Provisional Translation

OTO No. 589 Classification MITI-136
Date of Acceptance March 4, 1999 Ministry/Agency Receiving Complaint Economic Planning Agency
Responsible Ministries Ministry of International Trade and Industry Related Laws High Presure Gas Safety Law
Complainant Domestic association Exporting Countries The Netherlands
Subject Acceptance of pressurized LP gas fuel supply apparatus for automobiles
Description of Complaint (1) When the complainant attempted to introduce a pressurized fuel supply apparatus, which supplies fuel to engines by pressurizing the LP gas in a fuel tank (made in the Netherlands and meeting the ECE R67 regulation of the UN/ECE), the complainant was advised by the ministry that under the High-pressure Gas Safety Law (referred to hereafter as "the law"), pressurizing the gas constituted "production of high pressure gas" and that operating LP gas vehicles carrying the said apparatus would contravene the law unless prefectural governors were notified of the location, etc. of the apparatus. However, the complainant believes that interpreting mere pressurization of the LP gas for the purpose of injecting the fuel into the engine as " production of high pressure gas" is an excessively narrow interpretation of the law and is therefore erroneous application. Accordingly, measures should be taken to exempt this apparatus from the law and allow it to be used in Japan at an early date.
(2) Moreover, the complainant attempted to have the doughnut-shaped fuel tank attached to the apparatus inspected as called for under the law, but the High-pressure Gas Safety Association refused to even accept the application, for the extremely unclear reason that "there has never been a canister shaped like this before." The reasons for refusing application for inspection of the fuel tank should be given clearly in writing, and the application should be accepted if there is no clear reason for refusal. Furthermore, the apparatus should be exempt from domestic testing, since it meets the ECE R67 regulation.
Details of Measures The ministry replied as follows:
(1) It was clarified from October 1, 1999 that the pressurized fuel supply apparatus for LP gas-powered automobiles which is the subject of this complaint is not considered "production of high pressure gas" under the High-pressure Gas Safety Law, and from that date it has been possible to operate automobiles fitted with this pressurized fuel apparatus anywhere in Japan, without obtaining a permit from prefectural governors.

(2) Even though no imported fuel tank may have been doughnut-shaped before, this tank can undergo inspection according to the prescribed procedures. Therefore, individual doughnut-shaped fuel tanks which have passed container inspection conducted domestically may be attached and the LP gas-powered automobiles mentioned above operated. If the applicant for inspection of the said fuel tank agrees, technical data on doughnut-shaped fuel tanks which have passed inspection obtained by the High-pressure Gas Safety Association can be used for other applicants for inspection, to facilitate procedures related to their applications for inspection.
The ministry is currently collecting technical information on the UN/ECE R67 regulation of this doughnut-shaped fuel tank, and it is not possible to indicate exactly what the differences are between these regulation and domestic standards.
Inspection as to whether LP gas containers conform to domestic standards is carried out for containers manufactured domestically and imported containers alike, and as in this case, even though the containers already meets ECE R67 regulation, it is necessary to confirm that it meets domestic regulation. Further, spot inspections alone merely happened to confirm the safety of the container selected, and all containers, included those which are imported, must undergo container inspection in accordance with domestic standards.
Classification of Processing A Directions II-b
III
IV
Remarks
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