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  6. Procedures of the Notifying Suppliers based on the Act

Procedures of the Notifying Suppliers based on the Act

Flow of Procedures for Notifying Suppliers

1. Confirm Names of Electrical Appliances and Materials

  • Specified Electrical Appliances and Materials(Category A)
  • Non-Specified Electrical Appliances and Materials(Category B)

2. Notify Commencement of Business to METI

3. Comply with Technical Requirements

4. Conduct Self-Inspection

6. Affix PSE Labeling

Place on the Market in Japan

Flow of Procedures for Notifying Suppliers

1. Confirmation of the Names of Electrical Appliances and Materials

To begin with, confirmation is made of whether the electrical products correspond to "electrical appliances and materials" in the scope of the Act. Generally, products and parts that are connected to an AC power supply for use may fall under Electrical Appliances and Materials.
"Electrical appliances and materials" are designated in Appended Table 1 and 2 of the Order for Enforcement of the Electrical Appliances and Materials Safety Act. "Electrical appliances and materials" are divided into 20 classifications, with each category having an "electrical appliance and material name" and determinations made of the targeted sphere (upper limits of rated power consumption, etc.). There are names of electrical appliances and materials for 457 items (as of March, 2019), with 116 of those items determined to be Specified Electrical Appliances and Materials, which are especially liable to cause hazards and/or threats of troubles occurring. The other items (Non-Specified Electrical Appliance and Materials) are classified into 341 items. The procedures required for Notifying Suppliers differ depending upon the category into which an item is assigned.
Appropriate names of Electrical Appliances and Materials are determined according to the following criteria:

  1. Determine the name by the intended use, function, etc. rather than by the model name or other general names.
  2. If two or more functions are provided, consider the names of all the functions.
  3. To determine whether a product is subject to control under the Act or not, the information about it, such as the structure and ratings are needed.
  4. Parts packed with the equipment must also be checked.

What item fail to correspond to “Electrical Appliances and Materials”?

All electrical products do not fall under the category of Electrical Appliances and Materials Safety Act.
The Electrical Appliance and Material Safety Law targets electric products directly connected to indoor wiring equipment in general households (defined as being directly supplied with electricity from power outlets). Accordingly, electric product main units operated through detachable AC adaptors*1 and items operated by batteries are not targeted under this category.
Examples:

  1. Electric product main units operated through detachable AC adaptors (game machines、synthesizers, rechargeable electric shavers, etc.)
  2. Electric products supplied with electricity through amplifiers (speakers, electric guitars, microphones and other products without built-in amplifiers)
  3. Certain telecommunications equipment (personal computers*2、PC peripheral equipment, telephones、facsimiles, amateur radio sets, etc.)

*1. AC adaptors themselves are targeted as Specified Electrical Appliances and Materials (DC power source devices).
*2. Some personal computers with TV tuner are targeted

2. Notification of the Commencement of Business to METI

Manufacturers and Importers of the electrical products that fall under Electrical Appliances and Materials (Notifying Suppliers) must notify METI of such business within 30 days from the commencement of the business, in submitting the Notification of Business for Manufacturing/ Importing Electrical Appliances and Materials.
Notifications are required for each of the type classifications of the Appended Table 1 of the regulation for Enforcement of the Electrical Appliances and Materials Safety Act with the matters of notification requirements as follows;

Notifying Suppliers must also notify METI when they transfer such business to someone else, when they change the content of the business, and when they decide to discontinue such business.

Classification of Electrical Appliances and Materials (Appended Table 1 of the regulation for Enforcement of the Electrical Appliances and Materials Safety Act)
  Classifications of Electrical Appliances and Materials
1 Rubber insulated electric wires (electric wires or electric floor heating wires with rubber insulation)
2 Synthetic resin insulated electric wires (electric wires or electric floor heating wires with insulation of synthetic resin or other materials other than rubber)
3 Metal conduits
4 Metal conduit accessories (accessories of metal conduits or flexible conduits or cable wiring switch boxes)
5 Plastic conduits (rigid or flexible conduits of plastic or other materials (other than metal))
6 Plastic conduit accessories (accessories of plastic conduits or flexible conduits or cable wiring switch boxes)
7 Link fuses
8 Covered fuses (fuses other than link fuses and thermal fuses)
9 Thermal fuses
10 Wiring devices
11 Current limiters
12 Single-phase small power transformers (single-phase small power transformers, voltage regulators, or electric-discharge lamp ballasts)
13 Small AC electric motors
14 Electric heating appliances
15 Motor-operated mechanical devices
16 Luminaries and optical appliances and machines
17 Electronic appliances (including those listed in (viii) in Appendix Table 1 of the Order for Enforcement)
18 AC electrical appliances (including those listed in (ix) in Appendix Table 1 and (xi) in Appendix Table 2 of the Order for Enforcement)
19 Portable power generators
20 Secondary lithium ion batteries (those listed in (xii) in Appendix Table 2 of the Order for Enforcement)

3. Obligation to conform to the Technical Requirements

Notifying Suppliers must comply their products with the Ministerial Order to Provide Technical Standards for Electrical Appliances and Materials, in which the technical requirements correspond for all Electrical Appliances and Materials are stipulated as essential requirements.
The concrete technical standards harmonized with these essential requirements are denoted in the Circular Notice of Interpretation for the Ministerial Order to provide Technical Standards for Electrical Appliances and Materials, in which there are two types of technical standards — the traditional Japanese standards in the Appendix Table 1 to 11, and the standards based on IEC standards with some deviations*1) in the Appendix Table 12. While the Notifying Suppliers may freely choose which type of technical standards to apply, it is not possible to select and apply mixture of the technical standards in the Appendix Table 1 to 11 with the standards in the Appendix Table 12 except as otherwise expressly provided.
It is necessary to note that satisfying the foreign standards does not mean fulfillment of the obligation in the Electrical Appliances and Materials Safety Act, even if the products have earned the CE mark or the UL mark.

Outline of the harmonized technical standards In the Circular Notice of Interpretation for the Ministerial Order to provide Technical Standards for Electrical Appliances and Materials
  Type of Electrical Appliances and Materials
Appendix Table 1 Electric Wires and Electric floor heating wires
Appendix Table 2 Conduits, floor ducts and raceways including their accessories.
Appendix Table 3 Fuses.
Appendix Table 4 Wiring devices.
Appendix Table 5 Current limiters.
Appendix Table 6 Single-phase small power transformers and electric-discharge lamp ballasts.
Appendix Table 7 Small AC motors specified by Paragraph 6 of Appendix 2 of the Order for Enforcement of the Electrical Appliances and Materials Safety Act
Appendix Table 8 AC Electric/Mechanical Appliances and Portable power generators specified by “Paragraphs 6 to 9 of Appendix1” and “Paragraph 7 to 11 of Appendix 2”of the Order for Enforcement of the Electrical Appliances and Materials Safety Act
Appendix Table 9 Secondary lithium ion batteries.
Appendix Table 10 Electro Magnetic Interference.
Appendix Table 11 Maximum limit of the temperatures used of the Insulations used in the Electrical Appliance and Materials.
Appendix Table 12 Standards harmonized with the international standards or the equivalent.

*1) Because grounding outlets are not common in Japan, and the earthing system for electric power distribution lines is different between Japan (TT earthing system) and Europe (TN earthing system), it is necessary to ensure safety concerning Electrical Appliances and Materials. On the other hand, the standards for protection against electrical shocks have been eased because of the lower power supply voltage. These are the major reasons for these deviations.

No particular stipulations are made with regard to the methods to use for compliance conformation to the technical standards. Generally speaking, however, because of the difficulties involved for importers in confirming compliance with technical standards on their own, this obligation may be fulfilled through methods that include the following;

  1. Request that testing be performed by overseas manufacturers, with the said test reports obtained and compliance confirmed.
  2. Request that testing be performed by conformity assessment bodies.

Exemption of Standards Compliance

When the electrical appliances and materials should be utilized for the specified purposes, the technical standard compliance obligation may be waived with approval from the Minister of Economy, Trade and Industry. Such approval can be obtained for the products to be sold to foreign travelers (products that are in compliance with foreign standards and used in other countries), the products used in special locations, the antique lighting stands, etc.

4. Obligation to Conduct Self-inspections

Notifying Suppliers are obliged to conduct Self-inspections of Electrical Appliances and Materials to confirm their conformity to technical requirements, as well as preserve records of such inspections for three years, in accordance with the Regulation for Enforcement of the Electrical Appliances and Materials Safety Act.
There are difference in the methods of Self-inspections between the Specified Electrical Appliances and Materials (Category A) and the Non-Specified Electrical Appliances and Materials (Category B).

Self-inspections for the Specified Electrical Appliances and Materials

The Self-inspections for the Specified Electrical Appliances and Materials (Category A) consist of three types of inspection;

  1. Inspection conducted in manufacturing processes
    This inspection must be conducted constantly with respect to the structure, material, and performance of said Specified Electrical Appliances and Materials by a method deemed appropriate for ensuring conformity to technical requirements according to the manufacturing method.
  2. Inspection conducted on finished products
    This inspection must be conducted on every finished products, in other words, on a product-by-product basis. Test items of the inspection differ depending on the type of Specified Electrical Appliances and Materials as following table.
Test Items of the Inspection Conducted on Finished Products for the Specified Electrical Appliances and Materials
Specified Electrical Appliances and Materials Test Items
Fuses (thermal fuses with a container, excluding fuses with a container that is not charged) Appearance
Circuit-breakers Appearance, Dielectric strength, Energization,
Overcurrent tripping characteristics
Earth leakage circuit-breakers Those of fast operating type Appearance, Dielectric strength, Energization,
Overcurrent tripping characteristics
Leakage current protection characteristics
Others Appearance, Dielectric strength, Energization,
Overcurrent tripping characteristics
Meter-rate current limiters Appearance, Dielectric strength, Energization,
Operating characteristics
Appliances listed from No.6 to No.10 in the Appended Table 1 of the Order for Enforcement that have an automatic switch activated by a temperature change and used as an over-temperature protection system Appearance, Dielectric strength, Energization,
Operating characteristics of the automatic switch operated by thermal cutouts.
Other Specified Electrical Appliances and Materials Appearance, Dielectric strength, Energization
  1. Inspection conducted on samples
    Inspection on samples extracted randomly from materials, parts, semi-finished and completed products of Specified Electrical Appliances and Materials must be conducted by the test methods to conform Technical Requirements when changes are made to the materials, design, manufacturing method, or manufacturing equipment.

Self-inspection for the Non-specified Electrical Appliances and Materials

In case of the Non-Specified Electrical Appliances and Materials (Category B), it is adequate only to conduct inspection on finished products as the obliged Self-inspection. This inspection must be conducted on every finished products, in other words, on a product-by-product basis. Test items of the inspection differ depending on the type of Non-Specified Electrical Appliances and Materials as following table.

Test Items of the Inspection Conducted on Finished Products for the Non-Specified Electrical Appliances and Materials
Non-Specified Electrical Appliances and Materials Test Items
  • Conduits, their accessories and cable wiring switch boxes
  • Fuses
  • Incandescent lamps
  • Fluorescent lamps and lights designed for decorative purposes
Appearance
  • Belt conveyers
  • Barber chairs
Appearance, Dielectric strength
  • Secondary lithium ion batteries
Appearance, Output voltage
  • Other Non-Specified Electrical Appliances and Materials listed in the Appended Table 2 of the Order for Enforcement
Appearance, Dielectric strength, Energization,
 

Self-inspection Records

Notifying Suppliers are required to custody the inspection records including following six items.

  1. Product name and classification by product type of Electrical Appliances and Materials and outline of the structure, material, and performance
  2. Date and place of inspection
  3. Name of the person who conducted inspection
  4. Quantity of Electrical Appliances and Materials inspected
  5. Inspection method
  6. Inspection results

The inspection records can be prepared in any form as long as the form includes the necessary items stipulated by the Act. However, the record should show a relationship with product specifications, inspection specifications (test methods), criteria for judgment results, etc. Such a record does not satisfy the legal requirements like just states “Conforms to the Act,” or states that inspection has been passed in appearance, dielectric strength test, and energization test.

In the case of importer that does not own inspection equipment, outsourcing of the self-inspections is accepted. However, because the legal responsibilities under the Electrical Appliances and Materials Safety Act pertain fully to the importer, steps must be taken to keep the inspection records at the importer, be prepared to immediately submit those records to the METI or other authorities upon request and have the capacity to explain the compliance confirmation.

5. Obligation to Undergo Conformity Assessment on the Specified Electrical Appliances and Materials

Notifying Suppliers must fulfill the following obligations by the time such Electrical Appliances and Materials are sold.
However, conformity assessment can be omitted for other Electrical Appliances and Materials of the same product type if the certificate of conformity is valid or if an official copy of the equivalent of the certificate of conformity from overseas manufacturers is retained.

The Registered CAB is conformity assessment body that has been registered by the government to conform to International Standard (ISO/IEC 17065) for its capability. As a neutral and fair third party, the Registered CAB verify conformity with the Technical Requirements through testing the samples of products submitted by Notifying Suppliers, and verify suitability of the inspection equipment at the factories.

List of Registered CABs (as of 2019, March)

In JAPAN
  • Japan Electrical Safety & Environment Technology Laboratories (JET)
  • Japan Quality Assurance Organization (JQA)
  • Japan Electric Cable Technology Center (JECTEC)
  • TÜV Rheinland Japan Ltd.
  • UL Japan
  • Intertek Japan
  • Cosmos Corporation
Overseas
  • TÜV Rheinland LGA Products GmbH
  • TÜV Rheinland Taiwan Ltd.
  • TÜV Rheinland Hong Kong Ltd.
  • China Quality Certification Center
  • Electronics Testing Center,Taiwan
  • UL LLC
  • TÜV SÜD PSB Pte Ltd.

Outline of Conformity Assessment

(1) Certificate of conformity and its preservation

When conformity assessment is passed, a certificate of conformity is issued by the Registered CAB. A certificate of conformity may be valid for three years, five years, or seven years, depending on the Electrical Appliance and Material, and conformity assessment can be omitted for other Electrical Appliances and Materials of the same product type as long as the certificate of conformity is within the valid period.

(2) Methods of conformity assessment

Type 1 assessment (assessment on actual products) and Type 2 assessment (assessment on samples and inspection facilities) are stipulated as methods of conformity assessment in Article 9, paragraph (1) of the Act. An outline of these assessment methods is shown in the table below.
 

Methods of Conformity Assessment
Assessment method Object of assessment Remarks
Type 1 assessment Relevant Specified Electrical Appliances and Materials Electrical Appliances and Materials manufactured or imported are subject to assessment.
Type 2 assessment The Specified Electrical Appliances and Materials used for testing and the assessment facilities for said Specified Electrical Appliances and Materials which are in the Notifying Supplier's plant or workplace, and other matters as specified by Ordinance of the Ministry of Economy, Trade and Industry Samples of Electrical Appliances and Materials manufactured or imported and assessment facilities in the plant where they are manufactured are subject to assessment.
(3) Equivalent of the certificate of conformity

In case of importer dealing with the Specified Electrical Appliances and Materials, the conformity assessment can be omitted if the importer preserve an official copy of the equivalent of the certificate of conformity within the validity period, which covers same product type of the imported products. The equivalent of the certificate of conformity is issued by the CAB conducts conformity assessment of overseas manufacturers, and the official copy of equivalent is issued upon request of the overseas manufacturer.

Flow of Procedures for the official copy of the Equivalent of the Certificate of conformity

  1. A foreign manufacturer of Specified Electrical Appliances and Materials applies to a registered conformity assessment body for assessment equivalent of conformity assessment.
  2. When assessment is passed, the equivalent of the certificate of conformity is issued by the registered conformity assessment body.
  3. An importer of the Specified Electrical Appliances and Materials covered by the equivalent of the certificate of conformity asks the foreign manufacture to issue an official copy of the equivalent of the certificate of conformity.
  4. The foreign manufacturer applies to the registered conformity assessment body for issuance of an official copy of the equivalent of the certificate of conformity.
  5. The registered conformity assessment body issues an official copy of the equivalent of the certificate of conformity.
  6. The foreign manufacturer provides a copy (official copy) of the equivalent of the certificate of conformity issued by the registered conformity assessment body to the importer.
  7. By preserving an unexpired official copy of the equivalent of the certificate of conformity, the importer can omit conformity assessment of the Specified Electrical Appliances and Materials.

6. PSE Labeling

Without the PSE labeling, which include PSE mark as well as the specified labeling items in accordance with the Regulation for Enforcement of the Electrical Appliances and Materials Safety Act, sale and/or exhibition for sales purposes of Electrical Appliances and Materials is prohibited in Japan.
Only those Notifying Suppliers who have fulfilled the following obligations can affix the PSE labelling on their products

The PSE labeling should be affixed on the surface of Electrical Appliances and Materials in a way so that it does not easily disappear. In the vicinity of PSE mark, it is also required to display the name of Notifying Supplier, the rated voltage and so on. When it comes to the Specified Electrical Appliances and Materials, the PSE labeling should also include the name of the registered conformity assessment body.

Detail of PSE Labeling

Items to be included in labeling for Specified Electrical Appliances and Materials and for Non-Specified Electrical Appliances and Materials differ (refer to the table below). For Specified Electrical Appliances and Materials, (i) PSE mark, (ii) the name of the registered conformity assessment body, and (iii) the name of the notifying supplier must be put on labeling. For Non-Specified Electrical Appliances and Materials, (i) PSE mark and (iii) the name of the notifying supplier must be put on labeling.
In addition, it is required to display (iv) items specified in the Ministerial Order to Provide Technical Standards for Electrical Appliances and Materials and/or the Circular Notice of Interpretation for the Ministerial Order to Provide Technical Standards for Electrical Appliances and Materials.

Items to be Included in Labeling for Electrical Appliances and Materials
  Items to be included in labeling Specified
Electrical Appliances and Materials
Non-Specified
Electrical Appliances and Materials
(i) PSE Mark    
(ii) Name of the registered conformity assessment body that conducted conformity assessment, its abbreviation or registered trademark
(iii) Name of the notifying supplier
(iv) Items specified in Technical Requirements and the Interpretation of Technical Standard in the Ordinance for Enforcement

Specific example of handling of the labeling on Specified Electrical Appliances and Materials and Non-Specified Electrical Appliances and Materials are shown below.

Example of Labeling for Specified Electrical Appliances and Materials (for a AC/DC Power Supply)

(i) PSE Mark
(ii) Name of the registered conformity assessment body that conducted conformity assessment or its abbreviation
(iii) Name of the notifying supplier, its registered trademark notified, or its abbreviation approved
(iv) Ratings, etc. (Items to be included in marking are stipulated in Technical Standards for different Electrical Appliances and Materials.)

Example of Labeling for Non-Specified Electrical Appliances and Materials (for an Air Cleaner)

(i) PSE Mark
(iii) Name of the notifying supplier, its registered trademark notified, or its abbreviation approved
(iv) Ratings, etc. (Items to be included in marking are stipulated in Technical Standards for different Electrical Appliances and Materials.)

Simplified labeling of PSE Mark

On electric wires, fuses, wiring devices, and other parts or materials that do not have enough space for affixing the required PSE mark, the simplified mark <PS>E for the Diamond PSE mark or (PS)E for Round PSE mark can be affixed as substitution of the original symbol.

Last updated:2019-08-21