【Certification Q&A(6)】We will answer questions such as radio law and PSE whether authentication costs will be cheaper
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Hello. It is a hori of the manager.
One of the most frequently asked questions from customers is that they want you to check whether the products they handle and handle are eligible for certification.
As a business operator, certification will be more than 1 million yen if you are poor from hundreds of thousands of yen, so the presence or absence of certification is certainly a matter of life and death.
However, we generally refuse inquiries about whether or not we have certification. As for whether or not there is certification, if you ask the relevant ministries and agencies, you will tell us, and if you look into it, there is information.
Since it is a big decision about whether or not there is certification, products that we answered that certification is unnecessary are sold as it is, and in fact, authentication was required, and it may be difficult if it is claimed for damages.
Also, before, I was often involved in various confirmations because authentication was necessary, and when I finally verified that technical materials were provided, authentication was unnecessary.
We respond to customer requests that we want you to perform certification on your behalf because it requires authentication to the last.
However, on the other hand, if the presence or absence of certification is the needs of the customer, I will respond to it, and I will explain frequently asked questions and points to the extent that we know from our experience so far.
In addition, our opinion is for reference only, so please make a final judgment on whether or not to authenticate at your own risk.
- 1 Is the remote control subject to the Radio Act?
- 2 Is the refrigerator other than specific electrical appliances? If it is a specific electrical appliance and goods, it will be expensive.
- 3 Is it OK to only report on voluntary inspections for tests other than PSE specified electrical appliances?
- 4 I am thinking of importing a coffee making machine, but is it the No.105 electric coffee heater other than specified electrical appliances? No.173 Is it a coffee grinder?
- 5 Do ultrasonic welders require radio law certification?
- 6 I'm thinking of importing a barcode scanner that is irradiated with a laser, but is it a PSC target?
- 7 Announcements
Is the remote control subject to the Radio Act?
I mentioned in the article "4 Radio Law target products, asymmetric products" of the article on the radio law I wrote earlier, but I will explain it in a little more detail.
Even if you say "remote control" in a word, the type is roughly divided into two.
The first is to operate home appliances such as TVs, air conditioners, and electric fans through infrared communication. This is not covered by the Radio Law.
Although it is invisible, it uses infrared rays instead of radio.
As a trial, if you cover the tip of the remote control with your hand, it will not be sensed at all.
The other remote control that operates the smartphone with Bluetooth etc., this is subject to the Radio Act.
For example, VR goggles set up a smartphone and view videos. The VR goggles body has nothing to do with the radio law, but the remote control used in the operation of the smartphone at this time is subject to the radio wave method.
In addition, the remote control that comes with the selfie stick etc. also need the radio wave method. As a business operator, I would like to be firmly aware of this area.
By the way, as an aside, there are unidirectional and bidirectional radio laws, and the test cost is also different.
For example, just connecting it with Bluetooth to a smartphone etc. becomes unidirectional, and the cost is also standard.
On the other hand, let's take the wireless presenter introduced several times as an example.
This product can be used to slide (scroll) the screen by setting the USB attached to the main unit to the PC, launching applications such as PowerPoint and PDF, and operating the main unit.
In this way, those that have the function of sending and receiving within a single product are bidirectional, and the test cost is a little higher.
However, it may vary depending on the type and function of the radio, so please consult with the supplier who performs authentication.
Is the refrigerator other than specific electrical appliances? If it is a specific electrical appliance and goods, it will be expensive.
In fact, refrigerators are roughly classified into two categories: specific electrical appliances (rhombus PSE) and non-specified electrical appliances (round PSE), and in addition, there are electric refrigerators, electronic refrigerators, and electric refrigerators (absorption type) other than specific electrical appliances and supplies.
As a quick decision material when distinguishing between rhombus PSE and round PSE, let's recognize that the diamond PSP is for business use and the round PSE is for home use.
Even if you say refrigerator as described above, it is a wide variety, so if there is a need to perform PSE certification of the refrigerator, even if you say "I want to authenticate the refrigerator", you will always be asked "What kind of refrigerator?" and the purpose, so let's organize the information so that you can respond firmly.
By the way, this is also an aside, but refrigerators may be subject to the Energy Conservation Act depending on specifications, so let's be aware of this place.
Is it OK to only report on voluntary inspections for tests other than PSE specified electrical appliances?
It is difficult to interpret the law, but please check the PSE flow of the Ministry of Economy, Trade and Industry quoted earlier.
Citation: Ministry of Economy, Trade and Industry_Electrical Appliance and Material Safety Act_Flow of Notifications and Procedures
"Standard compliance confirmation" here means "self-confirmation that it conforms to technical standards".
The self-confirmation here is miso, and it is supposed that you can conduct your own inspections in-house other than external inspection institutions.
However, the need for rigorous inspections in accordance with PSE technical standards is the same whether it is an external inspection organization or an in-house inspection, and accumulating inspection equipment and know-how in-house is not a matter of overnight.
It takes time and money. In addition, if you do it in-house, the inspection contents may become sweet. In that sense, inspections by external inspection organizations are necessary to obtain an objective perspective.
In the unlikely event that there is a product accident after distribution and is interrogated by the Ministry of Economy, Trade and Industry, all inspections will be conducted only in-house, and you will be able to eat appropriate improvement guidance.
I do not know why it is such a law, but if you read only here, some people may misunderstand that you can do something by yourself without paying inspection costs. However, it is only a waste of time to investigate such things, and basically I think that there is only an external inspection organization choice.
In particular, it is absolutely impossible for the Chinese factory to confirm the standard conformity, so let's remember that.
Pse specified electrical appliances and supplies are required to conduct "conformity inspections" by the registered inspection organization.
I am thinking of importing a coffee making machine, but is it the No.105 electric coffee heater other than specified electrical appliances? No.173 Is it a coffee grinder?
This is not understood only by looking at the thing.
No.105 Electric coffee heater is classified as "electric heat appliance", And No.173 coffee grinder (coffee mill) is classified as "electric power application machinery and equipment".
The former uses electricity to generate heat, and the latter uses electricity to operate, and in this example, it is necessary to check which part of the coffee making machine.
However, coffee making machines can be distinguished immediately, but there are things that use electricity differently even if the objects are the same, and some are difficult to distinguish.
In any case, there is no doubt that it is a PSE product using electricity, so it may be a good idea to proceed with certification first and finally check the application classification with people of the Ministry of Economy, Trade and Industry at the stage of applying to the Ministry of Economy, Trade and Industry.
As an aside, since food touches the machine in the coffee making machine, it is necessary to inspect the machine by the Food Sanitation Law.
Do ultrasonic welders require radio law certification?
It will be a little maniac, but in the Radio Law, we have an agreement on high frequency utilization equipment (NFC).
High-frequency utilization equipment is a facility that uses energy of high-frequency current of 10 kilohertz or more for the purpose of communication, medical care, industry, etc.
Since radio waves leaked from high-frequency usage equipment may interfere with other wireless communications, it is necessary to obtain permission for high-frequency usage equipment that uses a certain frequency and power before installing or changing, and it is necessary to apply or notify the following procedures.
Citation: Kinki General Communications Bureau_High-frequency utilization equipment_Overview of high-frequency utilization equipment
Under these circumstances, for equipment that emits strong radio waves such as ultrasonic welders but is judged to have little impact on wireless communication, etc., individual permission is not required, and (after inspection and measurement), we apply for model designation of high-frequency utilization equipment.
The bottom line is that after all, we will conduct inspections and applications. The text of the law is confusing, but basically, it is better to think that there is no way through.
However, when I checked with the Ministry of Internal Affairs and Communications, there is a possibility that the views may differ depending on the area (region), so I asked the General Communications Bureau in each area to check for unclear points.
In addition, it is necessary to confirm that the type of equipment conforms to technical conditions by manufacturers and importers of microwave ovens and electromagnetic induction heating cookers (IH cookers) that emit strong electromagnetic waves, and report them to the Minister of Internal Affairs and Communications.
It is a law that should be suppressed if there is an opportunity to handle the product of this vicinity.
In addition, as an answer to the question "Does ultrasonic welder require radio law certification?", ultrasonic welders require testing of high frequency utilization equipment (NFC), and radio law certification is not required. In the first place, there is no problem with high frequency utilization equipment (NFC) and radio wave method if either test is cleared. The test target varies depending on the wireless strength, etc., but please think that some kind of test is necessary as long as you emit a radio.
I'm thinking of importing a barcode scanner that is irradiated with a laser, but is it a PSC target?
When I checked directly with the Ministry of Economy, Trade and Industry before, it was not eligible for PSC. As a reason, as the name "Consumer Product Safety Act" says, PSC is intended for what general consumers use in their daily lives, so to speak, barcode scanners are not eligible for PSC because they are for business use.
Even though barcode scanners are for business use, there is an image that people who do light work at home or office are using it, and what is the definition of "business use"? At that time, the Ministry of Economy, Trade and Industry's view was that it was not a PSC object.
In addition, laser distance metering is generally subject to PSC,
If it is a product that is mainly used for the lives of general consumers,
Specified products that fall under the category of "consumer products" and are based on the Act
(portable laser application equipment) and is subject to regulations.
Laser distance gauges that were originally used at construction sites (for business use), but recently they have been used as measuring lengths in daily life, and as a typical example, the act of measuring children's height with a laser rangefinder is increasing.
Then, the number of situations that children themselves use increases, so it is still subject to regulation.
In other words, it may be better to think that it is temporarily unregulated, but it may be applicable depending on the change of the times.
So, even if you say that you were not eligible for PSC before and do not leave it as it is, but you actually handle it, or if you are already handling it, it may be necessary to listen to your views with the Ministry of Economy, Trade and Industry on a regular basis.
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