under the rules of origin set out in the EPA; and
3. All necessary documentary and procedural requirements (submission of certificate of origin or origin certification document, consignment criteria, etc.) are fulfilled.

The procedures for claiming preferential treatment are set out in Article 68 of the Customs Act (Act No. 61 of 1954, as amended), the Cabinet Order for Enforcement of the Customs Act, and the Basic Notice of the Customs Act (per Japan Customs origin-certification guidance).

## Relationship between overlapping EPAs

When a good is eligible for preferential tariff treatment under more than one EPA (for example, a good imported from Australia may qualify under both the Japan-Australia EPA and the CPTPP, or a good from Thailand under the Japan-Thailand EPA, AJCEP, and RCEP), the importer may elect which EPA to claim. Japan Customs does not require the importer to claim the EPA that results in the lowest duty rate; the importer may select any EPA under which the good qualifies as an originating good and for which the necessary documentary evidence is available.

In practice, importers consider the burden of proof (how easily the applicable rule of origin can be satisfied), the availability of a certificate of origin or origin certification document, and the preferential rate when deciding which EPA to claim. For example, if a good qualifies under both the RCEP Agreement (which requires submission of an attachment sheet to the self-certification document) and the CPTPP (which does not require an attachment sheet), and the preferential rates are identical, the importer may elect the CPTPP to reduce compliance burden (per Japan Customs RCEP and origin-certification guidance).

Source: Free Trade Agreement / Economic Partnership Agreement and Related Initiatives, Japan Customs Source: Economic Partnership Agreement (EPA) / Free Trade Agreement (FTA) and Related Initiatives, Ministry of Foreign Affairs of Japan Source: Exchange of Diplomatic Notes concerning Entry into Force of the Agreement between the European Union and Japan for an Economic Partnership, Ministry of Foreign Affairs of Japan Source: Diplomatic Bluebook 2024, Chapter 3, Section 3.3.2: Efforts to expand the free and fair economic order, Ministry of Foreign Affairs of Japan Source: Diplomatic Bluebook 2022, Chapter 3, Section 3.3.2: Promotion of Rule-Making to Bolster Free and Open Global Economic Systems, Ministry of Foreign Affairs of Japan Source: Guide to obtaining preferential tariff treatment when importing goods under the RCEP Agreement, Japan Customs Source: Outline of the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP), Japan Customs FAQ 4052

Under the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP or TPP11), which entered into force for Japan on 30 December 2018, goods may qualify for preferential tariff treatment if they meet one of three origin criteria set out in Article 3.2 of Chapter 3 of the Agreement: (a) wholly obtained or produced goods; (b) goods produced exclusively from originating materials; or (c) goods that satisfy the applicable product-specific rule (PSR) set out in Annex 3-D to Chapter 3.

Most goods that contain non-originating materials qualify under criterion (c) — the product-specific rule. Japan Customs publishes guidance explaining how to apply CPTPP PSRs when claiming preferential tariff treatment for imports into Japan.

## Structure of Annex 3-D product-specific rules

Annex 3-D to Chapter 3 of the CPTPP sets out product-specific rules organized by Harmonized System (HS) Code at the six-digit subheading level. Each PSR specifies the minimum transformation required for a good produced with non-originating materials to acquire originating status. The PSRs are applied to the HS Code of the finished good being imported, not to the materials used in production.

CPTPP PSRs employ three primary types of criteria, which may appear singly or in the alternative (joined by "or") or in combination (joined by "and"):

1. Change in tariff classification (CTC)

A change in tariff classification requires that all non-originating materials used in the production of the good have undergone a specified degree of tariff shift. CPTPP uses four levels of tariff shift, identified by abbreviation:

• CC (Change in Chapter): all non-originating materials must be classified in a different two-digit HS chapter from the finished good.
• CTH (Change in Tariff Heading): all non-originating materials must be classified in a different four-digit HS heading from the finished good.
• CTSH (Change in Tariff Subheading): all non-originating materials must be classified in a different six-digit HS subheading from the finished good.
• CR (Change to a specific subheading or heading from any other heading or chapter): the finished good must be classified in the specified heading or subheading, and all non-originating materials must come from outside that heading or chapter, as specified in the rule.

Some CTC rules are qualified by additional requirements or exceptions. For example, a PSR may read "CTSH, except from subheading X," meaning that the change-in-subheading rule does not confer origin if a non-originating material is classified in subheading X. In such cases, the importer must verify that no non-originating materials fall within the excepted subheading or heading.

2. Regional value content (RVC)

A regional value content rule requires that the value of originating materials (or, equivalently, the value added within the CPTPP region) meet a specified percentage threshold. CPTPP RVC rules are typically expressed as percentages ranging from 30 per cent to 65 per cent, depending on the product.

The formulas for calculating RVC under the CPTPP are set out in Article 3.5 of Chapter 3. The Agreement permits three calculation methods, and importers may select the method that is most favorable:

Build-down method (transaction value):

RVC = [(AV – VNM) / AV] × 100

where:

• AV is the adjusted value of the good (the transaction value of the good adjusted to an FOB basis);
• VNM is the value of non-originating materials, including freight, insurance, packing, and all other costs incurred in transporting the material to the location of the producer.

Build-up method (transaction value):

RVC = [VOM / AV] × 100

where VOM is the value of originating materials.

Net cost method:

RVC = [(NC – VNM) / NC] × 100

where NC is the net cost of the good, calculated by deducting sales promotion, marketing, after-sales service costs, royalties, shipping and packing costs, and non-allowable interest costs from the total cost of the good.

The net cost method is mandatory for certain automotive goods specified in Annex 3-D and the automotive-specific Appendix 1 to Annex 3-D (provisions related to product-specific rules of origin for certain vehicles and parts of vehicles). For most other goods, importers may elect any of the three methods.

When a PSR specifies "CTSH or RVC 45," the good qualifies if it satisfies either the change-in-subheading requirement or the 45 per cent regional value content threshold. The importer may select the method that requires the lesser burden of proof or for which documentation is more readily available.

3. Specific process rules and wholly obtained criteria

Some PSRs require the performance of a specific manufacturing or processing operation rather than (or in addition to) a tariff shift or value-content threshold. These rules are product-specific and may include chemical-reaction tests (e.g., "a chemical reaction is undergone"), weight-percentage requirements for particular inputs, or operations such as spinning, weaving, dyeing, extrusion, or assembly accompanied by a specified level of value addition. Specific process rules appear for certain textile, chemical, steel, and automotive products.

For goods that are entirely obtained or produced in a single CPTPP Party without the incorporation of any materials from a non-Party, the wholly obtained criterion under Article 3.3 of Chapter 3 applies. The definition of wholly obtained is functionally equivalent across Japan's EPAs and includes goods harvested, extracted, or gathered in a Party (minerals, plants, live animals born and raised there), marine products taken from the territorial sea or exclusive economic zone of a Party or from the high seas by a vessel registered in and flying the flag of a Party, and goods manufactured in a Party exclusively from such materials.

## De minimis (tolerance) rule

Article 3.6 of Chapter 3 of the CPTPP provides a de minimis rule that allows a good to qualify as originating even if certain non-originating materials fail to satisfy the applicable CTC requirement, provided the value or weight of those materials is insignificant.

The de minimis thresholds are:

• For goods classified in HS Chapters 1 to 27 (agricultural and mineral products): the value of all non-originating materials that did not undergo the required change in tariff classification must not exceed 10 per cent of the transaction value or total cost of the finished good.
• For goods classified in HS Chapters 28 to 97 (industrial products): the value of all non-originating materials that did not undergo the required change in tariff classification must not exceed 10 per cent of the transaction value or total cost of the finished good.

For textile and apparel goods classified in HS Chapters 50 to 63, Chapter 4 (Textile and Apparel Goods) of the CPTPP sets separate de minimis rules: goods classified in Chapters 50 to 60 may contain up to 10 per cent by weight of non-originating fibres or yarns that do not undergo the required tariff shift, and goods classified in Chapters 61 to 63 may contain up to 10 per cent by weight of non-originating fibres or yarns in the component that determines the tariff classification of the finished good.

The de minimis rule does not apply when the PSR is based solely on a wholly obtained criterion or when the rule expressly states that the de minimis provision does not apply. Additionally, the good must still be produced entirely in one or more CPTPP Parties (the de minimis rule does not waive the requirement that the last production step occur in a Party).

## Accumulation (cumulation) of origin

Article 3.4 of Chapter 3 provides for accumulation of origin. A material that is an originating good under the rules of origin of Chapter 3 is treated as an originating material when it is used in the production of another good in the same or a different CPTPP Party. This means that an originating material produced in CPTPP Party A and then incorporated into a finished good in CPTPP Party B is treated as if it were an originating material of Party B, allowing the value or status of the material to count toward the origin determination of the finished good.

CPTPP cumulation applies to originating materials (diagonal cumulation). A non-originating material used in Party A to produce an originating intermediate good, and that intermediate good then shipped to Party B for further production, allows the intermediate good to be treated as originating in the cumulation calculation, but the underlying non-originating material does not itself become originating.

Importers relying on cumulation must confirm that the intermediate material qualifies as originating under the CPTPP rules of origin (either by obtaining a statement from the supplier of the intermediate material or by applying the relevant PSR to the intermediate good).

## Minimal operations and processes

Article 3.8 of Chapter 3 specifies that certain minimal operations or processes do not confer origin even if the applicable PSR is technically satisfied. Operations that are considered insufficient to confer origin include:

• operations to ensure the preservation of goods in good condition during transport and storage (ventilation, spreading, drying, chilling, placing in salt or other aqueous solutions, removal of damaged parts);
• simple operations consisting of removal of dust, sifting or screening, sorting, classifying, washing, painting, or cutting;
• changes of packaging and breaking up and assembly of packages;
• simple cutting, slitting, or repackaging or placing in bottles, cases, or boxes;
• affixing marks, labels, or other distinguishing signs on products or their packaging;
• simple mixing of goods (whether or not of different kinds) where one or more components of the mixture do not meet the applicable origin requirements;
• simple assembly of parts to constitute a complete good; or
• slaughter of animals.

A good that has undergone only minimal operations in a Party is not considered an originating good, irrespective of whether it meets the technical requirements of the PSR set out in Annex 3-D. Japan Customs guidance emphasizes that assembly operations must be accompanied by substantial value addition or a required tariff shift beyond simple joining of parts to confer origin.

## Procedure for applying product-specific rules when claiming preferential tariff treatment

When claiming preferential tariff treatment for an import into Japan under the CPTPP, the importer (or the exporter or producer completing an origin certification document on behalf of the importer) must:

1. Identify the six-digit HS subheading of the finished good using Japan's tariff schedule.
2. Look up the applicable PSR in Annex 3-D to Chapter 3 of the CPTPP (the full text of Annex 3-D is published on the Cabinet Office TPP website and linked from the Japan Customs CPTPP portal).
3. Determine whether the good satisfies the PSR by applying the CTC, RVC, or specific process test specified in the rule. If the PSR offers alternative pathways (e.g., "CTSH or RVC 45"), the importer may elect the pathway that is most readily demonstrated with available documentation.
4. Consider cumulation and de minimis if the good fails the PSR on its face. If originating materials from other CPTPP Parties were used, cumulation may allow those materials to be treated as originating in the country of production. If a small quantity of non-originating materials failed the tariff-shift test but the value or weight is within the 10 per cent de minimis threshold, the good may still qualify.
5. Prepare the origin certification document (or request a certificate of origin from the competent authority of the exporting Party, depending on the certification system being used). The CPTPP applies a self-certification system under which the importer, exporter, or producer may complete an origin certification document; no third-party governmental issuance is required. The data elements for the certification of origin are set out in Article 3.20 of Chapter 3. Japan Customs requires importers using the self-certification system to submit an attachment sheet (explanatory document) describing the production process, materials used, and how the applicable PSR is satisfied, except when claiming the 200,000-yen de minimis waiver or when an advance ruling on origin has been obtained.

Japan Customs provides worked examples of PSR application in the Guideline on 'Self-Certification System' (CPTPP edition) published on the Japan Customs Rules of Origin portal.

## Statutory basis and amendment procedure

The product-specific rules set out in Annex 3-D are directly incorporated into Japanese customs law as part of the CPTPP. Article 3.27 of Chapter 3 provides that the CPTPP Commission may modify Annex 3-D to reflect updates to the Harmonized System nomenclature or to amend the PSRs. Any modifications adopted by the Commission are published by Japan Customs on the CPTPP portal and apply automatically to import declarations filed after the effective date of the modification.

The requirements for claiming preferential tariff treatment under the CPTPP are codified in Article 68 of the Customs Act (Act No. 61 of 1954, as amended), paragraphs 1 and 4 through 8 of Article 61 of the Cabinet Order for Enforcement of the Customs Act, paragraphs 68-5-0 to 68-5-23 of the Basic Notice of the Customs Act, and paragraphs 3-1 through 3-20 of the Basic Notice of Treaties and Agreements.

Source: Guideline on 'Self-Certification System' (CPTPP), Japan Customs Source: FAQ 4052: Outline of the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP), Japan Customs Source: Text of the Trans-Pacific Partnership, Chapter 3: Rules of Origin and Origin Procedures, Ministry of Foreign Affairs of Japan Source: Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP) text repository, Cabinet Office of Japan Source: Outline of Rules of Origin, Customs and Tariff Bureau, Ministry of Finance, Japan (PDF) Source: Origin Certification Procedure, Japan Customs