Problems relating to Trade and Investment on EU
19. Industrial standards, approval of safety standards |
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Issue |
Issue details |
Requests |
Reference |
| (1) Excessively Heavy Burden for Acquisition of CE Mark | - Japanese exporters must apply the CE Mark on a product sold to EU market, Norway, Liechtenstein, and Iceland, each time the product is covered by the specific provision of the law. - Acquisition of CE Marking is prerquisite for distribution and sales of products in European Economic Area, without which no business development is possible. However, its acquisition is not only time consuming, but also acquisition procedures is unclear in part. |
- Exporters are responsible to go through the expensive test and certification procedures, when selling Japanese products in France and EU. By conclusion of the Japan-EU FTA, there is a possibility that the certification system is harmonised between the EU and Japan. - It is requested that EU streamlines and clarifies the CE Marking acquisition procedures. |
- CE marking - SOC - Council Regulation (EU) N 339/93 - Directive (2004/108/CE) - French decree n 2006-1278 |
| (Action) - GOJ presented a request for improvement at the Japan-EU Regulatory Reform Dialogue. |
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| (Improvement) - On 31 December 2004, new Directive 2004/108/EC was published in the Official Journal, and in May 2007, the new Guide for the EMC Directive 2004/108/EC was published. |
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| (2) Compulsory Attachment of CE Mark | - EU compels attachment of CE mark virtually on all products. As regards commodity products such as fire pumps manufactured in Japan, as a matter of course, they are manufactured to satisfy the Japan Industrial Standard (JIS). However, if this product is destined to distribution in EU, it becomes necessary to check and confirm if it is designed after the relevant EU Directives, and if it satisfies the inspection standards of every kind in EU on certain models, by appointing a professional consultant to enable issuance of a self-declaration of conformity. |
- A member firm contemplates introduction of a model to the EU market. Attachment of CE mark is compulsory even for a single unit equally upon a product for which the exporter has no idea how many can be sold in EU. For an SME enterprise, filing application for CE mark is risky and costly. Saving is significant, if the requirements are simplified in a less costly manner in time and expenses. | - The Council Decision of 22 July 1993 |
| (3) Stringent Standard on Protection of Potable Water | - The Standard for "Protection against pollution of potable water in water installations and general requirements of devices to prevent pollution by backflow" sought within the EU area, compared with those of outside the EU area, is unique and extremely stringent. For this reason, toilet seat with a warm-water shower feature destined to the EU area must have different specifications as regards its hydrographic composition and materials. | - It is requested that EU amends its Standard in line with the standard outside EU to maximise efficiency in product development. | - CSN EN 1717 Protection against Pollution of Potable Water in Water Installations and General Requirements of Devices to Prevent Pollution by Backflow |
| (4) Abrupt Removal of a Paragraph from Questions and Answer Web Page on Removing Batteries from Appliances | - In regard to QUESTIONS AND ANSWERS ON THE BATTERIES DIRECTIVE (2006/66/EC), out of the blue, without any advance notice, whatsoever, a whole paragraph has been removed from Q&A since November 2012 at under the caption of "What does 'batteries and accumulators can be readily removed' mean?" which in effect states: "it suffices the requirements, if end-users or professionals should be able to remove batteries from appliances," namely, reading as follows: End-users or professionals (e.g. appliance service centres, waste treatment facilities) should be able to remove batteries from appliances. The instructions showing how the batteries can be readily and safely removed should also specify who, in the view of the manufacturer, the best person to safely remove the battery is. The instructions should also describe any dangers of not complying with the battery removal instructions. Where there is more specific legislation applying to specific products (e.g. toys) on how the batteries should be removed, these products should comply with those specific rules. While the process for the deletion requires further rectification, should EU disapprove removal by professionals (recyclers, etc.), it will heavily burden manufacturers, who must absorb the cost of design change on Small Electric and Electrical Appliances. Moreover, its disapproval necessitates enlargement of machineries and equipment (heavier). It detracts from the operational ease, due to the increased weight of the equipment at the cost of the users' convenience. Moreover, satisfaction of this requirement results in an increased amount of plastic materials used, turning them into waste materials in the end past the products' useful life. It triggers the vicious cycle of increased volume of industrial waste that gives negative impact upon the environment. |
- Before making changes to Questions and Answer, it is requested that EU first exchange views with the interested parties. - It is requested that EU authorises Battery removal by professionals and restores the deleted Q&A. |
- Directive 2006/66/EC of 6 September 2006 on Batteries and Accumulators and Waste Batteries and Accumulators, and Repealing Directive 91/157/EEC - Commission Services Document: Questions and Answers on the Batteries Directive (2006/66/EC) |
| (Action) - Article 11 (Removal of waste batteries and accumulators) of the amended Battery Directive adopted on 10 October 2013 by the European Parliament adds provisions to the effect that assurance for the ready removal by the end-user and by qualified professionals suffices. However, the Commission's DG Environment provides under its Frequently Asked Questions at its website: "Its main provision is that Member States must ensure that the electrical or electronic equipment covered by the Directive is designed in such a way that waste batteries and accumulators can be (de facto) "readily" removed (by end-users.)". |
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| (5) Lack of Interchangeability Scheme in Industrial Standard | - No compatibility is secured between European Standards (PED, SIL) and Japanese Industrial Standards (JIS). Relative to Pressure Equipment Directive (PED), in substance, products with the JIS approval are rarely accepted. It seems hardly any customer swallows the idea that JIS is more stringent than PED, therefore, should be acceptable. | - It is requested that EU takes steps to: promulgate regulation that condemns unjustifiable treatment where interchangeability is recognised between EU and Japan regarding individual standards. It will save time and cost for conversion between the standards and expand business opportunities. | - SIL: IEC 61508 - PED |
| (6) Disapproved Export with the JIS Mark | - Food manufacturing equipment manufactured to the JIS Standards cannot be used in (or exported to) EU for local manufacture of food products. Japanese food manufacturing technology is superb in safety and hygiene. Nevertheless, the EU/the U.S. Standards serve for no purpose but totally as non-tariff barriers. | - It is requested that the concerned authorities advance mutual recognition of safety standards between Japanese and EU/the U.S. on food processing/ fabricating machines. | - CE marking |
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