To get your product into the Japanese market, it needs to be certified for Japanese Radio Law, Business Law and/or Weak Power / Receiver equipment, all based on Regulations specified and maintained by the Ministry of Information and Communication (MIC) in Japan. The Certificate for Radio Law and Business Law will be issued by the Japan CAB and is legally valid to market your equipment in Japan.
Radio Law
The Radio Law defines the requirements for Japanese approval of Radio Equipment. Radio Law certification can be obtained for three categories of Radio Equipment as specified in MPT Ordinance 37 article 38-2-2, Paragraph 1, item I (unlicensed, like bluetooth), II (licensed like cellphones) and III (others like amateur radios). Each type of radio technology has its own symbolic 2-digit equipment code (“Mark”), similar to the 3-digit FCC equipment code). MIC has published Technical Regulations , Additional Notifications and Test Methods. Certified Radio Equipment is also published by MIC.
Business law
The Telecommunications Business Law defines the requirements for Japanese approval of Telecom Equipment. Business Law Certification can be obtained for Termial Equipment to be connected to analog telephone facilities (PSTN, ADSL, WCDMA-handheld), radio calling facilities, ISDN facilities (BRI,PRI) or leased/digital data transmission facilities. Radio Equipment Interfaces used for public telecom services (e.g. Ethernet or 802.11a/b/g/n air interfaces for hot spot) require business Law Certification.
Essential requirements
The essential requirements for the approval of Radio Equipment for the Radio Law are specified in a generic way. The link he Radio Law can be found here.
The essential requirements for the approval of Telecommunication Terminal Equipment for the Telecommunications Business Law are specified in a generic way. The link to the Telecommunication Business Law can be found in Japanese here.
As for Extremely low power regulation; Certification is in this case voluntary, because this type of radio equipment does not need to be certified for use in Japan. The requirement is that all emissions of the radio equipment remain below the “extremely low power” regulation limits. See the following link.
Equipment classes
Japan divides radio equipment into three main categories.
- Category 1, unlicensed (low power) stations, 20 classes:
Specified Radio Equipment specified in Article 38-2, paragraph 1, item 1 of the Radio Law. - Category 2, licensed stations (blanket license), 38 classes:
Specified Radio Equipment specified in Article 38-2, paragraph 1, item 2 of the Radio Law. - Category 3, licensed stations, 101 classes:
Specified Radio Equipment specified in Article 38-2, paragraph 1, item 3 of the Radio Law. - Special specified radio equipment. The list of the three categories, special specified radio equipment, and all associated classes may be
found here.
Common technical requirements
Basic and common requirements are to be found in the Ordinance concerning Technical Regulations Conformity Certification of Specified Radio Equipment.
- Article 5: Frequency tolerance.
- Article 6: Occupied bandwidth (99% bandwidth).
- Article 7: Spurious and unwanted emissions.
- Article 14: Tolerance on antenna power.
- The applicant must state or declare the “rated antenna power” (specification). Rated antenna power is not the highest measured antenna power by default.
- The measured antenna power value must be within -80 % / +20 % or -50% / +50% of the “rated antenna power” value in case the “rated antenna power” value equals the limit for antenna power.
- In the case of FHSS devices, the antenna power is measured in hopping mode.
- The antenna power is the measured power divided by the 90% bandwidth (spreading bandwidth).
- Article 15: Condition for frequency stabilization.
- Article 15-1 requires that all testing must also be performed with a variation of ±10% of the nominal supply voltage.
- Testing at ±10% of the nominal supply voltage is not required when the radio equipment incorporates an onboard voltage regulator of which the DC output voltage remains within ±1% of the nominal DC output voltage when the supply voltage of the radio equipment is varied by ±10%.
- In case it has been verified that the DC output voltage of the onboard voltage regulator (if present) remains within ±1% of the nominal DC output voltage then a statement to that effect must be included in the test report.
- It is possible to deviate from the ±10% requirement in case the supply voltage of the radio equipment may range between tighter limits.
- As an example, the DC output voltage of a USB bus typically may range between 4.75 – 5.25 Volts DC. In such a case the ±10% requirement may be adjusted to ±5%.
- In case of a device which is supplied by a battery; the typical variation in the input voltage ranges between the cut-off voltage of the battery and the maximum voltage which may be generated by the battery (instead of ±10% of the nominal battery voltage).
- However, if the device contains a regulator to which the battery is connected and the output voltage of the regulator remains within ±1% of the nominal output voltage of the regulator when the input voltage of the regulator is varied between the cut-off voltage and maximum voltage of the battery then only testing at the nominal battery voltage is required.
- Article 24: Secondary emissions (receiver spurious emissions).
- Article 9-4: Interference prevention function.
- The interference prevention function is sometimes mistaken for a carrier sense mechanism. The interference prevention function consists of the requirement that the transmitter must be able to transmit/receiver ID codes in order to authorize itself on the radio link.
- In the case of a Bluetooth, WLAN, ZigBee, etc., device the ID code must be 48 bits long.
- The MAC address of a Bluetooth, WLAN, ZigBee, etc., device is considered to satisfy the interference requirement function.
Inductive RF-ID equipment
RF-ID equipment, e.g. operating on 13.56 MHz, and which exceeds the limits of the “extremely low power” regulation needs to be tested after which the RF-ID equipment needs to be registered at, or notified to, MIC in Japan.
• The registration/notification process of MIC in Japan in such cases requires the presence of a local representative in Japan who will be the “registration holder”.
• The equipment needs to be marked with the registration number which will be provided by MIC in Japan.
• The applicable regulation is found in the Radio Law, Article 100, section 1 (equipment using high frequency).
• Summary of the technical requirements for 13.56 MHz
inductive reading/writing equipment:
– Carrier frequency: 13.56 MHz.
– Frequency error: less than 50 ppm.
– Spurious emission field strength measured at a measurement distance of 10 meters.
– For all harmonics and sub-harmonics the limit is 50 mW (the measurement values must be tested in µW and expressed in µW in the test report).
DFS testing (IEEE 802.11a/n/ac)
- Japan has their own set of DFS requirements which must
be tested and complied with in case an IEEE 802.11a/n/ac
transceiver is used as an access point (or, “master” station). - The requirements and test procedure can be found here
(in English):
https://www.tele.soumu.go.jp/e/sys/equ/tech/5ghz/5ghz.htm
SAR
- (Body) SAR: Not a requirement for specified low power radio equipment such as Bluetooth, WLAN, RF-ID, etc., which are operated either stand-alone or in combination with each other.
- (Body) SAR: Is a requirement in those cases where cellular transmitters are operated in combination with specified low power radio equipment such as Bluetooth, WLAN, RF-ID, etc., and where the transmitters may be operated at a distance closer than 20 cm to the body.
- (Body) SAR: Is a requirement where cellular devices may be operated at a distance closer than 20 cm to the body.
- (Head) SAR: Is a requirement where cellular devices may be operated close to the head.
- Reference standards are IEC 62209-1 and IEC 62209-2.
RF Exposure requirements
Japan has RF exposure regulations for head and body SAR. However, these regulations do not apply to 2.4/5 GHz (Wi-Fi, BT, BLE) transceivers when used in a stand-alone configuration.
The Japanese body SAR regulation is only applicable when (1) a 2.4 GHz (Wi-Fi, BT, BLE) module is integrated in a host which also contains a cellular radio transceiver (e.g. 3G, 4G, 5G, satellite transceivers, etc.) AND (2) the host device may be used at a distance closer than 20 cm to the human body.
If the host device only contains a 2.4/5 GHz (Wi-Fi, BT, BLE) transceiver then no action needs to be taken with respect to RF exposure, except that the host device should be labeled with the GITEKI mark and certification number as found on the label of the radio module.
Compliance with the Telecommunications Business Law
Devices that connect directly or indirectly to the public network (and this is carrier systems as well as the public internet) must comply with Article 9 of the Telecommunications Business Law. This is a requirement that is designed to provide a minimum Quality of Service (QoS) for users of the public networks. It requires that a radio transmits an identification code in order to identify itself on the network (it’s like assigning a unique phone number to each transmitter).
Labeling of radio equipment
• The radio equipment must be marked with the certification mark (GITEKI mark) and certification number on an “easily recognizable” part of the radio equipment.
• In the case of a mobile phone, and other radio equipment where the certification mark (GITEKI mark) and certification number cannot be placed on the outside of the radio equipment due to practical reasons, the certification mark (GITEKI mark) and certification number may be located inside the battery compartment.
• In case the certification mark (GITEKI mark) and certification number cannot be affixed to the radio equipment because of size restrictions, the certification mark (GITEKI mark) and certification number must be placed in the user manual and on the packaging.
• The certification mark (GITEKI mark) and certification number must be grouped together, the mark and number may not be located on different locations on the device.
• The diameter of the Giteki mark, previously “3mm or greater” has now been changed to “as long as the indication can easily be distinguished by anyone”.
The manufacturer must affix the following marking for which approval has been granted by an RCB for radio law.
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The certification number is not free to be chosen or selected by the applicant/manufacturer but will be selected for you.
Please also note that if your products operates in the 5.15 – 5.25 GHz and 5.25 – 5.35 GHz bands, then this is restricted to indoor use only. Put the following text on your label.
LABEL: 電波法により5.2/5.3 GHz帯は屋内使用に限ります
(Translation: “5.2/5.3 GHz band is restricted to indoor use due to the Radio Law.”)
Or (in case the radio equipment supports just one of the two frequency bands):
電波法により5.2 GHz帯は屋内使用に限ります
電波法により5.3 GHz帯は屋内使用に限ります
Labeling of TTE equipment
• For TTE equipment the same labeling as for Radio Law must be placed on an easily recognizable location of the equipment.
• For TTE equipment the boxed “R” must be replaced by a boxed “T”.
• In case the equipment contains both a radio and TTE part, both certification numbers must be placed adjacent (or next to) the certification mark (GITEKI mark).
Electronic labelling
• Electronic labeling” is allowed by the Radio Law in Japan. Electronic labeling can be used with radio equipment having an integrated display. So then in this case you could show the conformity marking in an electrical image on the digital screen instead of a physical label on the exterior of the radio equipment.
• The electronic labeling can now also be used with radio equipment without an integrated display but to which an external display can be connected. The GITEKI mark and certification number must be displayed on the external display prior to the (first) activation of the transmitter of the radio equipment. This requirement implies that it is only allowed to connect an external display to the radio equipment by a wired connection.
Modular approval
• A radio module can be certified when tested in a stand-alone configuration in accordance with the full requirements of the Radio Law (although the concept of a “modular approval” does not exist in the Radio Law)
• A certified radio module must be labeled with the certification mark (GITEKI mark) and certification number.
• A radio module MUST be certified in combination with at least one antenna. The certificate is only valid for the combination of radio module and antenna(s) as covered by the certificate.
• When certified, the radio module may be integrated in any host equipment without additional testing, except where also certain certified radio modules (e.g. GSM, UMTS, LTE, etc.) are integrated in a host product which may be used at a separation distance which is closer than
20 cm to the body (e.g. tablet).
• In such cases the combination of host product and radio module(s) must be tested for the requirements of the body SAR regulation in Japan.
• A new certificate and certification number is then required to be issued for the combination of host product and radio module(s).
• In the case above, the certification body needs to carry out a limited assessment on the combination of host product and radio module(s) where it concerns the RF parameters of the radio module(s).
• The new certificate will list all the parameters of the radio module(s) which are integrated in the host product and therefore covers the combination of host product and radio module(s) which are integrated in the host product.
• The certification mark (GITEKI mark) and new certification number must be placed on the host product.
• The following is stipulated in the ordinance concerning GITEKI marks (enforced on September 1, 2014) regarding the labeling of host products with embedded and certified radio modules (excluding products with embedded radio modules which require additional body SAR measurements).
Please note that it is no longer mandatory to affix the GITEKI mark and certification number of an embedded radio module to the host product.
• Choose one of the following methods to VOLUNTARY display the GITEKI mark on host products in which radio equipment with the GITEKI mark is embedded:
• (1) Verify the GITEKI mark and certification number which is attached to radio equipment, which is embedded in host product(s), and display the GITEKI mark and certification number in a conspicuous place on the host product(s).
• (2) Verify the GITEKI mark and certification number which is attached to radio equipment which is embedded in the host product(s) and electronically display the GITEKI mark and certification number on the integrated display of, or on an external display which uses a wired connection to connect to, the host product(s) into which such radio equipment has been embedded.
It must be noted in the user manual that the GITEKI mark and certification number are electronically displayed and the user manual must describe how the GITEKI mark and certification number can be displayed on the integrated display. In cases where an external display, which uses a wired connection to connect to the host product(s), is used the GITEKI mark and certification number must be displayed on the external display
prior to the (first) activation of the transmitter of the radio equipment.
• In addition, it is recommended that the following text is shown on the host product and/or in the user manual to indicate the presence of certified radio modules:
当該機器には電波法に基づく、技術基準適合証明等を受けた特定無線設備を装着している。
Translation: “This equipment contains specified radio equipment that has been certified to the Technical Regulation Conformity Certification under the Radio Law.”
Module integration: So if you are installing a module which already has Japan certification then it is not necessary to certify your host device. But just add the above mentioned text on your product, to show that it contains a certified radio module.
Permissive changes
• A limited number of permissive changes are allowed on a certified device without having to apply for a new certification number.
• For a number of equipment categories it is allowed to make changes in the antenna system of the radio equipment (e.g., adding different antennas).
• It is allowed to replace or substitute components having the same footprint and with equal or better performance.
• Changes in components may not alter the characteristics of the radio equipment.
• There is no amendment to the documentation of the certified radio equipment.
• There are no changes in the circuit diagram, except for type numbers of components. It is not allowed to replace the radio circuit or chip in certified radio equipment.
• Adding a modulation method is allowed in those cases where there is no change in hardware or software of the certified radio equipment.
• Adding a modulation method is allowed under the control of a telecommunications provider in case a software update is required to add the modulation method.
• Adding additional frequencies of operation to certified radio equipment by means of a software update is only allowed under the control of a telecommunications provider.
• Spurious emission measurements are always required in case of permissive changes (with the exception of changes in antennas).
• All changes in certified radio equipment requires a (partial) assessment by the certification body and requires a new release of the certificate.
• Please note that the certification number contains the identification number of the certification body which certified the device in question. Because of this, it is not possible to use any certification body of your choice for Japan, in case permissive changes need to be reviewed. Permissive changes must always be filed at the certification body which issued the original certificate.
• Limited changes in the non-radio part(s) of the radio
equipment are allowed
Japan Quality Assurance Compliance
MIC requires continuous compliance with the radio parameters. An ISO certificate is typically sufficient. If not available, what is required, is a signed declaration of continuing quality control, a copy of their quality system procedure(s) which describe(s) how they will ensure the continued compliance of the radio equipment with the requirements of the Japanese Radio Law. Such a procedure could describe incoming inspection procedures, possible sample testing, etc. However, the procedure must be focused on compliance with the Japanese Radio Law.
Required exhibits
- Application form
- Authorization form
- RF exposure declaration
- Quality management system
- Construction protection confirmation
- ISO 9001, or equivalent
- Block diagram
- Schematics
- Parts list
- PCB layout
- Label/manual
- External photos
- Internal photos
- Test setup photos
- Antenna information
- Test report
Short description on the required exhibits
- Application form – Further information on the product and application type
- Authorization form – Authorizing your agent to submits the application.
- RF exposure declaration – Needs to be signed by the CEO of the company (applicant); Stating the operating frequencies and max rated output power.
- Quality management system – In this document you should explains how the quality, relating to the continued compliance of the device with the requirements of the Japanese Radio Law, is controlled for mass-production of the radio device.
- Construction protection confirmation –
- ISO 9001 – In case no ISO certificate(s) is(are) available, and where the company involved do not have a certified quality system, a detailed description of the quality system describing the procedures of how to guarantee the continued compliance of the device with the Japanese Radio Law in mass production must be submitted.
- Construction Protection Confirmation. The applicant has to declare the method(s) to prevent the end user changing the key components of the product.
- If the housing of the product uses screws, then the type of the screw should be unique. “Unique” is defined as those unable to be opened by tools normally available in the market. A description of these screws should be provided (i.e. exterior view, size, etc.);
- The housing can be ultrasonically welded, glued, or other permanent method such that the device is not intended to be opened.
- For other methods, the applicant must explain how the housing can not be opened by the end user and how attempting to would damage the device.
- If none of the above 3 can be fulfilled, then the key components must be fixed by glue. “Key components” are defined as crystal, VCO, memory, transceiver, base-band circuitry, RF power amplifier, filter, RF switch IC. Any component which is included underneath a fixed shield (no removable cover) has no need to be glued.
- Block diagram – Of the whole device.
- Schematics – Of the whole device.
- Parts list – List all components names and values of the whole device
- PCB layout – Show where all components are placed on the board.
- Label/manual – Label information should include label drawing, label location, material of the label, and the Giteki mark with box or R or T. As for the manual, it should just show the user instruction for the end user. No specific statements needed.
- External photos – Photographs of all sides of the device, including an indication of the dimensions (e.g. by placing a rules next to the device when it is being photographed.
- Internal photos – Interior photographs of the device, including an indication of the dimensions. Both sides of the PCB must be shown. Pictures of the PCB with and without shielding (where applicable) must be submitted.
- Test setup photos – Photos of the deice under test as it is being tested.
- Antenna information – Antenna information must include the radiation patterns, peak gain values, beam width, photographs and dimensions).
- Test report – Test report of the device.
- A report showing compliance to the Radio Law requirements, identify test procedures used, the date the measurements were made, location where measurements were made, the device tested, sample calculations and conversions for comparison with the technical requirements, accreditation status of the test facility. The test report should include, or they can be separately provided, accreditation certificate and scopes when relevant. The test laboratory does not necessarily need to be accredited. The acceptance of test data is at the discretion of the certification body to which the application for certification is submitted.
- The test report needs to contain calibration information for the measurement equipment which has been used during testing. Ideally the calibration interval should be 1 year although this could also be 2-3 years, depending on the type of test equipment. The test laboratory does not necessarily need to be accredited. The acceptance of test data is at the discretion of the certification body to which the application for certification is submitted.
- The test report needs to contain calibration information for the measurement equipment which has been used during testing. Ideally the calibration interval should be 1 year although this could also be 2-3 years, depending on the type of test equipment.
Japan MIC links:
- Japan Radio Website
- Japan Registered Radio products by CAB
- Japan Radio Regulations
- Japan Radio Law
- Association for Radio Industries and Businesses
- Japan Approvals Institute for Telecommunications Equipment
- Specified Radio Equipment Class Identifiers
- Japan Specified Categories (Telec website)
- Japan Frequency assignments