| TOP |
| 6th Report of Market Access Ombudsman Council (March 16, 2000) |
1. Complainant: Tokyo Chamber of Commerce and Industry
2. Ministry concerned: Ministry of International Trade and Industry
3. Complaint:
Insulated resin materials and wire coverings with heat resistance approved under UL, CSA or other foreign specifications are not allowed under the Electrical Appliance and Material Control Law. Because of this, even parts (materials) which meet foreign specifications must undergo heat resistance approval anew before they are allowed to be imported and used in Japan.
Parts (materials) approved under the principal foreign specifications should be allowed to be used within Japan under similar conditions.
4. Corresponding Policy of the Ministries concerned:
In the United States, UL specifications generally apply to products and materials on the market. In the case of insulating materials where the maker tries to use materials for which there are no rules for materials under UL specifications, these must be certified by UL, in order to be evaluated under specifications for maximum usage temperature.
Japan's Electrical Appliance and Material Control Law, on the other hand, specifies maximum usage temperatures for insulating materials used in electric appliances through a simplified system, and if the materials are used at temperatures below the maximum, they can be used without being certified. This applies regardless of whether the product has been UL-certified.
But when individual insulating materials are used at temperatures exceeding the specified maximum, certification must be obtained for each in the same way as with UL. Thus if the usage temperatures for the UL-certified insulating materials mentioned in this complaint exceed the maximum temperatures for which the Electrical Appliance and Material Control Law states no certification is necessary, each must obtain certification for use in the same way as with UL.
This complaint concerns acceptance of the certification results of materials evaluated based on specifications, rather than acceptance of the specifications themselves. Where mandatory safety-related specifications are concerned, items from foreign makers in countries where there are no means of regulating businesses cannot be accepted without certification, and given that various countries have different systems, for the CE mark, the UL mark or labeling according to the Electrical Appliance and Material Control Law, materials must each be certified individually before they can be accepted.
5. Remarks
The complainant accepted this policy.