This article contains information on the importation of electrical appliances and material. Relevant laws include the Electrical Appliance and Material Safety Law, the Radio Law, the Public Management Law (Pachinko Machines).
When importing electrical goods, a number of laws may be relevant, including the Electrical Appliance and Material Safety Law, Consumer Product Safety Law, Household Goods Control Law, Household Goods Quality Labeling Law, Industrial Standardization Law (JIS Law), Home Appliance Recycling Law, Law for Promotion of Effective Utilization of Resources, Energy Conservation Law, Radio Law (wireless communication equipment), Telecommunications Business Law (Devices for communication terminal), Water Supply Law (water supply equipment), and Entertainment Law (pachinko machines). In addition, the Food Sanitation Law (juicers, coffee makers) and the Pharmaceutical Affairs Law (medical devices such as electric massage machines), which have already been explained, may also be relevant.
Electrical Appliance and Material Safety Law
1 General Information
The Electrical Appliance and Material Safety Law regulates the manufacture, import, and sale of a wide range of electrical appliances and materials in order to ensure the safety of electrical appliances and materials.
2 Notification of Manufacturers and Importers
A manufacturer or importer of electrical appliances and materials must notify the Minister of Economy, Trade and Industry of its address and the type of electrical appliances and materials it handles within 30 days of the commencement of its business. In addition, foreign corporations that have not registered a branch office or a representative in Japan are not allowed to submit the notification1.
3 Compliance with Safety Standards and PSE Mark
A manufacturer or importer of electrical appliances and materials shall comply with the technical standards when manufacturing or importing electrical appliances and materials (Article 8, Paragraph 1)2. The relevant standards are set forth in the “Ministerial Ordinance on the Technical Standards for Electrical Appliances and Materials”.
In the case of specified electrical appliances and materials (electric pumps, vending machines, electric toys, etc.3), a technical standards conformity inspection must be conducted by a registered inspection body and a certificate of conformity must be issued (Article 9 of the same law). In the case of other electrical appliances (electric kotatsu, electric refrigerator, electric razor, electric stand,), the inspection shall be conducted voluntarily, and the inspection records shall be prepared and stored (Article 8, paragraph 2).
Manufacturers and importers of electrical appliances and materials may display the PSE Mark4 on their electrical products if they have fulfilled the above obligations, while sales of electrical appliances and materials without the PSE Mark are prohibited (Article 27).
specified electrical appliance5
l Electric water heaters
l Electric heating and electric toys
l electric pumps,
l electric massagers,
l vending machines,
l DC power supply equipment
and more than 100 other items
It is necessary to pass a conformity inspection by a registered inspection body. Self-inspection is not sufficient.
As of the date of publication of this document, the registered inspection bodies include Intertec Japan K.K., TÜV Rheinland Japan K.K., the Research Institute of Electrical Safety and Environment, the Japan Quality Assurance Organization, and the Electric Wire Technical Center. For details, see the METI website.
Other Electrical Appliances
Electric kotatsu/electric kettle/ electric refrigerator/electric toothbrush/electric razor/incandescent lamp/electric stand/television receiver/audio equipment/lithium-ion storage battery
and more than 300 other items
It is necessary to pass a conformity inspection, but inhouse inspection is also acceptable.
Note that smartphones and notebook computers are basically exempt from PSE as enumerated, but lithium-ion batteries and AC/DC adapters are subject to PSE, so it is easy to make a wrong judgment.
4 Long-term use of product safety indication system
For certain products (fans, air conditioners, electric washing machines and electric dehydrators, CRT televisions, ventilation fans) that often cause accidents due to aging and deterioration, labeling of standard use periods and precautions is mandatory6.
1 About the Radio Law
Radio waves are used in various technologies such as smartphones, WI-FI (wireless LAN), radios, and drones, and the Radio Law regulates the use of radio waves.
Radio waves are limited in frequency, and radio waves of the same frequency interfere with each other, making it impossible to listen to the radio if an illegal wave is broadcast.
Therefore, technical standards and specifications for frequency distribution and management have been formulated, and a licensing system for the establishment of radio stations has been established.
2 What is a license under the Radio Law?
When establishing a radio station that transmits radio waves, it is necessary to obtain a “radio station” license (Same law 4 this article).
The term “radio station” may conjure up images of large-scale equipment, but cell phones, wireless microphones, transceivers also emit radio waves and thus fall under the category of radio equipment.
Therefore, the Radio Law states that if there is no or little risk of interference between radio waves, there is no need to obtain a license7. Specifically, in the cases listed in the following table, no license is required.
weak-wave wireless equipment
A license is not required if only equipment that emits extremely weak radio waves8 is used. Exceptions may be made for in-vehicle FM transmitters9, wireless microphones, remote controls, car keyless entry, wireless headphones, radio-controlled devices, anti-shoplifting devices, and RFID devices.
Civil Radio Station
No license will be required for civil radio stations using radio equipment (limited to those with a technical compliance mark).
Low-power special-purpose radio stations
(Low-power radio station)
A license is not required for radio stations using low-power radio equipment for certain applications (limited to those with a technical compliance mark). A wide variety of applications have been specified, including low-power security systems (home security, fire alarms), low-power data communication systems (wireless LAN, Bluetooth), and cordless phones.
Simplified radio station
For the following types, registration is considered to be sufficient instead of a license10
・PHS radio station base stations (with an aerial power of 1 watt or less) and repeaters
・Premises radio stations (920 MHz band/2.4 GHz band)
・Base stations for radio access systems (5 GHz band)
・Digital simplex radio stations (350 MHz band)
Since the general public uses radio equipment (cell phones) without obtaining a license or registration, it is considered important for manufacturers/importers to make products with the “weak radio mark11” (see (1)) or with the “technical conformity mark” [for low-power radio stations] (see (3)) if they want to make them widely available to the general public.
None of the exceptions in (1) through (4) above can be utilized for cell phones. For cell phones, the base station and the handset (corresponding to a land mobile station) are considered as a pair, and the cell phone operator is supposed to apply for a license for both, so the user does not need to apply for a license under the Radio Law.
3 Standard Certification System under the Radio Law
The Radio Law stipulates the technical standards specified in the Radio Law for a certain range of radio equipment, “Specified Radio Equipment”. to be used for small-scale radio stations, and a system has been established in which a person registered by the Minister of Internal Affairs and Communications (registered certification body) judges whether or not the equipment complies with the relevant standards.
The following table simplifies the licensing procedures for radio stations that use radio equipment bearing the technical conformity mark.
Translation of [Source: Japan Electronics and Information Technology Industries Association (JEITA) website.]
First, for specified low-power radio stations, Wi-Fi, Bluetooth, BLE, Zigbee, etc., no license or registration is required as long as the radio equipment with the technical compliance mark is used (Category 1 above; Article 38-2-2, Paragraph 1, Item 1 of the same law).
Second, in the case of cell phones, 5G, LTE and WCDMA handsets (“specified radio stations”), a comprehensive license can be obtained, eliminating the need for inspections of each individual radio installation (Category 2 above; Article 38-2-2, Paragraph 1, Item 2 of the same law). Taking cell phones as an example, it is not necessary for users to open their own radio stations to use cell phones, since telecommunication carriers, etc. have obtained a comprehensive license in advance on behalf of the actual users.
Third, in the case of base stations other than those mentioned above (radio buoys, on-premises radio), these devices can be used by eliminating the need for inspection when obtaining a license, or by substituting a simpler radio station registration for obtaining a license (Category 3 above; Article 38-2-2, Paragraph 1, Item 3 of the same law).
4 Obtaining the “Technical conformity mark” based on the Radio Law
Under the licensing and registration system mentioned in the previous section, most of the radio equipment in general use bears the mark of Technical Regulations Conformity Certification, the so-called “Technical Conformity Mark”.
For example, the wireless LAN-compatible router (manufactured by NTT) for my personal use, has a technical compliance mark as shown below.
Ｔ Certification Number：××× ×× ×××× ×××
Ｒ Certification Number：×××―××××××
The Ｒ mark is an indication of conformity to the technical standards (“Technical Regulations”) under the Radio Law. It is often attached to things that generate radio waves such as wireless microphones, transceivers, cell phones, routers.
The Ｔ mark is an indication of compliance with technical standards under the Telecommunications Business Law.
It is often attached to terminals that connect to the facilities of a telecommunications carrier such as NTT’s communication facilities, (smartphones/old cell phones, analog phones, fax machines, and routers.
Basically, devices that do not have the technical compliance mark on them cannot be used in Japan. The same applies to imported foreign products, as it will explained in the next section.
The requirements and standards for obtaining the “technical conformity mark” are specified in the “Regulations Concerning Technical Regulations Conformity Certification of Specified Radio Equipment”.
In order to obtain the “technical conformity mark”, a conformity inspection to the technical standards12 by a registered certification body is required. However, there have been certain exceptions such as the special specified radio equipment. If the contractor verifies the construction design by himself and confirms that it conforms to the technical standards, the contractor can be considered to have obtained the technical standards conformity certification. The “Technical conformity mark” can be obtained by submitting the prescribed notification to the Minister of Internal Affairs and Communications after self-confirmation (Article 38-33 of the same law).
For specific test methods, please refer to the website13 of the Ministry of Internal Affairs and Communications.
5 Regulations on imports
In relation to imports, the Radio Law provides for exceptions to the importation of radio equipment. First of all, in order to import “specified radio equipment” from overseas and use it in Japan without a license, it is necessary to obtain a technical standards conformity certification from a registered certification body and attach a technical conformity mark (Article 38-6 of the same law). Even if a product already has an American FCC mark standard or the European EC mark standard affixed to it, indicating that it has undergone conformity assessment under foreign standards, it must be given a new Japanese technical compliance mark.
However, when importing products from countries that have concluded a Mutual Recognition Agreement (MRA), such as the U.S., Europe, and Singapore, if the product is certified by a certification body in these countries, it will be treated as if it has obtained a Technical Regulations Conformity Certification and can bear the Technical Regulations Conformity Mark12.
In addition, importers who imports transceivers of foreign standards shall endeavor to avoid importing radio equipment that does not conform to the technical standards specified in the Radio Law (Article 102-11, paragraph 1 of the same law). When a radio station using equipment that does not conform to such standards is likely to interfere with the radios of other radio stations or cause serious adverse effects on their operation, the Ministry of Internal Affairs and Communications may issue recommendations and orders to take the necessary measures (Article 102-11, Paragraph 2 and Paragraph 4 of the same law)14.
Public Management Law (Pachinko Machines)
The Entertainment Establishments Control Law does not specifically regulate the importation of pachinko machines, but prefectural approval is required for the replacement of pachinko machines (Application mutatis mutandis of Article 9, paragraph 1 pursuant to Article 31-23 of the Act), and pachinko machines cannot be used for pachinko business unless they do not meet the standards set by the National Commission (Article 20, Paragraph 1 of the Law).
As a result, approval for machines to be installed in pachinko parlors cannot be granted unless the Public Safety Commission certifies that the machines in question do not meet the standards set by the National Commission, effectively making it impossible to install them. Application procedures for certification are described in the “Regulations Concerning Certification and Model Approval of Amusement Machines”. If the type has already been verified, this approval procedure will be simplified.
Therefore, as an importer, it is useful to apply for certification for pachinko machines (Article 20, Paragraph 4 of the Law) and obtain approval for the model of the machine to be imported before importing the machine.
1 See Product Safety Division, Ministry of Economy, Trade and Industry, “Questions Concerning the Electrical Appliance and Material Safety Law” (regarding the possibility of notification by overseas businesses).
2 With the approval of the Minister of Economy, Trade and Industry, except in the case of experimental manufacture and import (proviso of paragraph 1 of the same Article).
3 For details, see Appendix 1 of the Enforcement Order.
4 PSE stands for “Product Safety” and “Electronic Appliance and Materials”.
5 The specific scope of “specified electrical appliances” and “other electrical appliances and materials” in relation to the Electrical Appliance and Material Safety Law is described in the upper and lower columns of Appendix 1 and 2, respectively, of the Enforcement Order of the Law.
6 Article 8, paragraph 1 of the same law, and Article 20 of the Ministerial Ordinance on the Technical Standards for Electrical Appliances and Materials.
7 See the proviso of Article 4 of the Act and the items of the same Article. For more details, see the Ministry of Internal Affairs and Communications’ website on “Radio Utilization HP – Radio Stations Not Requiring License or Registration.
8The standard for “extremely weak” differs for each frequency, but the electric field strength at a distance of 3 meters from the radio station is (1) 500 microvolts per meter or less for frequencies of 322 Mhz or less, (2) 35 microvolts per meter or less for frequencies of 322 Mhz to 10 GHz, and (3) 150 microvolts per meter or less for frequencies of 10 GHz to 150 GHz. is … etc. (Article 6, Paragraph 1, Item 1 of the Regulations). The standard for radio-controlled oscillators and radio microphones is a field strength of 200 μV/m or less at a distance of 500 meters from the radio equipment. The details are specified in the Ministry of Internal Affairs and Communications public notice (“Uses and Radio Types and Frequencies of Radio Stations Not Requiring a License under Article 6, Paragraph 1, Item 2 of the Ordinance for Enforcement of the Radio Law”). The details are specified in the Notification of the Ministry of Internal Affairs and Communications (“Uses, Types and Frequencies of Radio Stations Not Requiring a License under Article 6, Paragraph 1, Item 2 of the Enforcement Regulations of the Radio Law”).
9 An FM transmitter is a device used to listen to music from a device connected to the car’s cigarette lighter socket through the FM radio equipment in the car.
10 See Article 4, Item 4 of the Law and Article 16 of the Regulations.
11 The Japan Automobile Manufacturers Association (JAAMA) and the Electro-Magnetic Compatibility Council (EMCC) are voluntarily attaching the “weak radio conformity mark” (ELP mark) to weak radio equipment that has been fairly tested and conforms to the technical standards for weak radio equipment. Although it is not obligatory to affix the ELP mark, it enables users to confirm that the equipment is weak radio equipment at the time of purchase.
12 See “Regulations Concerning Technical Regulations Conformity Certification, etc., of Specified Radio Equipment”.
13 Ministry of Internal Affairs and Communications, “Radio Utilization Homepage – List of Specified Radio Equipment and Special Specified Radio Equipment”.
14 Article 33 of the “Law Concerning the Implementation of Mutual Recognition between Japan and Foreign States of the Results of Conformity Assessment Procedures for Specified Equipment
Please contact us if you have any questions.