Provisional Translation

OTO No. 668 Classification MLIT-(7)
Date of Acceptance March 29, 2004 Ministry/Agency Receiving Complaint Cabinet Office
Responsible Ministries Ministry of Land, Infrastructure and Transport Related Laws Road Vehicles Law
Complainant Domestic firm Exporting Countries USA
Subject Improvement of handling in emission tests for imported automobiles
Description of Complaint It has become obligatory to submit an emission gas report for vehicles with a kerb weight of over 2.5 tons but below 3.5 tons since October 1, 2003 (Ministry of Land, Infrastructure and Transport Notification No. 1318 on September 25, 2003). However, there are some imported automobiles subject to the report for which emission tests cannot be conducted due to the structure of the facilities of public testing organizations (e.g. full-time four-wheel drive cars with heavy weight).
The complainant requests that the ministry install emission test facilities available for such vehicles, or take such measures as exemption of such vehicles from the obligation to submit an emission gas report, if installation of such facilities is difficult.

(Second Opinion, April 20, 2004)
The complainant knows that emission tests can be conducted by a "method in which a four-wheel drive car is made two-wheel driven by removing part of the propeller shaft of four-wheel drive," which was proposed by the Ministry of Land, Infrastructure and Transport. However, there are cases as follows.

(Case)
A vehicle for which the Japan Vehicle Inspection Association (Higashikurume-shi, Tokyo) could not conduct emission tests
<Actual car> Cadillac Escalade ESV 2004


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The length of the vehicle's wheelbase is 3.3 m, so the vehicle cannot be put on the test facility for general four-wheel drive cars. Therefore, the shaft was removed to make the vehicle be rear-wheel driven. (There is no drive wheel switching unit on the relevant vehicle.) Although the association tried to conduct tests by putting the rear-wheel driven vehicle on the emission test facility, the vehicle could speed up only to around 25-26 kilometers per hour. The vehicle became unable to speed up even when the accelerator was pushed down, and it did not run with the shaft removed.

Details of Measures 1. Replies from the ministry
(A reply from the ministry on April 5, 2004)
With respect to imported automobiles with a kerb weight of over 2.5 tons but below 3.5 tons, the complaint cited a full-time four-wheel drive car with heavy weight as an example of vehicles for which emission tests cannot be conducted due to the structure of the facilities of public testing organizations. However, for full-time four-wheel drive cars for which public testing organizations have difficulty in measuring emission gas with existing test equipment for four-wheel drive cars due to such reasons as long wheelbase, there is no harm in conducting emission tests with test equipment for two-wheel drive cars by a method in which a four-wheel drive car is made two-wheel driven by removing part of the propeller shaft. The ministry also recognizes that it is possible to conduct emission tests by this method.
In cases where there are vehicles for which emission test cannot be conducted by the above method (making subject vehicle two-wheel driven), the ministry asks the complainant to show specific cases.

(A reply on April 28, 2004)
In a case submitted by the complainant, the relevant testing organization made the subject vehicle rear-wheel driven and tried to conduct emission tests, but the vehicle did not speed up to the sufficient degree to onduct the test. The ministry requests that the complainant ask the manufacturer or dealer of the relevant vehicle about a method for adjusting the vehicle so that sufficient speed to conduct the test can be ensured even when the vehicle is rear-wheel driven.
Incidentally, if it is possible to conduct emission tests by making the relevant vehicle two-wheel driven by a method other than removing part of the propeller shaft, there is no harm in conducting the test by such method.

2. In response to the ministry's reply, the complainant has tried to collect information about the method for adjusting the vehicle, etc. However, specifications for the type of vehicle in question were changed, and it thus became possible to conduct emission tests by making a four-wheel car two-wheel driven without removing part of the propeller shaft. Due to this, there will be no case that answers the purpose of the complaint. Therefore, the case was closed.

Classification of Processing Cc Directions II-a
Remarks A written reply was made on April 5, 2004.
A written reply was made on April 28, 2004.

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