“I think that the Japanese culture is one of the very few cultures left that is its own entity. They’re just so traditional and so specific in their ways. It’s kind of untouched, it’s not Americanized.” – Toni Collette
Japan was the first Asian country to emerge as an economic force in the 1960s, so it has been an attractive market for electronic manufacturers and consumers for over 50 years. With the 11th largest population at around 127 million, and a gross domestic product – per person parity (GDP-PPP) ranked 5th in the world, it is easy to see why global companies want to quickly get their products on Japanese physical and virtual store shelves.
While the Japanese government regulatory agencies have developed their requirements based on widely used international standards, it is important to be attentive to the exact requirements and methods dictated by the agencies. If you have previous experience with obtaining certifications and approvals in this country, you know that they closely follow their rules down to the last letter and period. Because of this, it is critical that you not only learn their country-specific standards, but that you strictly follow the defined processes and procedures when submitting your product applications and paperwork.
If you are entering the Japan marketplace for the first time, it is highly recommended to hire an experienced regulatory consultant, familiar with the latest requirements as they frequently change as electronics equipment advances, especially since many Japanese consumers are early adopters of new technologies. This expense will be easily overshadowed by the amount of money and time that could be wasted by having an unsuccessful agency submittal, and possibly having to redesign the product.
Since there a multitude of types of modern electronic products, we are going to look at a common device, a portable personal computer. As with most current devices, this laptop could have multiple types of wireless communication modules, so it will be regulated by the Japanese government agency for radio wireless technologies, which is the Ministry of Internal Affairs and Communications. Additionally, since it is classified as information technology equipment (ITE), then the electromagnetic compatibility (EMC) criteria will be set by the Voluntary Control Council for Interference (VCCI) for ITE. And finally it must meet the legal requirements of the Japan Electrical Appliance and Material Safety Law if it receives operational power from both batteries and AC power mains. So let’s now take a look at each of these three certifications that must be obtained to sell and market a portable computer in Japan.
Wireless and Telecom Compliance
The Ministry of Internal Affairs and Communications (MIC) is the official government agency responsible for the administration organization of Japan, which includes regional decentralization, fire and emergency services, and oversite of telecommunications and information communications technologies (ICT). Two of the MIC bureaus, the Telecommunication Bureau and the Information and Communications Bureau, are involved in setting the criteria for wireless and telecom technologies, as well as the associated compliance programs. The Telecommunications Bureau is further split into two departments, the Telecommunications Business Department that is responsible for traditional “hard-wired” telecom products such as modems, and the Radio Department, which is responsible for wireless radio frequency devices and technologies like Wi-Fi, Bluetooth, or LTE.
The MIC Radio Department is tasked with ensuring that wireless communications devices that are imported, marketed, or sold within this country are in compliance with the Radio Act of Japan. That legislation was implemented to help ensure the fair and efficient use of the frequency spectrum in Japan, which is seen as a valuable but finite resource. Technical wireless/radio frequency (RF) standards are designated under the Radio Act, which applies to all products that use radio waves to transmit information, such as by voice or data. These standards define the available wavelengths, modulation type format, transmit power limits, transmission methodologies and other related criteria, all of which are set in order to prevent interference between various devices and technologies.
There are two types of conformity certification systems for radio devices. The first scheme is called Technical Regulations Conformity Certification, which is established in Article 38-6 of the Radio Law. This sets the requirements for obtaining product registration from a MIC-authorized Registered Certification Body (RCB) that performs the compliance testing and certification according to the radio equipment classification to verify the conformance prescribed technical standards. Additionally, this scheme covers the Certification of Construction Type by the RCB, as set forth in Article 38-24 of the Law, as they will certify the construction type for specified radio equipment, including quality control methodologies in manufacturing to verify conformance with the technical regulations. Typically testing is conducted on a single product sample for each specific type of mass-produced radio equipment.
The second type of radio conformity certification system is named Self-Confirmation of Technical Regulation Conformity, and is legislated in Radio Law Article 38-33. This is done by the manufacturer or product importer conducting the required verification tests, and confirming compliance with the specified technical regulations. This is only allowed when the construction category of the special specified radio equipment conforms to the designated technical regulations.
There are three classes, or categories, of wireless devices covered by the Radio Law. Class 1 is for wireless devices that can be operated without any broadcast licensing or registration requirements but do have compliance requirements. This includes low power radio products, such as those used in telemetry applications, or a wireless microphone. Class 2 includes industrial-type specified radio station devices, as defined in Article 27-2, such as mobile phones classified as LTE or 3G terminals. Class 3 covers products that have a mandatory requirement for a simplified license or registration process, such as a mobile phone base station or an amateur radio station.
Similarly, the MIC Telecommunications Bureau is responsible for overseeing the compliance programs defined under the Japan Telecommunications Business Act. The main purpose of this specific Act is business regulation, as it is intended to encourage a level playing ground for all telecom service providers. The technical standards for telecom terminal equipment (TTE) in Japan are indicated under the Telecommunication Business Act. These standards seek to set engineering criteria that will prevent damage to telecom lines and TTE or cause unwanted interference or other undesired effects on users of other TTE products, as well as defining the areas of responsibility for the companies and parties involved in manufacturing the product and bringing it to market in Japan.
TTE equipment has three types of conformity certification systems available to utilize to demonstrate compliance with the standards. The first option is called Technical Standards Compliance Certification, as established by the Business Act Article 53, and the certification rules contained in Articles 4 to 18. For this process, each separate type of TTE device is certified, by a RCB confirming compliance to the specific technical standards. Once the device is approved, then the MIC product marking is allowed to be applied, and the RCB is responsible for ensuring that the marking is correct for each approved product.
The second TTE scheme is named Design Certification, which is defined in the Business Act under Articles 56, 57, and 58, with the certification rules set in Articles 19 to 24. There is one certification granted for each individual product model, with the RCB confirming compliance. The marking approval requires three tasks, which are to: 1) obtain the certification mark from a RCB; 2) testing the design for compliance; and 3) retaining test records for at least ten years.
The third choice is Technical Standards Compliance Self-Check, as defined in Articles 63, 64, and 65, with the certification requirements given in articles 41 to 44. This requires a manufacturer to test and confirm compliance for each unique design, as well as filing the required documents and retaining the test records for ten years. Since an RCB is not involved, the manufacturer is responsible for all of these aspects.
Products that demonstrate conformity with the specified MIC criteria are issued a MIC certificate, and are required to have the MIC conformity mark and certification number printed on the product label. Products covered under the Radio Law show a certification number starting with “R” to the right of the MIC conformity mark, and products covered under Telecommunication Business Law have conformity numbers starting with “T” at the beginning.
Japan’s MIC is very active in market surveillance activities for both radio and telecom devices. These activities cover the whole range of compliance criteria, from purchasing product samples from stores and checking to verify that the technical criteria for limits are being met, to inspecting the MIC label on the device, to ensure that the proper MIC logo and certification numbers have been properly affixed and displayed. Any nonconformance can result in actions ranging from a warning to correct a minor issue to large fines and possible prison sentences for company officers in cases where major violations have been made intentionally by the manufacturer.
The Japan MIC agency has a mutual recognition agreement (MRA) with the U.S. Federal Communications Commission (FCC), with the U.S. National Institute of Standards and Technology (NIST) being the official government MRA negotiator for this technology trade agreement. Under the MRA, Japan’s MIC accepts FCC criteria and vice versa, for radio and telecommunications equipment. The Japan-U.S. MRA has been in place since January of 2008.
Once a year, in late February or early March, there is a two-day MIC MRA meeting hosted by MIC and associated government agencies to discuss wireless and radio requirements with MRA partner countries. This meeting is attended by representatives from the FCC’s Office of Equipment Testing (OET), and the FCC’s Telecommunications Certification Body (TCB) Council (www.tcbcouncil.org) which represents the interests of the testing labs that have been accredited to issue FCC Grants as a TCB.
EMC Compliance for ITE
The Japan Voluntary Control Council for Interference (VCCI) for ITE is managed by the MIC Information and Communications Council. Under this authority, the VCCI drafts, publishes, and approves Japanese technical EMC standards based on CISPR recommendations that address the limits and methods of measurement of EMI caused by ITE.
The VCCI was established in 1985 by four industry groups, the Japan Electronic Industry Development Association, the Japan Business Machine Makers Association, the Electronic Industries Association of Japan, and the Communications Industry Association of Japan. The VCCI is a not-for-profit foundation that operates this voluntary control scheme to protect Japanese consumers, and their standards are based on CISPR 22. While this EMC conformance scheme for computer products is not a legal requirement, it is seen as a de-facto marketing requirement, especially for selling products to large corporations and government agencies.
Once a year, in late February or early March, there is a one-day VCCI workshop that follows the previously mentioned MIC MRA meeting. Held in Tokyo and hosted by the VCCI and associated government agencies, this workshop focuses on the latest EMC requirements for ITE equipment and related updates. This event is a prime opportunity to meet VCCI agency staff members and network with other interested stakeholders.
Product Safety Compliance
In Japan, the Ministry of Economy, Trade, and Industry (METI) has established the DENAN product scheme for ensuring compliance with Japan’s Electrical Appliance and Material Safety Law. The purpose of this law is to regulate manufacturers of electronic and electrical products, so that the safety and well-being of people and property is assured. Any organization that manufactures or imports these types of devices has a legal obligation to participate in this METI program and ensure that their products are in compliance.
Local Japanese companies must notify METI when they start their production but, for products produced outside of Japan, it is the responsibility of the importer to obtain the proof of conformity prior to entering the Japanese marketplace, including having the proper PSE safety approval markings that include the name of the importer. For specific types of equipment, importers must obtain a third-party product conformity assessment, or secure an official equivalency certificate through specified manufacturers.
Japan is a member country of the IECEE’s Certification Body (CB) Scheme, so CB-type reports can be utilized to demonstrate compliance as long as testing addresses the unique Japanese AC voltage and current requirements.
Next Steps
Even though the Japan compliance requirements and processes can seem difficult and bureaucratic, it becomes easier once you have some experience with submittals. Again, be sure to secure the services of experienced compliance agents as needed, and take advantage of the government agency websites as they are a valuable source of information as well.
As a reminder, please note that you shouldn’t rely on this one article alone for information on submitting your products for Japanese government approvals. As with all other countries, the official standards should be referenced, and an experienced regulatory agent should be utilized if in-house expertise is not available. In addition, customs facilitators can be an invaluable resource for getting your products to successfully pass through the customs and importation processes when they enter Japan.
In closing, compliance engineering and regulatory compliance professional organizations can help you to stay up-to-date on the latest developments and updates for regulatory compliance information. Local and regional chapters of the Institute of Electrical and Electronics Engineers (IEEE), especially the IEEE EMC Society and the IEEE Product Safety Engineering Society, hold monthly meetings with interesting presentations, and provide opportunities to network with fellow compliance engineers on the latest requirements. Finally, the most useful social media site for professionals I have found is LinkedIn, which has a number of regulatory compliance engineering “groups” that are free to LinkedIn subscribers.
Internet Resources
- Japan Ministry of Internal Affairs and Communications (MIC) website (English version)
- Japan Voluntary Control Council for Interference by Information Technology Equipment (VCCI) website (English version)
- VCCI Frequently Asked Questions webpage
- Japan Ministry of Economy, Trade, and Industry (METI) webpage for the “DENAN” Electrical Appliance and Material Safety Law (English version)
- U.S. Federal Communications Commission (FCC) homepage
- U.S. National Institute of Standards and Technology (NIST) homepage
- IEC System of Conformity Assessment Schemes for Electrotechnical Equipment and Components (IECEE)
- IEEE website
References
All geographic, economic, and population information and maps comes from the Central Intelligence Agency “World Factbook,” and is allowed for public domain use if given credit in the article. URL: www.cia.gov/library/publications/the-world-factbook/
Mark Maynard is Director of Business Development and Marketing at American Certification Body, Inc. He is an IEEE Senior Member, and also serves on the IEEE 2017 EMC Symposium Committee as the Exhibition and Trade Show chairperson. He can be reached at mmaynard@ieee.org.
