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[Certification Q&A (14)] We will answer the way of the Ministry of Economy, Trade and Industry procedure of the PSE mark (Electrical Appliance and Material Safety Act) based on the wrong case.

 2020/08/20 Business in Japan China Business Column example Principles of authentication PSE Q&A
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Hello. It is a hori of the manager.

There are a lot of sober questions that I'm doing authentication work,

How should PSE notify and apply to the Ministry of Economy, Trade and Industry?

It is a content that.

Source: Ministry of Economy, Trade and Industry website "Electrical Appliance and Material Safety Act_Flow of Notification and Procedure"


PSE flow has appeared many times, but this time I would like to summarize the questions of "business notification" in this one.

Please note that this time it is only in the form of an answer to the question and does not cover the entire flow of PSE application. Having said that, if you read the contents of this article, I think you will be able to grasp the general flow.

Before getting into the main subject, if I were to tell you the background of the many questions about the PSE application procedure to our company, it seems that there is a fear that business operators are new to the PSE application procedure and that if there is a document defect, METI will catch the eye of METI in a snake manner.

In addition, if a factory in China appeals to the Ministry of Economy, Trade and Industry (METI) with the appeal of "I have acquired PSE!" and submits the certificate it has presented as it is, there seems to be a concern that it will be suspected of something because it is a summer insect flying and on fire. By the way, it is better to think that the PSE certification that the Chinese factory acquired by itself basically has some kind of flaw.

Another thing is that the Ministry of Economy, Trade and Industry's page itself has a formulaic rather than a practical way, so I feel that it is a little difficult to understand, and I think that is also a reason to stop users from acting.

In addition, since business operators do not need to apply to the Ministry of Internal Affairs and Communications' Radio Law with the ministry themselves, from that aspect as well, applying to the Ministry of Economy, Trade and Industry may be a little high from the standpoint of a beginner in certification.

In any case, as a matter of feelings, if you feel that it is difficult to contact the Ministry of Economy, Trade and Industry from the beginning, I would like you to study on this page, gain some preliminary knowledge, and then contact and communicate.

Is it ok for the Ministry of Economy, Trade and Industry to submit PSE documents? Also, when do you submit a business notification?

Strictly speaking, it is not the Ministry of Economy, Trade and Industry (Ministry of Economy, Trade and Industry: Kasumigaseki) that submits business notifications such as PSE and PSC, but the Bureau of Economy, Trade and Industry in each area jurisdiction. Will be. Of course, I think that the station has various functions, but from our point of view, it is an image like a document application and reception agency for work related to the Ministry of Economy, Trade and Industry.

This is divided into areas, for example, the Kanto Bureau of Economy, Trade and Industry if the business operator is Tokyo, the Bureau of Economy, Trade and Industry if it is Osaka, and the Kyushu Bureau of Economy, Trade and Industry if it is Fukuoka.

So, please contact your local Bureau of Economy, Trade and Industry when submitting PSE documents. I think that it comes out soon if you search on the net.


Citation: Ministry of Economy, Trade and Industry_Notification and Inquiry Desk

Since we are a business operator in Kanagawa Prefecture, we will tell you about the following stories on the assumption that you are using the Kanto Bureau of Economy, Trade and Industry.

In addition, although it is time to submit a business notification, it is supposed to be put out before "confirmation of standard compliance" in the table above, but I think that it is rather severe physically as a reality. The reason will be described later.

The Economic and Industrial Pages

In the manufacture and import business of electrical appliances, the necessary matters must be notified to the competent Bureau of Economy, Trade and Industry within 30 days from the date of commencement of the business.
Citation: Ministry of Economy, Trade and Industry_Electrical Appliance and Material Safety Act_Flow of Notifications and Procedures

It is written.

On the other hand,

The date of commencement of business refers to the date on which electrical appliances and materials were specifically manufactured (completed) or imported (transferred to Japan), but includes preparation for business and some decision-making days in-house, etc. related to business start.)
Quoted

Because there is a atmosphere that must be submitted as soon as possible, as mentioned earlier, it is quite severe physically, so it may be just right to match the date on which the PSE certificate was issued. In addition, since this is our personal opinion to the last, I think that you can judge it by each company in the end.

Still, the thing that you should not do most is to sell (forget) without applying. For example, even if you apply in a hurry after about 60 days of sales, the date can only be traced back to 30 days.

If you are not good at it, you may be thrust in by the person in charge of the Bureau of Economy, Trade and Industry on the spot you submitted, and if there is a discrepancy between the social record that you are starting to sell and the document record (date), there may be an inquiry from the Ministry of Economy, Trade and Industry in the course of time.

Be careful about that area.

I plan to have PSE products produced at my factory in China, do I need to report my importer?

As a point in the first place, the notification of PSE is divided into importer notification and manufacturer notification.

As long as you produce overseas, you will need to report all importers. In addition, when manufacturing in Japan, a manufacturer's notification is required.

The following formats are covered.

Example manufacturing business (PDF format: 176KB) Import business (PDF format: 232KB) of business notification form (Word format: 24KB)

Citation: Ministry of Economy, Trade and Industry_Electrical Appliance and Material Safety Act_Flow of Notifications and Procedures_Business Notifications_Forms, etc.

 

What you need to be aware of here is that if you have PSE certified what is already produced by an overseas factory, if a Japanese business operator makes it at an overseas factory for PSE, you will need an importer report in both cases.

Since certification is granted to the production plant, it means importing products subject to PSE certified production plants, and if pse funds are provided in-house as an importer, management to prevent the factory from selling to others without permission will also be required.

This story will be a different theme, so if you are interested, please contact us directly.

On the other hand, the manufacturer's notification is also submitted by the production plant in Japan, not the seller. In this case, there are many patterns in which the seller provides PSE funds, and the name of the PSE producer describes the factory, but there are many cases where the name is displayed separately as "seller".

I don't think there are many things that Japanese businesses in Japan do, but it is still necessary to have prior discussions with the sales company that provided funds so that the production plant does not sell to other companies without permission.

When I submit a notification, is it okay to copy the prescribed form and PSE certificate?

The above mentioned,

It is the timing to submit a business notification, but in the table above, it is supposed to be put out before "confirmation of compliance with standards", but it is better to do so in the system, but as a reality it is probably quite severe physically.

It also explains the reason, but when filing a PSE business operator notification, you must submit a type classification together with the application form (documents to be submitted).

Electrical appliance and material classification

 

Type classification table (partial excerpt)

Citation: Ordinance for Enforcement of the Electrical Appliance and Material Safety Act_Appended Table 1 Classification of Electrical Appliances and Materials (Article 2)/Appended Table 2 Type Classification (Article 4)

The electrical appliance and material classification that is the basis of the type classification is the classification of the corresponding electrical appliances and materials, but it can be understood somehow by doing a little research, but the type classification is quite difficult for a layman of electrical appliances to understand.

In the first place, the product structure is different for each product, so even if you are a person who is familiar with technology, you can not make a model classification unless you confirm it firmly after certification.

In other words, since the type classification can not exist until after the certification is completed, business notification can not be made.

From an old-fashioned point of view, it may be like the PSE flow at the beginning because the Japan manufacturers and factories started manufacturing after firmly deciding on the model classification.

However, nowadays, when producing at overseas factories or at factories that are not familiar with PSE even in recent Japan, there are many cases where PSE is finally reconciled, and it is becoming difficult to grasp the type classification from the beginning.

Even so, I think that there is no problem because you can understand the type classification in the end, but the terrible thing is that when using an overseas inspection institution such as China, there are many cases where only the certificate is issued without making a type classification.

When a customer consults with you, how do you apply for this? Not once did I tilt my head, but each time there were many times when we acted as a substitute for the creation of type classifications.

Again, the notification is in the prescribed form, a copy of the PSE certificate (in some cases not required to be submitted) and the type classification. Since it is difficult to obtain this type classification unless the PSE inspection is completed, I think that the PSE application to the Bureau of Economy, Trade and Industry will be sufficient in time after the completion of the inspection.

I'm not very used to applying for this kind of application, can I submit the downloaded form for the time being?

Basically, there is no problem, but be careful about two points.

The first time to submit is "Business Operator Notification" of "Form No. 1 (Article 3 Related)"

Whether you are an importer or a manufacturer, if it is the first electrical appliance and material category, you will submit a "Business Operator Notification" of "Form No. 1 (Article 3 Related)".

It is necessary to be careful to make mistakes easily, and do not submit "Business Notification Matters Change Notification Form" etc. of "Form No. 6 (Article 6 related)".

Form 6 will be submitted as "additional", for example, when dealing with a new product in an electrical appliance and material category that has already been submitted.

The form number can be found in the upper left corner of the document.

It is difficult to understand what is written in unfamiliar A4 documents, but the recipient (Bureau of Economy, Trade and Industry) looks at the form number to determine what the applicant wants to do.

Previously, the customer who applied for the first time made a mistake, submitted it in Form 6 instead of Form 1, and the Bureau of Economy, Trade and Industry could not judge whether they had already applied even though they said it was the first application, and the customer panicked and the story fell into a parallel line.

When we finally confirmed that it was a different style, we found that the story was safe.

When downloading, be sure to check the form number carefully.

 

Don't ask anyone other than an administrative scrivener to prepare documents.

As mentioned above, the document itself is basically plain, and the Ministry of Economy, Trade and Industry has prepared examples of how to write carefully, so there is no problem if you calm down a little and fill it out.

However, I think that there are still some people who think that it is difficult to do it by themselves, so I would like to advise you, other than to prepare such official documents by yourself (your company), when you ask others to do it, do not ask anyone other than an administrative scrivener.

This is because there is a possibility that it will become a so-called substitute writing act (violation of the Administrative Scrivener Law).

We have never done a single book on behalf of our company. I will tell you where there is a style format, but after that, please look at the sample and create it yourself, it is a neglected play lol.

However, as I have said many times, it is a very simple document, so let's do it by yourself (company) unless there is something extraordinary.

When you submit a notification at a sole proprietor, you were told that the name of the business that displays the product must be your real name, but do you want to avoid this at all, but is there a remedy?

The Ministry of Economy, Trade and Industry page states the following:

In conclusion, there is no remedy.

If you apply for a PSE as an individual (business owner), you must always display your name (real name) on the product, not the shop name. This is also the case with the PSC, which is under the jurisdiction of the Ministry of Economy, Trade and Industry.

In my case, it will be displayed as "Yuta Hori" on the product, so I personally thought that this would be a disgrace until the last generation, so the sole proprietor graduated from this, established a corporation, and displayed "INSIGHT WORKS Co., Ltd." on the product.

Leaving aside our company's story, basically notification by sole proprietorship is a real name system, but there is also a method for corporations that "If it is an abbreviation that has been approved or a registered trademark that has been notified, it can be displayed even if it is not an official name."

For example, if it is an abbreviation, "INSIGHT WORKS Corporation" can be changed to "INSIGHT WORKS".

By the way, the abbreviation itself needs to be delivered to the Ministry of Economy, Trade and Industry in Kasumigaseki, not the Bureau of Economy, Trade and Industry. After that, you will have to report it to the Bureau of Economy, Trade and Industry.

With regard to registered trademarks, it takes at least half a year or more to file a trademark application in the first place. And trademark applications are also quite high hurdles, as there is a high possibility that they will fail in the examination.

If you wait for that, the PSE application will only be delayed more and more, so it may be safer to stop unless you have a trademark from the beginning.

In addition, the notification of the trademark for which the application has also been filed will be made by the Ministry of Economy, Trade and Industry in Kasumigaseki.

Is there any good way to apply suddenly and make a mistake because it is troublesome in various ways?

First of all, there are three ways to apply: electronic application, bring it directly to the bureau of economy, trade and industry of the jurisdiction, and also mail to the Bureau of Economy, Trade and Industry.

If you are a business operator who does not usually submit documents to government agencies, I think that there is no electronic application, so I will not discount that.

I will bring it with me and think by mail.

In any case, you will need two forms (the same one), a certificate and a copy of the model classification (one by one).

Certificates can be omitted if they are patterns that are listed together with the name and address of the production plant in the model classification. However, since it is not something to hide separately, let's think that the certificate and the model classification are basically a set.

One form is affixed by the Bureau of Economy, Trade and Industry and stored by the business operator, and the other is affixed.

To answer your question, contact your competent Bureau of Economy, Trade and Industry, ask your e-mail address, etc., and have it corrected in advance.

Whether you bring it directly or by mail, if you submit it suddenly, the small part is usually wrong, and whether you take what you brought home once, or wait for the mail to return, it will be a significant time loss.

Be sure to have them correct in advance.

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