LED lighting in Japan lacks standards

The Japanese government and the industry are actively promoting the popularization of LED lighting . At present, LED lighting in Japan is not yet applicable to PSE, and safety is mainly confirmed by self-certification by enterprises. The Ministry of Economy, Trade and Industry of Japan is considering including LED lighting in the applicable scope of PSE.

Among LED lighting products, the supply of LED bulbs in Japan was very small as of 2008, but statistics from the Japan Light Bulb Industry Association show that it has rapidly increased to about 4 million units by 2009. The supply of LED lighting fixtures reached 1.27 million units in December 2009, and has been recognized by ordinary consumers as a substitute for incandescent bulbs.

Various industries and enterprises in Japan have actively promoted the advantages of LED lighting products in terms of environmental protection and energy saving over existing lighting products through means such as television advertisements. The Japanese government has also implemented the "Green Home Appliances Environmental Points Promotion Business" since April 2010, which allows users to purchase LED bulbs at half price using environmental points. For ordinary consumers, LED lighting products, mainly LED bulbs, have begun to become a part of their lives (Note 1).

Note 1) In addition to promoting the popularization of general consumers, the Japanese government has also implemented measures to "promote the establishment of low-carbon industries in the country" for companies. It supports environmentally friendly and energy-saving industries such as lithium-ion rechargeable batteries and LED lighting that have the most advanced technology and are expected to grow in the future, and attempts to create green jobs.

The Electrical Appliance and Material Safety Law (PSE) is not applicable

However, the more LED lighting products enter people's lives, the more prominent a problem becomes. The Electrical Appliances and Materials Safety Law does not apply to LED lighting. In addition, with the continuous influx of new companies entering the LED lighting field, there is also a phenomenon of directly selling LED lighting products without knowledge of the Electrical Appliances and Materials Safety Law. These companies should understand that even if LED lighting is not subject to the Electrical Appliances and Materials Safety Law, when a major product accident occurs during consumer use, the company will still be held accountable under the Consumer Product Safety Law and the Product Liability Law (PL Law) in Japan.

LED bulbs, which are now being widely popularized and gradually entering ordinary household life, and fluorescent LEDs introduced by public institutions, factories and convenience stores, are not subject to the Electrical Appliances and Materials Safety Law. Therefore, there are no legal regulations on the safety of LED bulbs and fluorescent LEDs, and each company that sells the products guarantees it. As a result, the existing lighting products used by ordinary households and companies are printed with the "PSE mark" indicating that they meet the requirements of the Electrical Appliances and Materials Safety Law, but the LED bulbs that are currently being sold and can be seen everywhere in home appliance stores do not have the PSE mark printed on them.

Figure 1: LED bulbs with the S certification mark

Since safety has been confirmed, LED bulbs that have passed the compliance test at the Electrical Safety and Environmental Research Institute are marked with the S-JET certification mark.

Replaced by S-mark safety certification

The Electrical Appliances and Materials Safety Act originally refers to a law that defines the safety guarantee of electrical appliances. The purpose of this law is to prevent danger and damage from electrical appliances by promoting private enterprises to independently carry out activities related to the safety of electrical appliances while regulating the manufacture and sale of electrical appliances.

However, since the Electrical Appliances and Materials Safety Law does not apply to LED lighting products, the current problem is not that they "do not carry" the PSE mark, but that they "cannot carry" the PSE mark. Therefore, LED bulbs sold by large companies such as Panasonic, Toshiba Lighting Technology, and Sharp are printed with the "S Mark Certification" (Figure 1) that has passed the safety certification system of private third-party organizations such as the Japan Electrical Safety and Environment Research Institute (hereinafter referred to as JET).

However, the "S Mark Certification" has not been passed as a law. According to JET's website, the S Mark Certification has the following characteristics:

1. Provide services for customers who want to obtain safety confirmation and certification for electrical products, etc.
2. In addition to the safety guarantee of manufacturers, etc., by marking the S-JET certification mark, it is objectively and impartially proved that the product meets the test standards.
3. Products marked with the S-JET mark are certified by a third-party organization to meet the test standards, etc., which enhances consumers' trust.

What is the difference between existing lighting and LED lighting?

Although LED bulbs and fluorescent lamps are used to replace existing bulbs and fluorescent lamps, why are they not included in the applicable objects of the PSE mark? This is because the light source LED chip in LED bulbs and fluorescent lamps has a different lighting principle and structure from incandescent lamps and fluorescent lamps, and is not currently designated as a regulated object by the Electrical Appliances and Materials Safety Law, so it cannot be marked with the PSE mark.

The Ministry of Economy, Trade and Industry of Japan also admitted: "The Electrical Appliances and Materials Safety Law specifies the objects of regulation based on each product, so sometimes additional regulations have to be added after new products are launched on the market."

Currently only third-party certification is used to confirm safety

JET, the certification body for the PSE mark and the S mark, believes that even if LED lighting products are not subject to the Electrical Appliances and Materials Safety Act, product suppliers also need to conduct 'safety confirmation'. Therefore, according to the safety standards set by JET, through the "S-JET certification service" and "commissioned testing service", the implementation of compliance with the standards has begun. In addition to the compliance confirmation of this certification body, large Japanese companies also conduct tests within their own companies based on the technical standards of the Electrical Appliances and Materials Safety Act, and supply the market after confirming safety.

As mentioned above, Panasonic, Toshiba Lighting Technology, and Sharp have marked the "S Mark Certification" on their LED bulbs. However, it should be noted that the S Mark Certification is only a certification conducted by a private third-party certification agency (Table 1).

Incorrect PSE mark markings and misleading statements

LED lighting products are being promoted without relevant standards and regulations, so some people are worried that poor quality products will appear due to misunderstanding. In this case, the image of LED lighting products that have finally gained "citizenship" will be greatly damaged, and even the market will be lost.

Due to a misunderstanding of safety certification, some companies operating LED lighting products have posted product descriptions on their websites that are likely to cause misunderstanding among consumers.

Here are two examples.

Case 1

——As a characteristic of the product, emphasize "with PSE mark" or "has obtained PSE certification".

—— Claiming that LED lighting products (in this case, fluorescent lamp-type LEDs) can be directly installed on lighting fixtures that use glow starter-type and quick-start fluorescent lamps.

Case 2

——Claims to be the first in the industry to obtain the PSE mark.

——The process of obtaining the PSE mark was explained as, "Although it is an LED fluorescent lamp that is not subject to PSE , we have started work to obtain the PSE mark. (Omitted) It has been proven to be highly safe by a third-party organization."

As mentioned above, there are many companies that say "PSE mark has been obtained" on their websites. If you look closely at the content, you will find that the PSE mark is not actually marked on the entire LED lighting product. The PSE mark is only marked on the "DC power supply device" included in the electrical appliances specified in the Electrical Appliances and Materials Safety Act. It does not refer to the entire lamp. In addition, there is a problem with the description method. The PSE mark is a marking obligation, and it is wrong to describe it as "obtained".

Some companies are also taking advantage of legal loopholes

For the description of "having obtained the PSE mark" made under misunderstanding, the buyer can only judge whether the company has knowledge of electrical appliances and whether it has misinterpreted the Electrical Appliance Safety Law after fully understanding the content. The consequences become the buyer's own responsibility.

Regarding the marking obligation of the PSE mark, part of the "Marking" in Article 10 of the Electrical Appliances and Materials Safety Act states: When the reporting enterprise has fulfilled the obligations of ② and ③, it may use the provincial order to mark the corresponding electrical appliances in the manner prescribed. Except for the above circumstances, no one is allowed to mark these marks or marks that are confusing with them on electrical appliances. As mentioned above, LED bulbs and fluorescent lamp-type LEDs are not regulated in the Electrical Appliances and Materials Safety Act. If the PSE mark is marked on LED lighting equipment, it is likely to be considered an illegal act.

Figure 2: PSE Mark Designated electrical appliances are marked with PSE within a circle, while electrical appliances not designated as such are marked with PSE within a circle.

However, some companies that have marked the PSE mark have claimed that it is not illegal to mark LED lighting products, arguing that they are not "electrical appliances" as stated in Article 10 of the Electrical Appliances and Materials Safety Law. These companies have not been punished, so they have been calmly marking the PSE mark. Therefore, there are indeed companies that misinterpret the law and exploit loopholes in the legal provisions. For this reason, the Ministry of Economy, Trade and Industry of Japan has asked these companies to correct the content of their advertisements.

Only the DC power supply unit is marked with the PSE mark

Under the current mechanism, the only part of LED lighting products that can be labeled with the PSE mark is the DC power supply device that supplies power to the LED chip. Therefore, if the PSE mark is only applied to the power supply, there is no problem. Note 2). The DC power supply device (AC adapter) is a bundled accessory, so it is a PSE target item when viewed separately.

Note 2) Here, the PSE mark is described as "marking" rather than "obtaining". Because it is a legal obligation to mark, it should not be described as "obtaining".

When the power supply is sold separately, it must be inspected by a registered inspection agency as a designated electrical appliance according to the law. If it passes the inspection, the PSE mark is marked inside the ◇ mark. The Ministry of Economy, Trade and Industry of Japan reminds that if this regulation is violated, it will be punished (Figure 2).

The Ministry of Economy, Trade and Industry of Japan has explained the non-regulated items of the Electrical Appliances and Materials Safety Act: Electrical appliances and materials subject to the Electrical Appliances and Materials Safety Act are electrical products that are plugged into an outlet in a normal household and are specified by the law. Although AC adapters are specified as electrical appliances and materials, products that receive DC power supply through the AC adapters are not regulated items.

Therefore, when a company currently operating LED lighting products displays the PSE mark and explains the product safety, it can be regarded as the sales company explaining to the purchaser that the PSE mark is only marked on the power supply (AC adapter).

Japan's Ministry of Economy, Trade and Industry takes full action

In order to deal with the above situation of LED lighting products, the Ministry of Economy, Trade and Industry of Japan stated that "electrical appliances that are not designated as electrical appliances will be subject to new regulations, and the provincial order will be revised to prevent accidents before they happen." It is scheduled to revise the government and provincial order in fiscal 2010. The scope of regulations related to lighting products has been basically determined in May 2010: "In addition to LED lighting, new generation lighting including organic EL lighting and other light bulb-type lamps and lighting fixtures with electronic light emitters will be targeted" (Ministry of Economy, Trade and Industry of Japan). It is scheduled to be implemented in fiscal 2011 after the announcement. Large enterprises have begun to prepare secretly in order to meet the requirements immediately after the announcement.

Although the products specified are "electroluminescent tubes" and "other electroluminescent lighting fixtures", the specific provisions are still being formulated, so these names are only tentative. Among them, "electroluminescent tubes" list LED bulbs as the target, while "other electroluminescent lighting fixtures" list ceiling embedded LED lighting fixtures, ceiling embedded LED lighting used for basic lighting, and organic EDL lighting that uses the entire ceiling surface for lighting.

In terms of the outline of technical standards, the technical standards common to existing electrical products are used. On this basis, the ministerial ordinance on technical standards is revised and added with regard to individual requirements for LED lighting (Table 2).

The establishment of the PSE system is conducive to the development of the LED lighting industry

LED lighting is a product in the transition period, and the law related to the PSE mark has not been established. Therefore, there are still problems in the way companies explain their products, and there is confusion in the interpretation of the PSE mark. In order to continue to develop this industry in the future, it is important for each company to fully consider "safety".

In Japan, the Ministry of Economy, Trade and Industry is working hard to include standards related to LED lighting products in the scope of the Electrical Appliances and Materials Safety Law, and countries around the world are also formulating standards and regulations related to LEDs. By establishing a system that allows consumers to purchase and use LED lighting products with confidence, the LED lighting industry is expected to achieve greater development.