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When will the PSE self-inspection required for PSE certification be done? Does PSE costs matter?

 2021/07/11 China Business China Imports example Principles of authentication PSE
この記事は約 19 分で読めます。 23 Views

Hello. It is the moat of the caretaker.

When you receive an inquiry about PSE, together with the PSE exam itself, you will almost always be asked,

This is about the PSE voluntary examination.

Who conducts voluntary inspections?
Will you do that for you?
Is it included in the PSE test cost?

We are asked in rapid succession, but our company's answer is as follows:

Voluntary inspection is basically done by the production plant after productionWe do not substitute for voluntary inspection (can not do) Voluntary inspection is not included in PSE inspection cost

It means.

However, what is "voluntary inspection" in the first place?
That seems to be the kind of question you have.

If I don't do this, can I not apply for PSE?
Will they be subject to punishment by the Ministry of Economy, Trade and Industry?

To put it bluntly, the people in charge of the Ministry of Economy, Trade and Industry and the Bureau of Economy, Trade and Industry can only give fixed answers based on the system.
It is also true that to some extent, the person asking the question does not have knowledge before the conversation will mesh.

So, first of all, I would like to briefly explain the outline of the "voluntary inspection",
I hope you will learn.

There is no need to be impatient, but I hope that you will know the actual situation of the system and take appropriate actions that can be used in actual business.

Looking at the flow of the PSE voluntary inspection from the perspective of the review flow again, the positioning of the PSE voluntary inspection

In the first place, some people may have doubts about "voluntary inspection?", so I will review it using the flow diagram of the Ministry of Economy, Trade and Industry.

Citation: Ministry of Economy, Trade and Industry_Act on the Safety of Electrical Appliance and Materials_Flow of Notification and Procedures_Voluntary Inspection

Voluntary inspection refers to inspection (inspection) at the stage of completing PSE inspection, etc. and importing it into the Japan after shipment and production. In other words, all electrical appliances are not completed after completing the PSE test, and operators are obliged to check whether their quality is maintained for each production.

Voluntary inspections described in Article 8, Paragraph 2 of the Electrical Appliance and Material Safety Act (PSE)

The text describes it this way:

Chapter III Conformity Inspection, etc. of Electrical Appliances and Materials

(Obligation to Conformance to Standards, etc.)

2. The notified business operator shall, pursuant to the provisions of an Ordinance of the Ministry of Economy, Trade and Industry, produce or import electrical appliances and equipment set forth in the preceding paragraph pertaining to its manufacture or import (excluding those manufactured or imported pursuant to the provisions of the proviso to the same paragraph) Inspections shall be performed, the inspection records shall be created, and they shall be saved.

As far as I can see from this part, it is unclear who will do what.
This part is also checked many times when receiving consultation from customers.

In practice, we are not in a position to respond to consultations.

"For details, please check with the Ministry of Economy, Trade and Industry / Bureau of Economy, Trade and Industry."

I urge you first.

And then

"I heard it, but I'm not sure."

The majority of the replies are that.
From the standpoint of an official, this is not something that a business operator cannot explain in a friendly and polite manner, nor does it mean that he will tell you what is necessary in advance.

In other words, the person in the position of asking the question will not be able to get the answer they really want unless they have a certain amount of knowledge, but the person who inquires for the first time is asking the question because they do not have such knowledge. There's a lot going on here, and only time passes.

About a little more concrete voluntary inspection on the Ministry of Economy, Trade and Industry page

On the other hand, if you look at the page of the Ministry of Economy, Trade and Industry on PSE voluntary inspections, the contents are summarized in this way.

Voluntary inspection

When manufacturing or importing electrical appliances and materials, the notifying business operator must conduct inspections according to the inspection method prescribed by the government, prepare inspection records, and keep them for three years from the date of inspection.

The method of inspection is stipulated in the Ministerial Ordinance for specified electrical appliances and materials and electrical appliances other than specified electrical appliances and materials, respectively.

Add the following contents to this and keep it as an inspection record.
・Classification of product names and models of electrical appliances and materials, as well as an overview of structure, materials and performance

・Date and place of inspection

・Name of the person who conducted the inspection

・Quantity of electrical appliances and materials inspected

・Method of inspection

・Inspection results

Citation: Ministry of Economy, Trade and Industry website_Electrical Appliance and Material Safety Act_Flow of Notification and Procedures_Voluntary Inspection

 

Let's remember only here Important points about the contents of the voluntary inspection!

Voluntary inspections are basically conducted by the factory.

Who conducts voluntary inspections after product production? The answer to the question is that the factory basically does the voluntary inspection. The reason is that if a company that does not have production facilities does it, it is necessary to start from the place where the equipment is arranged.

It is an inefficient story to inspect what the factory produces elsewhere.

Is the voluntary inspection a 100%? Is it a removal inspection?

Pse voluntary inspections are required to be 100% inspections.

Do I need a sample recording form?

The Ministry of Economy, Trade and Industry believes that one piece of head paper is sufficient for the records that importers should keep. However, the inspection records themselves should be stored in the factory.

Is there a format for recording paper?

There is no special format specified by the Ministry of Economy, Trade and Industry. If the required inspection contents are included, the format is fine.

Is the contents of the voluntary inspection unique to PSE?

Basically, there is very little to do with PSE voluntary testing. It's not just PSE (Japan), it's just the minimum post-production inspections required for shipments anywhere in the world. In other words, keep what you should be doing in any decent factory as a PSE voluntary inspection report.

 

Many people misunderstand!? Self-inspection is not required at the time of business notification

This is also a story that is often heard.

"When do I submit my voluntary inspection report?"

To state the answer first,

"Basically, we don't submit it, so we don't need a voluntary inspection report when we submit our business."

Leaving aside whether it is good or bad, if there is a problem with the product on the market with regard to Japan PSE, the Ministry of Economy, Trade and Industry embarks on an investigation at that time.

So, weird, legally,

2. The notified business operator shall, pursuant to the provisions of an Ordinance of the Ministry of Economy, Trade and Industry, produce or import electrical appliances and equipment set forth in the preceding paragraph pertaining to its manufacture or import (excluding those manufactured or imported pursuant to the provisions of the proviso to the same paragraph) Inspections shall be performed, the inspection records shall be created, and they shall be saved.

However, it is written that disclosure is required by the Ministry of Economy, Trade and Industry when there is an accident, etc., or when it becomes an investigation subject by regulations after distribution. By the way, those who consulted with our company under the regulation after distribution were not required to disclose the voluntary inspection report.

In other words, from the standpoint of people who know the actual situation, I sometimes personally feel that there is no need to have [a voluntary inspection report].

However, in recent years, the social eye has become severe due to the fraud problem related to the inspection of railway-related products that have continued for more than 35 years of Mitsubishi Electric, and many people think that it is still necessary to properly implement product safety measures.

Of course, we think so, but if we should properly grasp the system design of PSE in the first place, and if you do not know anything and say "voluntary inspection, voluntary inspection", I think that it is not good as a business.

As a matter of fact, will production plants in China (overseas) conduct voluntary inspections?

We often ask us if they will act as a substitute for voluntary inspections, but basically we do not perform voluntary inspections on our behalf.

As for the reason, as I mentioned a little earlier, the factory should perform voluntary inspections by itself, and the most efficient is that factories with facilities related to the product do it.

Instead of doing voluntary inspections because there is a voluntary inspection of PSE, it is a good thing to conduct voluntary inspections (pre-shipment inspections) as a professional ethics of the factory in the first place. And, there is no thing that is originally difficult for the voluntary inspection items of PSE, and only basic inspections.

However, it may be difficult to convince the factory to think about the format of the report, and we may provide a format for voluntary inspection reports as an option for PSE testing according to the customer's request.

It is also true that there are still a lot of factories which do not want to inspect it though it becomes a conclusion that the factory should do in principle theory. What should I do if I do that? It is asked, but it becomes a problem of the arrangement between the business operator and the factory.

By paying inspection costs in addition to the production price, will you have them prepare their own inspection reports? Or, do you persistently ask and get them to do something?

We also accept consultations about negotiations with such factories, so if you have any problems, please contact us.

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