WORKSHOP “The Regulatory System for Importing Electrical /electronical Goods to Japan” on 2010-06-29 in Tel Aviv by Kurt K. Heinz NCB TÜV Rheinland Japan 1 Contents: 1. Electrical Appliance and Material Safety Law (DENAN Law) 2. New Pharmaceutical Affairs Law (PAL) 3. Test and Certification for Telecommunication Products 4. Supplemental explanation on Japanese regulations 2 1. Electrical Appliance and Material Safety Law (DENAN Law) 3 1. Electrical Appliance and Material Safety Law (DENAN) Explanation for “Denki Yōhin” - Electrical Appliance and Materials In the DENAN, ”Denki Yōhin” is classified into two categories -“Category A” and “Category B” Category A product : Need to obtain “Certificate of Conformity (CoC) by Registered Conformity Assessment Body (RCAB) = Registered by Japanese Government. Category B product : Not necessary to get CoC, but there is the obligation to conform to the Technical Requirements stipulated by the Ministerial Ordinance. Self- verification (confirmation) can be done by manufacturer. NOTE: There are many other products not being in scope of DENAN Law. And, even if subjecting to DENAN, there are also products being in scope of another regulation, e.g., therapeutic apparatus for households use, microwave oven, etc. 4 1. Electrical Appliance and Material Safety Law (DENAN) DENAN - Concept of Denki Yōhin* * “Denki Yōhin” = The products specified by “DENAN” Category B products (other electrical appliance and materials) “Denki Yōhin” Total : 339 items = Electrical Appliance Category A Products (specified electrical appliance and materials) Total : 115 items Category A and Category B Total : 454 items 5 and Materials 1. Electrical Appliance and Material Safety Law (DENAN) Electrical products in Japanese market Products controlled by DENAN Products not controlled by DENAN Other Category B products electrical products 339 items not in scope of DENAN which are (but, may be in scope of other regulations, e.g., Radio Law, Category A products 115 items 6 Pharmaceutical Affairs Law, etc.) 1. Electrical Appliance and Material Safety Law (DENAN) In the DENAN Scope? Mobile Phone Out of Scope of DENAN Why? Because it is powered by a battery. 7 1. Electrical Appliance and Material Safety Law (DENAN) In the DENAN Scope? Power Supply Device with DC Output Category A AC Electrical Appliance DC Power Supply Unit 8 1. Electrical Appliance and Material Safety Law (DENAN) In the DENAN Scope? Power Supply Device without Enclosure Out of Scope of DENAN 9 1. Electrical Appliance and Material Safety Law (DENAN) In the DENAN Scope? Extension Cord Set Category A Wiring Devices Multi Tap, Cord, Attachment Plug (respective part) 10 1. Electrical Appliance and Material Safety Law (DENAN) In the DENAN Scope? Coffee Maker Category B Electrical Heating Appliance Electric Coffee Maker 11 1. Electrical Appliance and Material Safety Law (DENAN) In the DENAN Scope? Hair Dryer Category B Electrical Motor Operated Appliance Electric Hair Dryer 12 1. Electrical Appliance and Material Safety Law (DENAN) In the DENAN Scope? DVD Player Category B Electronic Appliance Other Audio Equipment 13 1. Electrical Appliance and Material Safety Law (DENAN) In the DENAN Scope? Refrigerator Category B Electrical Motor Operated Appliance Electric Refrigerator 14 1. Electrical Appliance and Material Safety Law (DENAN) In the DENAN Scope? Massage Chair Category A Electrical Motor Operated Appliance Electric Massager 15 1. Electrical Appliance and Material Safety Law (DENAN) In the DENAN Scope? Paper Shredder Category A Electrical Motor Operated Appliance Shredder 16 1. Electrical Appliance and Material Safety Law (DENAN) Conformity Assessment For Category A product For example: DC Power Supply Unit Select Technical Requirement : Clause 1 or Clause 2 Product Evaluation (Safety & RFI) Survey for test equipment of manufacturer Need both compliances OK OK Issue of CoC 17 1. Electrical Appliance and Material Safety Law (DENAN) Product Evaluation Safety related Category A product + Category B product RFI related (if required) Technical requirement Ordinance Clause 1 Technical requirement Ordinance Clause 1 Technical requirement Ordinance Clause 2 Technical requirement Ordinance Clause 2 Selection NOTE: Clause 1: Japanese original, requirements existing by each designated product Clause 2: based on international standards RFI test is part of Technical Requirements, but not for all. 18 1. Electrical Appliance and Material Safety Law (DENAN) Applicable Technical Requirements / Standards Products specified by “DENAN Law” should be tested in accordance with the technical requirements /standards specified by MITI Ordinance Clause 1 or 2 Selection Possible (Chose one) MITI Ordinance for Technical requirements MITI Ordinance for Technical requirements MITI Ordinance Clause 1 MITI Ordinance Clause 2 Technical requirements Technical requirements Appendix 1-8 J-IEC standards (Remarks) Not only Safety requirements but also RFI requirements are included. (Remarks) Not only Safety requirements but also RFI requirements are included. Technical Requirements consist of two standard groups : Category A products / Category B products are required to be tested according to the following standards. (Either Clause 1 or Clause 2) Need to be in compliance with either Clause 1 or Clause 2. 19 1. Electrical Appliance and Material Safety Law (DENAN) DENAN Flowchart Important ! Is your product in question in the DENAN Law scope??? No Out of Scope of DENAN Law The Law does not apply YES Category A product Is your product Category A?or Category B? Category B product Japanese Mfr. Flow-Chart (A) Flow-Chart (C) Japanese Mfr. Overseas Mfr. Flow-Chart (B) Flow-Chart (D) Overseas Mfr. 20 1. Electrical Appliance and Material Safety Law (DENAN) Overseas Mfr. / Japanese importer DENAN Flowchart (B) for Category A products Request for CoC Overseas nations Mfr. who produces Category A product Japanese importer Business relation Conformity assessment (Mandatory) by RCAB Application ■Product Test according to Technical Requirement Clause 1 or Clause 2 (Safety / RFI ) Pass Obligation of Japanese Importer ■Factory Inspection Site/facility check “Issue of CoC” (As Notifying Supplier) ■Obligation to keep “CoC” (copy) ■Obligation to check conformity with technical requirements ■Obligation to make and keep inspection records ■ Obligation for marking; “Notifying Supplier’s name” + ”RCAB’s name” + 21 Overseas Mfr. Need to fulfill the obligation as Notifying Supplier Business relation “Submittal of CoC Authorized Valid Copy Japanese Importer 1. Electrical Appliance and Material Safety Law (DENAN) Overseas Mfr. / Japanese importer for Category B products DENAN Flowchart (D) Obligation to conform to Technical requirements Confirmation Japanese importer Overseas Mfr. who produces “Category B” product Business relation Overseas Mfr. can apply to 3rd party testing body for compliance testing (not mandatory = voluntary) 3rd party testing ■Product Test according to Technical Requirement selection Clause 1 or Clause 2 (Safety / RFI ) Compliance check by Mfr. by themselves ■Product Test according to Technical Requirement Clause 1 or Clause 2 (Safety / RFI ) Obligation of Japanese Importer (As Notifying Supplier) ■Obligation to check conformity with technical requirements ■Obligation to make and keep inspection records ■ Obligation for marking; “Notifying Supplier’s name” + Self confirmation Overseas manufacturers Need to fulfill the obligation as Notifying Supplier Business relation Submittal of the evidence of compliance Japanese Importer 22 1. Electrical Appliance and Material Safety Law (DENAN) Audit / Registration Report upon request Notification of starting business Manufacturer Registered Conformity Assessment Body Registration by METI Request for CoC (Application) Issue of CoC Request for CoC (Application) Issue of CoC Request for CoC equivalent (Application) Issue of CoC equivalent 23 Category A Products Legal action if necessary Notifying Supplier Importer Notification of starting business Category A Products Request for CoC equivalent Ministry of Economy, Trade and Industry (METI) Legal action if necessary Submit of CoC equivalent Overseas manufacturer (category A product) =(outside Japan) 1. Electrical Appliance and Material Safety Law (DENAN) Legal marks stipulated by DENAN Law in Japan There are two kinds of legal marks; one for specified electrical appliances and materials and another for other electrical appliances and materials. Marking for Category A (specified electrical appliances and materials ) For electric cables/cords, fuses, wiring devices etc, if there is not enough space for marking, manufacturers, etc. it may be marked as “<PS>E” instead of this Mark. Notifying Supplier’s name and RCAB name who conducted the “Conformity Assessment” have to be indicated near the PSE-diamond mark. Marking for Category B (other electrical appliances and materials ) (those not specified in Category A) For electric cables/cords, conduits and its accessories, fuses, wiring devices etc, if there is no enough space for the notifying supplier’s name, it may be marked as “(PS)E” instead of this Mark. Notifying Supplier’s name has to be indicated near the PSE-Circle mark. 24 1. Electrical Appliance and Material Safety Law (DENAN) About METI HP: Information of DENAN is available in http://www.meti.go.jp/english/policy/economy/consumer/pse/index.html The following is an example of information available on the above HP. 25 2. New Pharmaceutical Affairs Law (PAL) 薬 事 法 26 Yaku Medicine Ji issue, topic Hō law Pharmaceutical Affairs Law 2. Pharmaceutical Affairs Law (PAL) The New PAL – Introduction and Overview Pharmaceutical Affairs Law (PAL, ‘Yakujihō’) Revised by the MHLW effective since 2005-04-01 http://www.mhlw.go.jp/ Article 1: This law is intended to provide regulations required to ensure the quality, efficacy and safety of drugs, quasi-drugs, cosmetics and medical devices and to improve the public health and hygiene through necessary measures taken to promote the research and development of drugs and medical devices which are of particular importance to the medical practice. 27 2. Pharmaceutical Affairs Law (PAL) The New PAL – Introduction and Overview NEW: Review of the Safety Measures for Medical Devices New System of Medical Devices Classification Product Certification of the Designated Controlled Medical Devices (Class II) by Registered Certification Bodies(RCBs) 28 2. Pharmaceutical Affairs Law (PAL) New System of Medical Devices Classification [General Medical Devices] – Class I, extremely low risk Potential risk is almost insignificant in case of malfunction or side effect. Examples: scalpel, X-Ray film [(Designated) Controlled Medical Devices] – Class II, low risk Having potential risk in case of malfunction or side effect. Examples: MRI, electronic sphygmomanometers, gastric catheters [Specially Controlled Medical Devices] – Class III / IV, middle/high risk Potential risk is significant in case of malfunction or side effect. Examples: dialyzer, pacemaker, stent 29 2. Pharmaceutical Affairs Law (PAL) Product Approval/Certification Classification by PAL Class I Class II General MD (Designated) Controlled MD Class III Specially Controlled MD Product Certification no requirements by RCB Class IV Product Approval by MHLW (Application to PMDA) • RCB: Registered Certification Body (Designated) Controlled MD: Designated with certain criteria by MHLW • PMDA: Pharmaceuticals and Medical Devices Agency (Independent Agency of the MHLW) 30 2. Pharmaceutical Affairs Law (PAL) Necessary Approvals / Registrations Marketing Authorization Holder (MAH) - Resposible for distribution, quality of the product and manufacturing - Responsible for vigilance system Manufacturer (Manufacturing site) - Manufactures the products upon the order from MAH, products can be sold only to MAH or Manufacturer 31 Marketing Authorization Holder Supervising License to Marketing Authorization function MAH, (Marketing Approval Holder) GQP supervision GVP supervision QA function Post-marketing safety measures function GQP: Good Quality Practice products Info GVP: Good Vigilance Practice Sales office Domestic factory Overseas factory OEM factory (manufacturing Site ) (retail business) distributor QC compliant with the revised QMS(GMP) (ISO 13485) hospial 32 2. Pharmaceutical Affairs Law (PAL) Marketing Authorization System 1. ‘License to Marketing Business’ MAH Marketing Authorization Holder 2. ‘License (Registration) for Manufacture‘ Production License (-Registration) 3. ‘Device Approval (MHLW) / Certification (RCB)‘ Product Approval / Certification 33 2. Pharmaceutical Affairs Law (PAL) Special Rules for Foreign Manufacturers - A foreign manufacturer who intends to get product approval or product certificate: Appointment of the Appointed/Designated MAH (D-MAH) in Japan (needs the corresponding license). Appointed/Designated MAH(D-MAH) may be: (1) Distributor (2) Third party (3) Company’s subsidiary in Japan 34 2. Pharmaceutical Affairs Law (PAL) License to Marketing Authorization Holder (MAH) - Classification of the MAH Licenses (License for Marketing Authorization Holders) Article 12 Classification by PAL Class I Class II General MD Designated Controlled MD Class III Class IV Specially Controlled MD Type of Marketing Authorization Holders No. 3 Type 35 No. 2 Type No. 1 Type License for Marketing Business of Medical Devices 2. Pharmaceutical Affairs Law (PAL) License to Marketing Authorization Holder (MAH) - MAH has to be in Japan - Classification of the licenses (for MDs, type 1, 2 & 3) - MAH license renewal: every 5 years (PAL, Article 12, 2.) - Requirements for MAH (e.g. GQP - Good Quality Practice, GVP – Good Vigilance Practice) - Appointment of a MAH ‘Marketing Supervisor-General’ (responsible person for quality control and market surveillance). Qualification requirements of Marketing Supervisor-General : depending on the product category (MHLW Ordinance) 36 2. Pharmaceutical Affairs Law (PAL) License (Registration) for Manufacture ‘License for Manufacture’ is required for all production sites (also abroad, with the exception of component suppliers) Depending on the category of the license, the building and it‘s equipment are subject to different requirements. - Manufacture license categories: Type No. 1 ‘Animal Origin Devices’ (PAL, Article 43) Type No. 2 ‘Sterile Devices’ Type No. 3 ‘Other than No.1 and No.2(Other general devices) Type No. 4 ‘License for Labeling, Packaging and storage - Foreign manufacturers do not obtain a „manufacture license“ with other words: an „Accreditation“ of all production sites 37 2. Pharmaceutical Affairs Law (PAL) License (Registration) for Manufacture PAL: (License for Manufacture) Article 13 - The License has to be renewed every 5 years. - Building and equipment must comply with the standards given by MHLW Ordinance # 180 Article 13-2 Inspection and registration is done by Prefecture and PMDA (Pharmaceuticals and Medical Devices Agency). These organizations reserve the right to do an Inspection/Audit on-site. 38 2. Pharmaceutical Affairs Law (PAL) Requirements of License (Registration) for Manufacture - Inspection of Buildings and Facilities of Manufacturers: Building and equipment must comply with the standards given by MHLW Ordinance # 180 - Quality System Inspection (QMS Ordinance No.169) is required Category Domestic (License) Foreign Manufacturer (Accreditation) Radioactive PMDA PMDA Prefecture PMDA PMDA PMDA Prefecture PMDA IVD Others Medical Device 39 Cell/tissue derived Others 2. Pharmaceutical Affairs Law (PAL) Accreditation of Foreign Manufacturer by PMDA - A person intending to manufacture in a foreign country drugs or medical devices etc. that are imported to Japan may be accredited by the Minister as a foreign manufacturer. - Accreditation is granted for each site according to the categories. - Accreditation shall be renewed every 5 years. 40 2. Pharmaceutical Affairs Law (PAL) Product Approval Procedure under PAL - Approval (Shōnin) of Medical Device by PMDA - Certification (Ninshō) of Medical Device by RCB (Registered Certification Body ) 41 2. Pharmaceutical Affairs Law (PAL) Product Approval/Certification System Classification by PAL Class I Class II General MD (Designated) Controlled MD Product Certification no requirements by RCB Class III Class IV Specially Controlled MD Product Approval by MHLW (Application to PMDA) • RCB: Registered Certification Body - alltogether 14, out of that only 3 RCB accredited for all 400 product categories (> 700 products) • PMDA: Pharmaceuticals and Medical Devices Agency (Independent Agency of the MHLW) 42 2. Pharmaceutical Affairs Law (PAL) Certification Process by Third Party Certification (RCB) System Applicant MAH Post Market Requirement Conformity (GVP) Quality Assurance Item Conformity (GQP) Manufacturing Site (Manufacturer) • Certification Applicant • Evidence for Criteria Conformity •Self Declaration of Criteria Conformity ① Certification Application ④ Certification (Product) • On-Site / Doc Audit for conformity to ordinance 169. Confirm evidence related to criteria conformity as needed ③ On-Site or Doc Audit Facility Structure Criteria Mfg Control / Quality Control (GMP/QMS) 43 ⑤ Follow-up Audit (After Certification) • Follow-up Audit related to Ordinance 169(GMP/QMS) Conformity once a year Registered Certification Body ② Document Review Document evaluation based on individual conformity criteria of product Audit accordance with ISO IEC 17021 2. Pharmaceutical Affairs Law (PAL) License (Registration) for Manufacture Registration of the Production Site: Attachments: • Overview/technical drawings of the buildings and the equipment • Resumee of the management representative • List of the manufactured products • Manufacturing process • Copies of existing licenses, approval or certificates 44 Application: • Name of the manufacturer • Address • Registration category • Attachment for buildings and equipment • Name & private address of the management representative • Name & address of the applicant (could be foreign manufacturer or MAH) 2. Pharmaceutical Affairs Law (PAL) How to put your products on the Japanese market Product Approval/Certification Steps for Foreign Manufacturers 1. Appointment of the Appointed/Designated MAH (DMAH) in Japan 2. Accreditation of the production facility by PMDA 3. Application for product approval (via DMAH or directly) a) Class II: to RCB b) Class III, IV: to PMDA - RCB/PMDA reviews the product application documents and checks the QMS(GMP) compliance (on-site Audit or Document Review of manufacturing facilities) 45 2. Pharmaceutical Affairs Law (PAL) References Revision of the Pharmaceutical Affairs Regulations 2002 Edition by Pharmaceutical Affairs Study Group Yakuji Nippon Ltd. ISBN 4-8408-0726-4 The Pharmaceutical Affairs Law - New Regulations Effective in 2005 Edited by The Japan Federation of Medical Devices Associations Yakuji Nippon Ltd. (www.yakuji.co.jp/e/publications/ ) ISBN 4-8408-0773-6 46 3. Test and Certification for Telecommunication Products 47 3. Test and Certification for Telecommunication Products Regulatory Scheme in Japan Wired Products Telecommunication Business Law Radio Products Radio Law 48 3. Test and Certification for Telecommunication Products Certification Scheme in Japan Home Electric Pump etc. AC Adapter etc. DENAN Law (Safety) 49 Wired Products Telephone FAX PBX ISDN Terminal PC etc. Radio Products Cellular Phone Cordless Telephone Wireless LAN Telecommunication Business Law Bluetooth Wi-Fi ZigBee Low Power security etc. Radio Law 3. Test and Certification for Telecommunication Products Flow of Radio/Telecom Products Certification by CB and SDOC By CB ①Test Certification Investigation Test and Document By SDOC ②Type Approval Applicant CB Test and Document Judgment Judgment Product Certificate Type Approval Certificate Test and Document Verification Indication Design Conformity Design Conformity Bring to Market Data Preservation Indication MIC Data Preservation Pu blic atio n Effectiveness of Certification and Obligation 50 Preservation Indication Bring to Market 3. Test and Certification for Telecommunication Products Test Certificate and Type Approval 1) Test Certificate Every radio product will be tested and certified based on Radio Law. This scheme is applicable for sample radio products or field trial purpose. Each radio has to affix the unique certification number and certification mark on it. 2) Type Approval The certificate covers all products manufactured based on the designs or the types and one typical radio product will be tested based on Radio Law. Each radio product has to affix the certification number and mark on it. This scheme is applicable to the mass production product. 51 3. Test and Certification for Telecommunication Products Specific Radio Facility Group-1: 17 radio facilities (based on Radio Law 38-2-1) No Radio operation license required Cordless telephone, Low power security, 2.4GHz Data comm., 5GHz Data comm., PHS telephone, etc. Group-2: 31 radio facilities (based on Radio Law 38-2-2) Covered by Blanket license Cell Phone(PDC、CDMA、WCDMA, WiMAX)、5GHz Radio Access, Portable Earth Station, etc. Group-3: 75 radio facilities (based on Radio Law 38-2-3) Radio operation license required Digital Radio, F3E Radio, Cellular Base Station(PDC、CDMA、 WCDMA, WiMAX), PHS Base Station, 5GHz Radio Access Base Station, Several Radar systems, Several Earth Stations , etc. 52 3. Test and Certification for Telecommunication Products Specific Telecom Facility Chapter 3 Chapter 4 Chapter 5 Chapter 6 Chapter 7 53 Safety, etc. (Articles 4 through 9) Terminal Facilities to be Connected to Telephone Circuit Facilities Analog Telephone Terminals (Articles 10 through 16) Mobile Telephone Terminals (Articles 17 through 32) Terminal Facilities to be Connected to Radio Paging Circuit Facilities (Articles 33 and 34) Pager Terminal Facilities to be Connected to Integrated Services Digital Network (ISDN) Circuit Facilities (Articles 34-2 through 34-6) ISDN Terminal Adapter Terminal Facilities to be Connected to Private Circuit Facilities or Digital Data Transmission Facilities (Articles 34-7 and 34-8) 10BaseT/100Base-TX, ADSL, Packet data (mobile), HSDPA, EVDO, DOCSIS 2.0, etc 3. Test and Certification for Telecommunication Products Certification Mark and Number Radio R 005YAA0000 R: 005: YAA: 0000: Telecom AD01-0000 005 AD: 01: 0000: 005: 54 Radio CB number of TUV Rheinland Japan Type of radio equipment Serial number Type of telephone Year Serial number CB number of TUV Rheinland Japan 3. Test and Certification for Telecommunication Products Drawing of label (example) 20mm Bluetooth Mouse Diameter of Telecom Mark is specified, 2.4FH1 Manufactured by XXX company. R 005WWCAXXXX 12mm 5mm or more for the product volume being 100cc or more, 3mm or more for the product volume being less than 100cc. 55 3. Test and Certification for Telecommunication Products Extreme Low Power Device 56 3. Test and Certification for Telecommunication Products Radio Certification Body Accredited by MIC Name of CB Telecom Engineering Center Japan Armature Radio Association DSP Research Chemitox TUV Rheinland Japan RF Technplogy UL Japan Cosmos Corporation TUV SUD Ohtama Zacta Technology Corporation TELEFICATION B.V CETECOM ICT Services GmbH BABT Phoenix Testlab GmbH KTL EMCCert Dr. Rasek GmbH 57 Number 001 002 003 004 005 006 007 008 010 011 201 202 203 204 205 206 Group Group -1, -2, -3 in Radio Law 38-2-1 Group -1 in Radio Law 38-2-1 Group -1, -2, -3 in Radio Law 38-2-1 Group -1, -2, -3 in Radio Law 38-2-1 Group -1, -2, -3 in Radio Law 38-2-1 Group -1 in Radio Law 38-2-1 Group -1, -2, -3 in Radio Law 38-2-1 Group -1, -2, -3 in Radio Law 38-2-1 Group -1 in Radio Law 38-2-1 Group -1, -2, -3 in Radio Law 38-2-1 Group -1, -2, -3 in Radio Law 38-2-1 Group -1, -2, -3 in Radio Law 38-2-1 Group -1 in Radio Law 38-2-1 Group -1, -2, -3 in Radio Law 38-2-1 Group -1, -2, -3 in Radio Law 38-2-1 Group -1, -2, -3 in Radio Law 38-2-1 3. Test and Certification for Telecommunication Products Telecom Certification Body Accredited by MIC Name of CB Japan Approval Institute for Telecommunications Equipment DSP Research Chemitox TUV Rheinland Japan Cosmos Corporation TUV SUD Ohtama Zacta Technology Corporation TELEFICATION B.V CETECOM ICT Services GmbH BABT Phoenix Testlab GmbH KTL 58 Number 001 003 004 005 008 010 011 201 202 203 204 205 3. Test and Certification for Telecommunication Products Information Link related to Radio certificate Radio Law: http://law.e-gov.go.jp/htmldata/S25/S25HO131.html http://www.soumu.go.jp/main_sosiki/joho_tsusin/eng/Resources/la ws/radiolaw2003/RL-index.html Ordinance Regulating Radio Equipment: http://law.e-gov.go.jp/htmldata/S25/S25F30901000018.html http://www.tele.soumu.go.jp/resource/e/equ/tech/orre.pdf Ordinance concerning Technical Regulations Conformity Certification etc. of Specified Radio Equipment: http://law.e-gov.go.jp/htmldata/S56/S56F04001000037.html http://www.tele.soumu.go.jp/resource/e/equ/tech/octr.pdf 59 4. Supplemental explanation on Japanese regulations 60 Supplemental explanation on Japanese regulations (1/2) Although it depends on the product specifications, concerning the requirements of “Electrical Appliance and Material Safety Law (“DENAN” in Japanese abbreviation)”, “Pharmaceutical Affairs Law”, “Telecommunication Business Law” and “Radio Law”, the following present conditions must be taken into account: a) Under Radio Law, there are products to which approval by the Minister is required even if it is not categorized under radio products. Examples are microwave oven, induction cooking appliances, ultrasonic cleaners, ultrasonic processing machines, ultrasonic welders, etc. Some of these are also in the scope of DENAN although it depends on the specification. b) There are a number of products applicable to DENAN and “Pharmaceutical Affairs Law”. Examples are: electric inhalators (heater or motor operated), household heating therapeutic appliances, electric massagers (motor-operated), electric bubble generators for bathtubs (motor-operated), magnetic therapeutic apparatus, electric moxibustion appliances, household therapeutic ray apparatuses, household low frequency therapeutic apparatuses, household ultrasonic therapeutic apparatuses, household ultrashort wave therapeutic apparatuses, producers of medical materials, household electric-potential therapeutic apparatuses, etc. 61 Supplemental explanation on Japanese regulations (2/2) c) Transformers or DC power supply units which are used only for medical equipment and which are in the range specified by DENAN, are in the scope of DENAN but the “Pharmaceutical Affairs Law” does not apply. Detachable power cords are also treated in the same manner. d) Products subject to DENAN and with telecommunication and/or radio function, are also subject to the “Telecommunication Business Law” and/or “Radio Law” in addition to DENAN. For example: television receivers with modem function for telecommunication and/or radio communication function such as Bluetooth. 62