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(Provisional Translation)

6th Report of Market Access Ombudsman Council (March 16, 2000)

3-(4) Acceptance of foreign standards regarding gas appliances

1. Complainant: Tokyo Chamber of Commerce and Industry


2. Ministry concerned: Ministry of International Trade and Industry


3. Complaint:

Commercial gas appliances imported after meeting foreign standards (CE, AGA) must be certified once again by the Japan Gas Appliance Inspection Association. This is duplicated effort and is inefficient.
The standards of the Japan Gas Appliance Inspection Association should be harmonized with those of foreign countries so that inspection of appliances meeting foreign standards may be omitted.


4. Corresponding Policy of the Ministries concerned:

(1) Gas appliance mainly for commercial use that uses large amounts of gas does not come under any public regulations in Japan. The Japan Gas Appliance Inspection Association's certification system for a commercial gas cooking appliance is a voluntary, private sector certification system.

(2) The ministry is aware that the Japan Gas Appliance Inspection Association is attempting to harmonize its voluntary standards with standards of foreign countries, and that test of appliance meeting foreign standards cannot be omitted, for the following reasons:

1) Regarding the certification system for gas appliances by testing organizations, the testing personnel carry out type test, to check that the appliance conforms in terms of materials, construction and performance, and on factory audits, where they ascertain that the manufacturing facilities can continue producing appliance conforming to standards. This certification system is the same in Japan as for CE and AGA.

2) However, since the types, composition and supply pressure for gas used are different in every country, no international standards exist, and each country sets its own standards, and based on those standards, carries out its own test and certification. For example, in combustion tests to verify for complete combustion, the calorific value of gas used in Japan and in various EU countries differs markedly, and gas appliances which burn EU-country gases well may not necessarily do so with Japanese gas. In the United States, combustion tests are conducted by taking the appliance input rate to its maximum capacity (25% over consumption), and may not necessarily burn Japanese gas well. Additionally, temperature increase tests to check the rise in temperature in areas adjacent to where the gas appliance is installed are not conducted using Japanese gas, because of differences in calorific value and so on.


5. Remarks
The complainant accepted this policy.