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【Certification Q&a(13)】 Does the authentication change depending on the way pse, PSC, and radio law method?

example Principles of authentication PSC PSE Q&A Radio Law
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Hello. It is a hori of the manager.

When I'm in the authentication job, the most common thing I'm asked about is that it's not eligible for authentication? Not applicable, right? It is a question. Of course, it may be natural, but basically I feel that everyone does not want to authenticate.

If you are doing the certification business for a long time, you can do business for a long time and stably by certifying, and I know that funds can be pulled as much as you can depending on how you build the business, so I feel that such people are not very familiar with business.

Is this PSE? Is this the Radio Law? If you are worried, on the contrary, there are people who take certification and appeal to the surroundings that it is a certified product, so I think that it depends on the way.

Rather, I feel that it is more profitable to handle apparel and household goods that are completely unrelated as long as you are concerned about the presence or absence of certification. The point is up to the design of your business.

In the first place, authentication is a major premise, since it is a viewpoint of user protection from product accidents, authentication must be performed At the time of thinking, there is also a place where you doubt your qualities as a business operator.

Well, the position talk of the certification agency is just like this lol, but the authentication cost is not cheap even so, so if you can, you will want to avoid authentication.

In addition, in today's highly developed production technology, it may be the real intention of the business operator that there is no way that accidents can occur without certification.

We cannot decide whether or not to apply the law, but since there are some responses that change the presence or absence within the scope of the law, I would like to focus on such contents (Q&A) this time.

Is it not applicable to PSE that is powered by USB instead of an AC adapter or power cord?

This is a really common question, and I have answered it several times on this site, but I would like to tell you a little more.

In the first place, the standard for electrical appliances and electrical appliances under the Electrical Appliance and Material Safety Act (PSE) is that they are electrical machinery and equipment rated from 100V to 300V AC.

Products that use electricity below 100V are basically treated as toys (toys), most of which operate with batteries and USB power supply.

On the other hand, powering power cords and AC adapters is usually more than 100V.

By the way, those of 300 V or more are basically for business use, and pse is not electrical equipment, but instead, strict installation work by electrical workers etc. is required.

If you return the story to USB, the voltage required by the USB cable is basically only 5V. Therefore, electrical appliances powered by USB cables do not require PSE.

However, since PSE authentication is difficult, it is premature to think about usb powering anything.

Basically, USB has only 5V, so it cannot sufficiently supply most electrical appliances and does not work. Be careful about the way you think about it.

On the other hand, even if usb power is powered, there are many cases where the connector cable is USB and comes with a power plug, but the power plug corresponds to PSE specific electrical appliances (insertion plugs, etc.) that transformer voltages of 100V or more.

In addition, it is an act that is not recommended so much as a business operator, for example, it is naturally more user-friendly to sell with an AC adapter or power plug, but there is also a sales method that comes with only a USB cable without it, and the plug should be aligned by the purchaser himself.

Doing so will not result in a PSE violation.

Is there a way to not authenticate the AC adapter yourself?

This is also the content introduced in the previous article "I use an AC adapter for power supply in radio law products, but do I need PSE?", but I will write in a little more detail.

Under the pse system, there is no problem that the seller sells electrical appliances and appliances that have been properly submitted for the manufacturer's notification or importer's notification. It does not matter whether it is a PSE that you are applying for yourself or a PSE that another company is applying for.

In other words, businesses that sell things that have not been applied correctly are subject to penalties. And, there are companies that sell PSE adapters used by others, etc. though it applies for PSE because it sells it by oneself roughly.

In Japan, you can find it on manufacturer sites such as Misumi and monotaro on business sites. These will definitely be PSE certified.

There is no legal problem to bundle the AC adapter procured at such a place with your own products and sell it because it is PSE certified.

However, pse certified adapters sold on these sites are basically expensive, and it would be fine if you purchase about 1 and 2 for personal use, but if you purchase 100 pieces and 200 units units as a commercial, you may need to do the PSE procedure yourself cheaper.

In addition, the voltage check of the product body and the power adapter is important, and if charging and powering is used using an adapter that does not match the voltage, the main body may not work immediately, so if you are not familiar with electrical relationships, you may want to ask a specialist to test the measurement.

It seems to correspond to psc portable laser application device, but it has been judged as a laser of class 3 or higher

Let's review the standards for portable laser application equipment under the jurisdiction of the Ministry of Economy, Trade and Industry (PSC) (Consumer Product Safety Act).

Portable laser application equipment

It is designed for displaying text or shapes by irradiating laser light (limited to visible light) to the outside, and portable products are subject to special specific products. These include laser pointers and radiation thermometers with lasers.

Citation: JQA (Japan Quality Assurance Organization) Consumer Product Safety Act (PSC Mark) (business based on the law)

To be honest, I don't think it's easy to get a pin even if it is said jis C 6802 (2014) safety standard 3.18.

In short, laser pointers, laser sight, radiation thermometers with lasers, laser scanning portable projectors, etc. can be subject to PSC. In addition, it is better to check whether or not the target of the PSC is intended for those that emit a laser.

In addition, regarding the "laser class" in the citation, and again, please refer to wikipedia's explanation.

Class 1

Outputs around approximately 0.2mW (units: milliwatts). It is said that there is no problem even if it does not blink for 100 seconds and it is looked straight. The output limit differs depending on the wavelength of the ray. PSC mark certified laser pointers described below, mainly for toys.

Class 2

Outputs of less than 1mW. It is assumed that there is no problem in direct vision for less than 0.25 seconds. PSC mark certified laser pointer, mainly for presentations.

Since 2001, the manufacture and sale of laser pointers (to be precise, battery-powered portable laser applications) with higher outputs are prohibited by law.

Class 3A

Laser pointers and laser markers sold before regulatory regulations. Even if you look directly, you may be able to avoid it with blinks. If you look directly with a telescope, it will cause fatal damage to your eyes.

Class 3B

Outputs of 500mW or less. The laser of the optical drive corresponds to this. Direct vision of light rays should be avoided under any circumstances.

Class 4

Output beyond class 3B. Not only direct vision, but diffuse reflection adversely affects the eyes and causes skin disorders such as burns. The irradiation portion may ignite due to temperature rise. For laser shows.

Learn more about each class and output

In classes 1 to 2, the trajectory from the laser pointer to the target is not visible at all in normal atmosphere. Products whose trajectories are visible in the atmosphere are likely to be class 3A or higher, and such products are prohibited from manufacturing and selling in Japan and importing and selling them.

Citation: Wikipedia_ Laser Pointer_Light Intensity and Class Display

As the class rises, the power of the laser increases, but it is only class 2 that can be imported and sold in the General Market in Japan. In addition, PSC testing is also required.

Although the preface has become longer, the content of the question was judged by the Ministry of Economy, Trade and Industry that it was a laser device for PSC as a product, but when confirmed by the production (overseas) factory product, it was measured that the laser class was (in Japan) 3 or more, so what should I do? It is.

Laser Class 3 or higher is prohibited from importing and selling, but it is not subject to PSC. Therefore, it is not possible to even undergo a PSC test. However, what should I do because it is a PSC target in terms of product type?

The content that can be proposed is to change the specifications to reduce the laser class to 2 or less on the premise that the production plant actively cooperates, such as providing sample creation and technical materials.

Technically, that's possible. Then, laser power is lower than conventional products, but it will be possible to import and sell by receiving PSC inspection.

However, I feel frankly that it is better to look for a factory that makes products with good conditions in the first place, whether there is a reason to use the factory.

However, it may be safe to remember that there is a way to reduce the output power.

Is R45J (LAN cable) certification required separately from the Radio Law for devices subject to the Radio Act?

In addition to wireless, there are devices that operate the function by connecting to a router using a wired (LAN cable), but in that case, authentication of the LAN cable terminal (R45J) is required.

However, if you set the product configuration that does not use the function of R45J, authentication is unnecessary.

In that case, it is necessary to make it impossible to use it by covering the terminal part, and to erase all the description about the LAN cable from the instructions.

The approach is a bit complicated, so be sure to check with an expert.

 

Can I choose not to authenticate some of the features in the product because it is expensive?

It is theoretically possible to conclude first. However, it is up to the factory whether it can actually be made. In addition, I think that it is difficult to realize it unless you know the certification by yourself or a consultant who is familiar with certification gives instructions to the factory to change specifications.

For example, suppose you have a radio law product and you have two authentication targets: Wifi-2.4G and Bluetooth.

However, since Bluetooth is mainly connected to a smartphone, you may think that Bluetooth is unnecessary as the range of use assumed by the operator.

When you think that Bluetooth does not require authentication, it is also possible to request the production plant to remove the Bluetooth chip and not authenticate.

In addition, it is necessary to be careful that even if you think that authentication is unnecessary, you do not change the setting and specifications so that the function does not work, you can not sell in the default state, and in the first place, you can not pass the test by the inspection institution.

It is necessary to ask the production plant to suspend functions and change specifications, and test it with the sample.

However, even in factories, it is normal to produce with the function originally designed, and it is unclear whether they will respond to the request to stop the function, and it will not move without clear instructions to perform the work itself.

It is possible to have the factory himself think about it if you are ordering a considerable amount, but if there are not many orders, it will be practically difficult to hope for such a response.

In such a case, you will need a consultant who can give instructions to the factory.

On the other hand, there are factories that do not change specifications under any circumstances, so negotiation skills around there are necessary.

Above, does the authentication or absence change depending on the way of PSE, PSC, radio law? I wrote based on our case study.

The important thing is that the business operator himself will study authentication as much as possible, and I hope that you will be able to convey your intentions from the pattern of certification that has been talked about by the agency and inspection organization.

To be clear, it is the agency's responsibility to present everything that needs to be certified, and if it reduces functions, it will require appropriate adjustments with the production plant, and it will be time and costly, so it is often disadvantageous to customers, and honestly, I think it is better to do everything necessary.

Basically, inspection institutions and agency companies do not know the customer's budget, so first of all, there is no choice but to present the whole amount, and the certification cost is high in the first place, so I think that it is a little childish to make noise if it is high looking at the amount.

It is good to get a phase estimate, but unless you fundamentally study authentication yourself, the cheap place is roughly incomplete, and it is often time consuming after all. Authentication is so complicated.

Including such various things, please be sure to study thoroughly, such as talking with inspection institutions and agency companies that seem to be saying the right thing.

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