Import Customs Regulations under the Washington Convention (CITES)
Interlink編集部Import Customs Clearance Regulations under the Washington Convention (CITES)
Import customs clearance regulations under the Washington Convention (CITES) involve checking CITES documents, import approval, prior confirmation, confirmation at the time of customs clearance, designated customs offices, verification under other laws on NACCS, and original document management when importing endangered wild fauna and flora, or their parts, derivatives, and processed products into Japan.
CITES is an international treaty that regulates the international trade of wild fauna and flora. However, in import operations, it appears not only as a nature conservation system but also as a customs-related issue, including whether cargo can be brought into Japan, which customs office can accept the import declaration, which documents must be submitted or presented to customs, and which other legal checks must be reflected on NACCS.
The scope includes not only live animals and plants but may also cover products containing animal- or plant-derived raw materials, such as fur, leather goods, ivory, tortoiseshell, coral, timber, musical instruments, plants, Kampo medicines, health foods, cosmetics, specimens, ornaments, and research samples.
Document deficiencies or overlooked applicability may lead to import customs clearance delays, changes in the designated customs office for declaration, cargo being held in a bonded area, storage fees, return costs, disposal expenses, delivery delays, and administrative issues.
Scope Covered by This Article
This article deals with the Washington Convention not only as a regulatory system but also as a practical regulation related to import customs clearance, verification under other laws, freight forwarder operations, and customs broker operations.
| Item | Contents Covered in This Article | Contents Covered in Detail in Other Articles |
|---|---|---|
| CITES Confirmation at Import Customs | How to practically confirm whether cargo imported into Japan is subject to the Washington Convention in import operations. | The purpose of the Washington Convention, the background of the treaty, and the overall Appendix system are covered in the general CITES article. |
| Import Approval | Situations requiring import approval from the Minister of Economy, Trade and Industry, and the role of the Certificate of Import Approval. | Detailed application forms, application destinations, and review materials for import approval are covered in the import approval article. |
| Prior Confirmation | Cases requiring a Certificate of Prior Confirmation and matters to be confirmed prior to shipment. | Details on specific countries of origin, target species lists, and prior confirmation application procedures are covered in the prior confirmation article. |
| Confirmation at the Time of Customs Clearance | The practice of confirming original CITES documents at import declaration even if the cargo is not subject to import approval or prior confirmation. | Customs examination, certification under other laws, and NACCS input details are covered in the import customs clearance article. |
| Designated Customs Office | Checking the customs offices authorized to accept declarations for Washington Convention-related cargo and precautions for selecting bonded receipt locations. | Details on each customs office, bonded areas, and bonded transportation are covered in customs and bonded area articles. |
| Freight Forwarders and Customs Brokers’ Checks | Information, documents, and transportation planning to be confirmed when receiving instructions from the cargo owner. | Freight forwarders’ scope of responsibility, E&O risks, and practices for confirming with cargo owners are covered in separate articles. |
| Actions After Cargo Arrival | Cases where cargo is found to be subject to CITES after arrival, including storage fees, return, disposal, and cost responsibility. | Details on marine cargo insurance, demurrage, detention, and storage fees are covered in each related cost and insurance article. |
Purpose and Background of the System
The Washington Convention (CITES) is a regulatory framework designed to prevent wild fauna and flora from being driven toward extinction due to excessive international trade. Species covered under CITES are classified into Appendices I, II, and III, and the required documents and procedures vary depending on the classification and the condition of the cargo.
In Japan’s import operations, CITES intersects with import controls under the Foreign Exchange and Foreign Trade Act and the Import Trade Control Order, verification under other laws by customs, import declarations at designated customs offices, NACCS data entry, and submission or presentation of original documents. Therefore, verifying whether cargo is subject to CITES is not merely a matter of legal knowledge; it directly affects whether the cargo can clear customs.
In particular, the Certificate of Import Approval, Certificate of Prior Confirmation, CITES Export Permit, CITES Re-export Certificate, and Import Permit Notice serve different purposes. Confusing these documents may result in customs clearance being halted even when some documents are available.
Main Cargoes That Could Cause Issues at Import
CITES-regulated cargo cannot be identified by the product name alone on the invoice. Even general product names may include materials or components from regulated species.
| Type of Cargo | Examples | Information to Confirm | Practical Notes |
|---|---|---|---|
| Live Animals and Plants | Animals, fish, reptiles, birds, insects, plants, seedlings, seeds, bulbs, cut flowers | Scientific name, country of origin, Appendix classification, live specimen status, quarantine requirements | Verification is required not only for CITES but also for plant and animal quarantine and acceptance facilities. |
| Leather Products | Bags, wallets, belts, shoes made with crocodile, snake, or lizard leather | Scientific name, country of origin, tag number, exporter’s CITES documents | The label “Leather Bag” alone is insufficient to determine whether it is regulated. |
| Ornaments and Handicrafts | Items made with ivory, tortoiseshell, coral, bone, horn, or shells | Material, scientific name, acquisition date, pre-convention acquisition status | Antiques and used items may also be subject to regulation. |
| Wood and Musical Instruments | Wood, furniture, musical instruments, and components using rosewood, ebony, mahogany, etc. | Tree species, scientific name, processing status, manufacturing year, component usage locations | Regulatory status is checked by individual component, not only by the finished product. |
| Cosmetics, Health Foods, and Pharmaceutical Raw Materials | Plant extracts, Kampo medicines, health foods, cosmetic raw materials, and pharmaceutical raw materials | Ingredient list, raw material specifications, scientific name, content amount, Pharmaceuticals and Medical Devices Act (PMD Act) and Food Sanitation Act review | Verification is based on raw materials and components, not only on the finished product name. |
| Specimens and Research Samples | Taxidermy, specimens, research samples, educational materials, DNA samples | Research purpose, scientific name, quantity, preservation condition, receiving institution | CITES procedures may still be required for non-commercial purposes. |
| Exhibition, Promotional, and Returned Cargo | Exhibition samples, promotional items, returned repair goods, personal effects | Import purpose, return schedule, planned re-export, original document control | Even temporary imports should be checked if the cargo is subject to CITES regulations. |
Differences Between Import Approval, Prior Confirmation, and Confirmation at the Time of Customs Clearance
When importing CITES-regulated cargo into Japan, the main procedural issues are generally import approval, prior confirmation, or confirmation at the time of customs clearance.
| Category | Main Targets | Main Procedures | Practical Points to Note |
|---|---|---|---|
| Import Approval | Cargo requiring particularly strict control, such as species listed in Appendix I. | An application for import approval is submitted to the Minister of Economy, Trade and Industry, and a Certificate of Import Approval is obtained. | Export country documents alone are insufficient; if the cargo arrives before Japanese import approval is obtained, customs clearance is likely to be delayed. |
| Prior Confirmation | Cargo subject to the prior confirmation system, such as live animals or cargo originating from specified countries and listed in Appendices II or III. | An application for prior confirmation is submitted to the Ministry of Economy, Trade and Industry or related authorities, and a Certificate of Prior Confirmation is obtained. | The target species, country of origin, shipping country, and export country CITES documents must be confirmed before shipment. |
| Confirmation at the Time of Customs Clearance | Species listed in Appendices II and III that are not subject to import approval or prior confirmation. | At import declaration, the original CITES Export Permit or equivalent document issued by the exporting country must be submitted or presented to customs for confirmation. | Even when prior application seems unnecessary, customs clearance may be delayed due to missing originals, discrepancies in documentation, or declaration at an incorrect designated customs office. |
This classification is not determined mechanically by the Appendix alone. The required procedure varies depending on the species, country of origin, shipping country, export country, whether the cargo is live or processed, whether it is a re-export, and whether it falls under specified country-of-origin rules.
Main Documents Required at Import
The key documents relevant to the import of CITES-regulated cargo include the following. The actual documents required vary depending on the Appendix classification, country of origin, exporting country, cargo condition, and import purpose.
| Document | Main Purpose | Who Prepares or Obtains It | Notes |
|---|---|---|---|
| CITES Export Permit | Document authorizing export of CITES-listed cargo on the exporting country side. | Overseas exporter, applicant in the exporting country | Verify authenticity, validity period, scientific name, quantity, exporter details, and importer details. |
| CITES Re-export Certificate | Certificate for cargo previously imported and now being shipped to a third country. | Overseas exporter, applicant in the re-exporting country | Confirm the re-exporting country, country of origin, and past import history. |
| Pre-convention Certificate / Breeding Certificate / Commercial Sample Certificate | Documents explaining special circumstances such as timing of acquisition, breeding or cultivation, and commercial samples. | Overseas exporter, owner, related institutions | These are not the same as a standard export permit; verify their intended use. |
| Certificate of Import Approval | Document indicating approval by the Minister of Economy, Trade and Industry for cargo requiring import approval in Japan. | Japanese importer, applicant | This is different from the Import Permit Notice issued after customs procedures. |
| Certificate of Prior Confirmation | Document certifying that prior confirmation has been obtained for cargo requiring such confirmation in Japan. | Japanese importer, applicant | It may need to be obtained before shipment; post-arrival handling may cause delays. |
| Import Permit Notice | Document showing that the import declaration has been approved by customs. | Issued or notified as a result of customs procedures. | It does not substitute for a Certificate of Import Approval or Certificate of Prior Confirmation. |
| Invoice, Packing List, B/L, AWB | Basic documents indicating import declaration information, cargo contents, transportation route, and quantity. | Exporter, freight forwarder, shipping company, airline | They must be consistent with CITES documents regarding item names, quantities, weights, exporter details, and importer details. |
| Ingredient List, Material Certificate, Scientific Name Documents, Manufacturer Certificate | Supplementary materials used to determine whether the cargo falls under CITES regulations. | Manufacturer, supplier, shipper | Important when generic item names are insufficient to identify regulatory status. |
Comparison with Other Systems
| System / Document | Main Purpose | Relation to CITES Import Customs Clearance | Practical Points |
|---|---|---|---|
| CITES Documentation | To authorize the international movement of CITES-regulated goods by the exporting or re-exporting country. | CITES Export Permits, CITES Re-export Certificates, etc. are verified by customs. | Original documents, validity period, scientific names, quantities, and consistency between exporter and importer are important. |
| Certificate of Import Approval | To obtain approval from the Minister of Economy, Trade and Industry for goods requiring import approval in Japan. | For applicable goods, it is submitted to customs together with CITES documentation. | It should not be confused with an Import Permit Notice issued after customs procedures. |
| Certificate of Prior Confirmation | To receive confirmation prior to import for applicable goods. | For applicable goods, it is checked together with CITES documentation. | Confirm the timing of acquisition before shipment or arrival. |
| Import Permit Notice | To show that the import declaration has been approved by customs. | This is a document issued after customs clearance procedures are completed. | It is not a substitute for a Certificate of Import Approval or Certificate of Prior Confirmation. |
| Animal and Plant Quarantine | To prevent the entry of pests, diseases, and livestock epidemics. | May overlap with CITES for animals, plants, timber, seeds, livestock products, etc. | Having CITES documentation does not necessarily exempt the cargo from quarantine procedures. |
| Food Sanitation Act and Pharmaceuticals and Medical Devices Act (PMD Act) | To ensure the safety and legality of foods, additives, cosmetics, pharmaceuticals, quasi-drugs, etc. | May overlap with CITES for health foods, Kampo medicines, cosmetic raw materials, and pharmaceutical raw materials. | Additional checks under other laws may be required depending on ingredients, usage, and sales form. |
Applicable Situations
| Situation | Relevant Cargo | Procedures to Check | Practical Notes |
|---|---|---|---|
| Regular Imports | Leather goods, wood products, plant products, etc. imported from overseas for resale. | Check CITES documents, import approval, prior confirmation, and confirmation at the time of customs clearance. | Confirm required documents and designated customs offices before shipment. |
| Import of Exhibition Items | Musical instruments, artworks, ornaments, and specimens for exhibitions. | Even for temporary importation, confirm CITES applicability and manage original documents carefully. | Check procedures including return shipment and re-export after the exhibition. |
| Repair and Returned Goods | Musical instruments, bags, ornaments, etc. entering Japan for repair from overseas. | Confirm CITES documents at import and certificate requirements for re-export. | Re-export after repair may also raise compliance issues. |
| Research Samples | Specimens, DNA samples, plant fragments, animal-derived materials, etc. | Confirm the necessity of CITES documents, import approval, and prior confirmation even for non-commercial use. | Do not treat university or research institution shipments as ordinary courier parcels. |
| Small Shipments and International Couriers | Samples, personal purchases, promotional items, small parts, etc. | Check CITES applicability, original documents, designated customs offices, and whether courier companies can handle the cargo. | Small quantity or free-of-charge shipments are not necessarily exempt. |
| Food, Cosmetics, and Pharmaceutical Ingredients | Kampo medicines, health foods, plant extracts, cosmetic raw materials, pharmaceutical raw materials, etc. | Check CITES, the Food Sanitation Act, the Pharmaceuticals and Medical Devices Act (PMD Act), quarantine, etc. | Ingredient lists and scientific names are crucial. |
Applicable Conditions and Potential Exceptions
| Check Item | When It Is Likely Applicable | When It May Be Excluded or Require Separate Verification | Notes |
|---|---|---|---|
| Applicable Species | When the scientific name is listed in the CITES Appendices. | When the species is not listed in the Appendices. | Judgment cannot be made based solely on Japanese name, English name, or product name. |
| Parts, Derivatives, and Processed Products | When items such as leather, wood, bone, horn, extracts, powders, or essences are included within the regulated scope. | Some processed products may be excluded due to Appendix annotations. | The scope requires confirmation of annotations specific to each species. |
| Country of Origin / Export | When the country of origin, export country, or re-export country is relevant to the CITES documents. | It may not be determined solely by the manufacturing country or shipping country. | Distinguish between the CITES-defined country of origin and the trade-related place of origin. |
| Purpose of Import | When there is international movement for resale, exhibition, research, repair, return, or personal use. | Even for non-commercial purposes, procedures may still be required. | The applicable species and the existence of international movement are more important than the purpose itself. |
| Original Documents | When submission or presentation of original CITES documents is required. | Copies or PDFs may be insufficient in some cases. | Check whether the original documents will arrive before the cargo. |
| Validity Period | When CITES documents have an expiration date. | The import declaration may not be accepted after the expiration date. | Manage the shipment date, arrival date, and import declaration date together. |
Basic Flow of Import Procedures
For cargo that may fall under the Washington Convention (CITES), the following checks should be conducted before import:
- Confirm whether the product contains animal- or plant-derived raw materials.
- Verify the scientific name, Japanese name, and English name of the applicable species.
- Check whether the species is listed in CITES Appendix I, II, or III.
- Confirm the country of origin, export country, loading country, and transit countries.
- Confirm whether a CITES Export Permit or equivalent document can be obtained from the exporting country.
- Confirm whether import approval or prior confirmation is required on the Japan side.
- If confirmation at the time of customs clearance applies, verify that original documents can be submitted or presented at import declaration.
- Confirm that export and import declaration procedures can be completed within the validity period of the CITES documents.
- Verify the arrival port, airport, and bonded receipt location to ensure import declaration can be made at the designated customs office.
- Organize the necessary information for NACCS fields, including the Other Laws field, Import Trade Control Order field, and Certificate of Import Approval-related fields.
- Submit or present the required documents to customs for review and confirmation.
- If no issues are found, customs approves the import declaration and issues or notifies the Import Permit Notice.
It is critical to conduct these checks before shipment or before air transport departure, rather than after cargo arrival. For CITES-regulated cargo, discovering issues after arrival may prevent timely document acquisition or changing the customs office for declaration.
Relationship with Designated Customs Offices
For cargo subject to the Washington Convention, designated customs offices are extremely important.
For ordinary imported cargo, the customs office for declaration is sometimes chosen based on the convenience of the destination or the customs broker. However, for cargo subject to the Washington Convention, import declaration may only be possible at a designated customs office.
| Check Item | Reason for Check | Party to Confirm With | Action if Issues Arise |
|---|---|---|---|
| Port or Airport of Arrival | To confirm whether it is suitable for handling Washington Convention cargo. | Freight forwarder, customs broker, customs | Review the arrival location and transport route as needed. |
| Planned Customs Office for Import Declaration | To confirm whether import declaration can be made at the designated customs office. | Customs broker, customs | If declaration at the designated customs office is not possible, consider bonded transportation or changing the bonded receipt location. |
| Bonded Receipt Location | To confirm whether declaration can be made at the designated customs office after bonded receipt. | Freight forwarder, warehouse, customs broker | Confirm the relationship between the customs office for declaration and the bonded area before receipt. |
| Mode of Transport | Handling varies among sea cargo, air cargo, international mail, and international courier. | Freight forwarder, courier company, customs broker | Even for small shipments, if subject to CITES, the same checks as for ordinary cargo are required. |
| Arrival of Original Documents | Original documents may be required for confirmation by customs. | Overseas exporter, importer, freight forwarder | If cargo and documents arrive separately, manage their arrival timing carefully. |
| Movement Path of Live Cargo | There may be restrictions on inspection, storage, and delivery. | Freight forwarder, warehouse, quarantine officials, customs | Confirm storage conditions, inspection flow, and delivery timing in advance. |
Checks Conducted at the Time of Customs Clearance
Confirmation at the time of customs clearance is the process where customs authorities review CITES-related documents at the time of import declaration. Even when prior confirmation or import approval is not required, the originals and details of the CITES documents issued by the exporting country are checked during customs clearance.
- Whether the original CITES Export Permit or CITES Re-export Certificate is available
- Whether export and import procedures are carried out within the document’s validity period
- Whether there are inconsistencies in the exporter, importer, country of origin, exporting country, or re-exporting country stated
- Whether the scientific name, product name, quantity, weight, and number match the invoice and packing list
- Whether the cargo and documents can be linked through B/L, AWB, marks, lot numbers, etc.
- Whether there are errors in the combination of Appendix classifications and required documents
- Whether the document includes necessary signatures, stamps, and issuing authority information
- Whether originals can be presented in cases where original documents are mandatory instead of copies or scans
Confirmation at the time of customs clearance does not mean that no preparation is required. Even if the cargo is not subject to import approval or prior confirmation, deficiencies in the CITES documents may cause customs to halt clearance and delay issuance of the Import Permit Notice.
Relationship with NACCS and Verification under Other Laws
For cargo subject to the Washington Convention (CITES), verification under other laws via NACCS is also important.
In import declarations, cargo falling under the Import Trade Control Order must have the required codes and numbers entered in fields such as the Other Laws field, Import Trade Control Order field, and Certificate of Import Approval-related fields. Whether the procedure is import approval, prior confirmation, or confirmation at the time of customs clearance, the fact that the cargo is subject to the Washington Convention must be accurately reflected on NACCS.
| Confirmation Item | Details to Confirm | Involved Parties | Notes |
|---|---|---|---|
| Other Laws Field / Import Trade Control Order Field | Check whether the cargo requires processing as subject to the Washington Convention. | Customs Broker, Customs | Processing may not be the same as for ordinary cargo. |
| Certificate of Import Approval Number | If a Certificate of Import Approval exists, its number and details should be reflected in the declaration. | Importer, Customs Broker | Avoid confusing it with the Import Permit Notice. |
| Certificate of Prior Confirmation Number | If a Certificate of Prior Confirmation exists, verify its number and the applicable cargo. | Importer, Customs Broker | Confirm consistency with the cargo, quantity, and scientific name. |
| CITES Document Number | Confirm the number of the CITES Export Permit or CITES Re-export Certificate. | Overseas Exporter, Importer, Customs Broker | If the number is long or multiple documents exist, prepare supplemental materials. |
| Overlap with Other Regulations | Check whether the Food Sanitation Act, Pharmaceuticals and Medical Devices Act (PMD Act), plant quarantine, animal quarantine, or other regulations may also apply. | Importer, Customs Broker, Relevant Authorities | Customs clearance can be halted due to omissions in procedures other than CITES. |
Freight Forwarder's Scope of Involvement and Role Allocation Among Stakeholders
| Category | Support Typically Provided | Matters Not to Be Definitively Determined | Practical Handling |
|---|---|---|---|
| Initial Cargo Screening | Freight forwarders can ask whether the cargo contains animal- or plant-derived materials and request basic supporting documents. | They should not make a final determination that the cargo is outside CITES based only on product names or invoice descriptions. | If there is any doubt, request scientific names, composition sheets, material certificates, and manufacturer information from the cargo owner. |
| CITES Applicability | Freight forwarders can identify risk signals and connect the cargo owner, customs broker, overseas exporter, and relevant specialists. | They should not independently decide final CITES applicability, Appendix classification, or availability of exemptions. | Record the confirmation route and make clear that final product information and regulatory confirmation must come from the cargo owner or appropriate authority. |
| Japan-Side Import Approval and Prior Confirmation | Freight forwarders can remind the importer to check whether a Certificate of Import Approval or Certificate of Prior Confirmation is required. | They should not assume that export-side CITES documents alone are sufficient for Japanese import procedures. | Before shipment, confirm whether the importer has checked Japan-side procedures and application timelines. |
| Original Document Management | Freight forwarders can coordinate the timing and routing of original CITES documents and related certificates. | They should not assume that PDF copies or scanned documents are sufficient when originals may be required. | Confirm whether originals will arrive before import declaration and who will hand them to the customs broker. |
| Designated Customs Office and Routing | Freight forwarders can check whether the planned port, airport, and bonded receipt location are compatible with the designated customs office. | They should not decide routing solely by cost or schedule without confirming CITES-related customs office requirements. | If the planned route is unsuitable, consider changing the arrival port, airport, or bonded receipt location before shipment. |
| After-Arrival Issues | Freight forwarders can coordinate between the cargo owner, customs broker, warehouse, and overseas exporter when issues arise after arrival. | They should not guarantee that delayed documents, expired certificates, or missing approvals can be cured after arrival. | Clarify storage fees, return costs, disposal risks, and responsibility for additional expenses as early as possible. |
4-Point Checklist
| Verification Stage | Party to Verify With | Items to Check | Action if Issues Are Found |
|---|---|---|---|
| Quotation and Import Consultation | Shipper / Importer | Confirm whether the cargo contains any materials derived from animals or plants. | If unclear, request composition sheets, material certificates, or manufacturer documentation. |
| Pre-Shipment | Overseas Exporter / Shipper | Confirm plans for obtaining CITES Export Permits, sending originals, and managing validity periods. | If permits have not been obtained, consider delaying shipment or changing routing. |
| Import Approval / Prior Confirmation | Importer / Application Responsible Person | Confirm whether a Certificate of Import Approval or Certificate of Prior Confirmation is required. | If needed, secure application and acquisition timelines before cargo arrival. |
| Booking and Determining Bonded Receipt Location | Freight Forwarder / Customs Broker | Verify whether the arrival point and bonded receipt location allow declaration at the designated customs office. | If declaration at the designated customs office is not possible, change the arrival port or bonded receipt location. |
| Before Import Declaration | Customs Broker / Importer | Check consistency among CITES documents, invoice, packing list, B/L, and AWB. | If discrepancies exist, prepare corrections or supplementary documents before declaration. |
| NACCS Data Entry | Customs Broker | Confirm whether to enter information in fields for other laws, the Import Trade Control Order, and Certificate of Import Approval-related information. | If unsure, consult customs or review related documents. |
| Customs Inquiry | Customs Broker / Importer / Manufacturer | Ensure the ability to explain scientific names, country of origin, composition, materials, quantity, and intended use. | Submit additional manufacturer documents, photos, catalogs, or composition sheets as needed. |
| Original Document Management | Freight Forwarder / Customs Broker / Importer | Check whether original documents are available before cargo arrival or at the time of declaration. | If originals have not arrived, re-check timing of declaration, storage, and risks of return shipment. |
Common Practical Issues
| Case | Likely Issues | Documents to Check | Recommended Approach |
|---|---|---|---|
| Importing crocodile leather bags as ordinary bags | There is a risk of overlooking CITES applicability by judging solely from the product name as ordinary cargo. | Check scientific name, country of origin, tag number, CITES Export Permit, and invoice. | Always verify the species and country of origin when leather materials are involved. |
| Animal-derived ingredients in Kampo medicines or health supplements | Ingredient names may be generic, making it unclear whether they fall under CITES-regulated species. | Check ingredient list, raw material specification, scientific name, manufacturer certificate, and Food Sanitation Act-related documents. | Confirm separately for CITES, the Food Sanitation Act, and the Pharmaceuticals and Medical Devices Act (PMD Act). |
| Use of rare wood, ivory, or tortoiseshell in musical instruments | The overall product name may cause oversight of restricted components. | Check material certificates, manufacturing year, photos, serial numbers, scientific names, and CITES documents. | Verify applicability at the component level. |
| Importing plants such as orchids or cacti | Both CITES and plant quarantine requirements may apply. | Confirm scientific name, Appendix classification, CITES documents, plant quarantine certificate, and the need for import approval or prior confirmation. | Do not assume quarantine is unnecessary based solely on CITES documentation. |
| Plant-derived ingredients in cosmetic raw materials | The raw material subject to regulation may be hidden by the finished product name, leading to overlooked CITES checks. | Check ingredient list, raw material specifications, scientific name, country of origin, and PMD Act-related documents. | Confirm regulated species at the raw material stage. |
| Importing small samples via international courier | There may be a misconception that procedures are unnecessary due to small quantity or no charge. | Check product documents, ingredient list, scientific names, CITES documents, and courier handling policies. | Determine applicability based on species and international movement, not quantity or value. |
| Discovering CITES applicability after cargo arrival | Requires obtaining originals, changing the declaration office, incurring storage fees, and may cause delivery delays. | Check arrival data, bonded receipt location, CITES documents, designated customs office, and customs consultation records. | Make pre-shipment verification standard practice rather than only responding after arrival. |
| Expiry of export country CITES documents approaching | Documents may expire before import declaration, creating a risk that customs clearance cannot proceed. | Confirm issuance date, expiry date, shipping date, arrival date, and planned import declaration date. | Manage document validity and customs clearance schedule simultaneously. |
Response When Identified After Cargo Arrival
If it is determined after cargo arrival that the shipment is subject to the Washington Convention (CITES), the response will vary depending on the stage at which this is found.
| Stage of Identification | Main Actions | Common Issues | Practical Considerations |
|---|---|---|---|
| Before Vessel or Flight Arrival | Arrange original documents, confirm the need for import approval and prior confirmation, verify the designated customs office, and consider changing the arrival location. | Delays in document arrival, amendments to shipping documents, and review of the port or airport of arrival. | There may still be room to adjust the transportation route. |
| After Bonded Receipt, Before Declaration | Confirm other regulatory requirements through the customs broker, consult customs, obtain additional necessary documents, and confirm the declaration office. | Storage charges, loading and unloading fees, bonded transport costs, and declaration delays may occur. | Priority should be given to verifying the relationship between the bonded area and the designated customs office. |
| After Import Declaration, During Customs Examination | Respond to customs inquiries, submit original CITES documents, provide component lists and scientific names, and make declaration corrections. | Extended examination periods, delivery delays, and insufficient supplementary documentation. | Promptly gather documentation from the shipper and manufacturer. |
| If Required Documents Cannot Be Obtained | Consider return shipment to the exporter, reloading, disposal, transaction cancellation, and consultation with relevant authorities. | Return shipping costs, disposal fees, storage charges, contractual disputes, and administrative issues may arise. | Costs should be clarified on the assumption that the import declaration may not be approved. |
| If Originals Do Not Arrive | Confirm the whereabouts of originals, track them via international mail or courier, and verify the possibility of reissuance. | Customs hold, storage fees, and delivery delays may occur. | Do not assume copies are sufficient; confirm with the customs broker and customs authorities. |
| If Validity Period Has Expired | Consider the possibility of reissuance, return shipment, reloading, and consultation with customs. | Declaration refusal, return shipping costs, and contract disputes may arise. | Do not rely on post-expiry remedies; ensure strict management before shipment. |
Example 1: Importing Crocodile Leather Bags
When importing crocodile leather bags, a description on the invoice such as “Bag” or “Leather Bag” is insufficient to determine whether the goods fall under CITES regulations.
In practice, it is necessary to verify the crocodile’s scientific name, country of origin, country of manufacture, exporting country, tag numbers, and the exporter’s CITES Export Permit or CITES Re-export Certificate. If required, import approval or confirmation at the time of customs clearance in Japan may also be involved.
If the original documents do not arrive before the cargo, or if the quantity and tag numbers on the documents do not match the actual cargo, customs clearance may be delayed, resulting in storage fees or delivery schedule delays.
Example 2: Importing Kampo Medicines and Health Supplements
Kampo medicines, health supplements, and cosmetic raw materials may contain animal- or plant-derived ingredients. It is not possible to determine CITES applicability based on product names alone, so ingredient lists and raw material specifications must be reviewed.
For example, when animal-derived components, plant extracts, or powdered raw materials are included, it is necessary to check the scientific name, country of origin, applicable parts, content amount, and Appendix classification. At the same time, compliance with other regulations such as the Food Sanitation Act, Pharmaceuticals and Medical Devices Act (PMD Act), and animal and plant quarantine laws may also be relevant.
Even small samples, research-use items, or pre-sale test products cannot skip CITES verification if they contain controlled species. It is important to separately organize CITES documentation and materials related to other regulations.
Example 3: When Cargo Is Identified as CITES-Listed after Arrival
After imported cargo has arrived in a bonded area, it may be determined to be subject to CITES through checks by the customs broker or inquiries from customs. In such cases, since the transportation route and bonded receipt location are already set, response options are limited.
The first points to confirm are whether original CITES documents from the exporting country are available, whether import approval or prior confirmation is required in Japan, whether the cargo can be declared at the designated customs office, and whether verification under other laws can be handled via NACCS.
If the necessary documents cannot be obtained, the import declaration may not be approved, leading to issues such as return shipment, reloading, disposal, or cancellation of the transaction. Since post-arrival handling tends to increase storage fees and delay deadlines, it is standard practice to confirm whether cargo is CITES-listed before shipment.
Relationship with Marine Cargo Insurance and Logistics Costs
If customs clearance is delayed due to incomplete CITES documentation or lack of required import approval, charges such as storage fees, demurrage, detention, return shipping costs, disposal fees, repacking costs, and additional delivery expenses may arise.
These costs are not necessarily covered under marine cargo insurance. Typically, marine cargo insurance covers accidental physical damage during transportation, while delays or expenses caused by customs document deficiencies, legal violations, absence of required approvals, or import regulations may fall outside the scope of coverage.
Therefore, when handling CITES-regulated cargo, it is important not to assume that insurance will cover the issue after the cargo arrives. Instead, confirm applicability, required documents, original document management, relevant customs offices, and cost responsibilities before shipment by sea or air.
Common Misconceptions
| Common Misconception | Actual Understanding | Practical Considerations |
|---|---|---|
| If the exporting country’s CITES documents are available, no procedures are required in Japan. | For some cargo, a Certificate of Import Approval or Certificate of Prior Confirmation is required on the Japanese side. | Confirm the exporting country documents and Japanese procedures separately. |
| Confirmation at the time of customs clearance means no prior preparation is needed. | Even in confirmation at the time of customs clearance, original CITES documents and their details are checked at import declaration. | Verify originals, validity periods, quantities, and scientific names before shipment. |
| A Certificate of Import Approval and an Import Permit Notice are the same. | A Certificate of Import Approval is issued under the import approval procedure of the Ministry of Economy, Trade and Industry, while an Import Permit Notice relates to approval of the import declaration by customs. | Do not confuse Certificate of Import Approval with Import Permit Notice in English translations. |
| Designated customs offices can be handled later by the customs broker. | CITES-related cargo may only be declared to customs at a designated customs office. | Confirm the port of arrival, airport, and bonded receipt location before shipment. |
| CITES procedures are unnecessary for small sample quantities. | Procedures may still be required even for small quantities, free-of-charge items, samples, or research use if the cargo involves regulated species. | Assess based on the species covered and international movement, not quantity or price. |
| If the product name does not include animal or plant names, it is exempt. | Regulated species may not be obvious from general product names. | Check scientific names, raw materials, ingredients, and material certifications. |
| NACCS input is a purely formal task. | For CITES cargo, verification under other laws and Import Trade Control Order-related entries affect customs examination. | Organize document numbers, approval numbers, and other regulatory codes carefully. |
| Costs from customs clearance delays are automatically covered by marine cargo insurance. | Costs arising from procedural defects or missing approvals may be excluded from marine cargo insurance coverage. | Confirm eligibility before shipment and clarify cost responsibilities rather than relying on insurance. |
Summary
Import customs clearance regulations under the Washington Convention (CITES) represent a critical verification area under other applicable laws when importing flora, fauna, and their products into Japan.
Simply understanding the CITES framework is not enough. In practical import operations, it is necessary to verify the scientific names of regulated species, the relevant Appendix classification, country of origin, export-side CITES documentation, Japan-side import approval, prior confirmation, confirmation at the time of customs clearance, designated customs offices, NACCS data entry, and original document management.
Freight forwarders are responsible for early identification of potential issues, transport planning, and coordination. Customs brokers handle pre-declaration verification under other laws and NACCS processing. Shippers and importers must secure product information and obtain the required permits, approvals, and certificates. Clearly defining these roles is essential to mitigate the risk of customs clearance delays after cargo arrival.
For CITES-controlled shipments, addressing requirements only after the cargo has arrived can be too late. Verifying species applicability, necessary documentation, designated customs offices, original document management, and cost allocation before shipment by sea or air is fundamental to avoiding customs delays and unexpected additional expenses.
