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ACB Japanese Radio Law – An Overview

Understand the regulations for radio equipment in Japan through translated documents, compliance requirements, and testing methods. Explore Extremely Low Power Regulation and rules for inductive RFID equipment.

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ACB Japanese Radio Law – An Overview

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  1. ACBJapanese Radio Law – An Overview Pieter Robben ACB Europe – 18 May 2017 LPRA Radio Solutions 2017

  2. Introduction • Radio Law (Law No. 131, 2 May 1950). • This document contains the general provisions and requirements for radio equipment intended for use in Japan.A tentative English translation may be found at:http://www.tele.soumu.go.jp/e/sys/equ/tech/index.htm#4000055

  3. Introduction • Ministerial Ordinance No. 37, November 21, 1981 (Rules Concerning Technical Regulations Conformity Certification of Specified Radio Equipment). • This document contains frequency use information and general requirements for the various types of radio equipment.A tentative English translation may be found at:http://www.tele.soumu.go.jp/e/sys/equ/tech/index.htm#4000055

  4. Introduction • Ordinance Regulating Radio Equipment (Radio Regulatory Commission Regulations No. 18, November 30, 1950). • This document contains the detailed technical requirements for the various types of radio equipment (comparable to a standard without the test methods or “interface specifications”).A tentative English translation may be found at:http://www.tele.soumu.go.jp/e/sys/equ/tech/index.htm#4000055

  5. Introduction • MIC Notice 88, January 26, 2004 (test methods and appendix to Post of the Ministerial Ordinance No. 37, November 21, 1981). • These documents contain the test methods for the various types of radio equipment.The original Japanese documents are available at:http://www.tele.soumu.go.jp/j/sys/equ/tech/type/index.htm

  6. Introduction • TTE equipment and radio equipment containing a TTE part must (also) comply with the requirements of the Telecommunications Business Law.A mix of Japanese documents and English translations relating to the Telecommunications Business Law may be found here:http://www.soumu.go.jp/main_sosiki/joho_tsusin/eng/laws_dt03.html

  7. Extremely low power regulation • Certain radio equipment does not need to be certified for use in Japan. The requirement is that all emissions of the radio equipment (including the fundamental) remain below the “extremely low power” regulation limits:http://www.tele.soumu.go.jp/e/ref/material/rule/index.htm • This regulation is mostly being used for RFID equipment and other (inductive) radio equipment operating below 30 MHz.

  8. Extremely low power regulation • “Extremely low power” radio equipment limits:

  9. Extremely low power regulation • Test procedure: Ministry of Posts and Telecommunications Notification No.: 127 (25 February 1988), of defining a method for measuring the field strength of the radio station to launch a remarkably weak radio. • Amended by Ministry of Internal Affairs and Communications Notification No.: 172 (28 March 2006). • Amended by Ministry of Internal Affairs and Communications Notification No.: 173 (28 March 2006).

  10. Extremely low power regulation • The limit as specified in the “extremely low power” regulation is, or looks, quite low. • However, the Ministry of Posts and Telecommunications Notification No.: 127 (25 February 1988), and its amendments, allows or requires the application of a correction factor to field strength levels measured up to 15 MHz. • The correction factor is defined as 24 – (20 * log (f)) dB, where f is the frequency in MHz. • This correction factor is essentially an attempt to convert field strength levels which have been measured, while using a loop antenna which has been calibrated for use in the far field region, to equivalent field strength values in the near field (since the measurement distance is defined as 3 meters).

  11. Extremely low power regulation

  12. Inductive RF-ID equipment • RFID 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 a registration at MIC in Japan must be obtained. • The registration/notification process at 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.

  13. Inductive RF-ID equipment • The following documents must be submitted to MIC: • An authorization letter (POA) must be submitted when the registration/notification at MIC is requested through an agent. • Application form (in Japanese) signed by the local representative in Japan. • Design document (Specified Form)_Specification for inductive reading and writing equipment (in Japanese). • Test report (in Japanese). • Label information. • Schematics. • Block diagram. • External and internal photographs. • Operational description. • User manual.

  14. Inductive RF-ID equipment • 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).

  15. Inductive RF-ID equipment

  16. Inductive RF-ID equipment • Labeling in case the device as a whole is registered/notified:

  17. Inductive RF-ID equipment • The major axis of Figure 1 in the previous slide must have a length of 2 cm or more. • If the device is too small, the alternate marking in Figure 2 in the previous slide can be used. The longest side of Figure 2 must be 5 mm or more. • The material of the marking must be durable. • The font, color and characters must be easily readable. • The marking must be firmly affixed to the device in a location where it can be easily recognized. • In Figure 1 in the previous slide the※ character must be replaced by the designated number when the confirmation of MIC is received.

  18. Inductive RF-ID equipment • Labeling in case a radio module is registered/notified is the same as when a device as a whole is registered notified. • However, the following text must be placed on the host system in which the module is being used:当該機器には電波法施行規則第46条の21項五に基づく誘導式読み書き通信設備：第※号を装着しているTranslation: This device contains the already notified Inductive reading and writing radio communication equipment module: Number ※(Note: replace ※with the number when the confirmation of MIC is received)

  19. 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.

  20. Equipment classes • 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 at:http://www.tele.soumu.go.jp/e/sys/equ/tech/techobj/index.htm

  21. Equipment classes for RF-ID • Radio Law, unlicensed device, Article 38-2-2.1.1 • Rules concerning technical regulations conformity certification of specified radio equipment, Article 2, Paragraph 1, Item 8, category code Y. • Ordinance Regulating Radio Equipment: • Article 5, frequency tolerance; • Article 6, occupied bandwidth; • Article 7, spurious and unwanted emission intensity; • Article 14, tolerance of antenna power; • Article 15, condition for frequency stabilization; • Article 24, secondary radiated emissions; • Article 9-4, interference prevention function. • Ordinance Regulating Radio Equipment, specific requirements Article 49-14. • Frequency range: 916.7 – 923.5 MHz. • Maximum allowable RF output power: 0.25 W (conducted).

  22. Equipment classes for RF-ID • Radio Law, unlicensed device, Article 38-2-2.1.1 • Rules concerning technical regulations conformity certification of specified radio equipment, Article 2, Paragraph 1, Item 8, category code Y. • Ordinance Regulating Radio Equipment: • Article 5, frequency tolerance; • Article 6, occupied bandwidth; • Article 7, spurious and unwanted emission intensity; • Article 14, tolerance of antenna power; • Article 15, condition for frequency stabilization; • Article 24, secondary radiated emissions; • Article 9-4, interference prevention function. • Ordinance Regulating Radio Equipment, specific requirements Article 49-14. • Frequency range: 2400 – 2483.5 MHz (FHSS). • Maximum allowable RF output power: 10 mW/MHz (conducted).

  23. Equipment classes for RF-ID • Radio Law, unlicensed device, Article 38-2-2.1.1 • Rules concerning technical regulations conformity certification of specified radio equipment, Article 2, Paragraph 1, Item 8, category code Y. • Ordinance Regulating Radio Equipment: • Article 5, frequency tolerance; • Article 6, occupied bandwidth; • Article 7, spurious and unwanted emission intensity; • Article 14, tolerance of antenna power; • Article 15, condition for frequency stabilization; • Article 24, secondary radiated emissions; • Article 9-4, interference prevention function. • Ordinance Regulating Radio Equipment, specific requirements Article 49-14. • Frequency range: 2427 – 2470.75 MHz (except FHSS). • Maximum allowable RF output power: 10 mW (conducted).

  24. Equipment classes for RF-ID • Radio Law, licensed device, Article 38-2-2.1.3 • Rules concerning technical regulations conformity certification of specified radio equipment, Article 2, Paragraph 1, Item 6, category code AS. • Ordinance Regulating Radio Equipment: • Article 5, frequency tolerance; • Article 6, occupied bandwidth; • Article 7, spurious and unwanted emission intensity; • Article 14, tolerance of antenna power; • Article 15, condition for frequency stabilization; • Article 24, secondary radiated emissions; • Ordinance Regulating Radio Equipment, specific requirements Article 49-9. • Frequency range: 916.7 – 920.9 MHz. • Maximum allowable RF output power: 1 W (conducted).

  25. Equipment classes for RF-ID • Radio Law, licensed device, Article 38-2-2.1.3 • Rules concerning technical regulations conformity certification of specified radio equipment, Article 2, Paragraph 1, Item 6, category code AS. • Ordinance Regulating Radio Equipment: • Article 5, frequency tolerance; • Article 6, occupied bandwidth; • Article 7, spurious and unwanted emission intensity; • Article 14, tolerance of antenna power; • Article 15, condition for frequency stabilization; • Article 24, secondary radiated emissions; • Ordinance Regulating Radio Equipment, specific requirements Article 49-9. • Frequency range: 2427 – 2470.75 MHz • Maximum allowable RF output power: 0.3 W (conducted).

  26. Equipment classes for RF-ID • Radio Law, licensed device, Article 38-2-2.1.3 • Rules concerning technical regulations conformity certification of specified radio equipment, Article 2, Paragraph 1, Item 6-2, category code BS. • Ordinance Regulating Radio Equipment: • Article 5, frequency tolerance; • Article 6, occupied bandwidth; • Article 7, spurious and unwanted emission intensity; • Article 14, tolerance of antenna power; • Article 15, condition for frequency stabilization; • Article 24, secondary radiated emissions; • Ordinance Regulating Radio Equipment, specific requirements Article 49-9. • Frequency range: 916.7 – 920.9 MHz. • Maximum allowable RF output power: 1 W (conducted). • Carrier sense function required.

  27. Equipment classes for RF-ID • Radio Law, licensed device, Article 38-2-2.1.3 • Rules concerning technical regulations conformity certification of specified radio equipment, Article 2, Paragraph 1, Item 6-3, category code CS. • Ordinance Regulating Radio Equipment: • Article 5, frequency tolerance; • Article 6, occupied bandwidth; • Article 7, spurious and unwanted emission intensity; • Article 14, tolerance of antenna power; • Article 15, condition for frequency stabilization; • Article 24, secondary radiated emissions; • Ordinance Regulating Radio Equipment, specific requirements Article 49-9. • Frequency range: 2427 – 2470.75 MHz • Maximum allowable RF output power: 0.3 W (conducted). • Carrier sense function required.

  28. Common technical requirements • Article 6: Occupied bandwidth (99% bandwidth). • Article 14: Tolerance on antenna power. • The applicant must state on the application form the “rated antenna power” (specification). • 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).

  29. Common technical requirements • 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.

  30. Common technical requirements • 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.

  31. Common technical requirements • 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.

  32. 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.

  33. Application documents • Application form. Note: this must be signed by the CEO of the company (applicant). • Appropriate “Technical Type Specification Form”Form 1: Land Mobile (PHS, DSRC, 50 GHz convenience radio, etc.); Form 2: Radio Navigation/Radio Location; Form 3: Specified Low Power Devices, CB, Cordless Phones, Special Low Power Radio, LP Security, LP Data, Digital Cordless Phone, Land Mobile station PHS, Land Mobile SDRC, 5 GHz Wireless Access, UWB etc.; Form 4: Amateur Radio and 27, 150, 400, 900 MHz; Form 5: Earth Station (fixed and portable).

  34. Application documents • Authorization letter or POA in case an agent submits the application. • Quality Management System Declaration and Letter of Quality Control Confirmation Method(with these letters the manufacturer 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). • ISO 9001 certificate(s) (must be provided for all involved companies such as applicant, manufacturer and factory when available).

  35. Application documents • 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 or balun, RF switch IC. Any component which is included underneath a fixed shield (no removable cover) has no need to be glued.

  36. Application documents • Label information. Label information should include label drawing, label location, material of the label, color of the text and background, material of the glue used to affix the label, and size of the label. • Schematics/circuit diagram (for the whole device). • Block diagram of the whole device. • PCB layout and silk screen drawings. • Exterior photographs of all sides of the devices, including an indication of the dimensions.

  37. Application documents • Interior photographs of the device, including an indication of the dimensions. Both sides of the PCB must be show. Pictures of the PCB with and without shielding (where applicable) must be submitted. • Bill of materials / parts list of the whole device. • Test setup photographs. • Users manual. • Operational description. • Antenna information (must include the radiation patterns, peak gain information, opening angle, photographs and dimensions).

  38. Application documents • 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.

  39. 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.

  40. Labeling of radio equipment • 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.

  41. Labeling of radio equipment • The full certification marking looks like this:

  42. Labeling of radio equipment • 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 certification number has the following format:

  43. Labeling of radio equipment • The following is stipulated in the ordinance concerning GITEKI marks (enforced on September 1, 2014). • This ordinance revises any previously required labeling formats.

  44. Labeling of radio equipment • Original regulation regarding the GITEKI mark: • Display in a conspicuous place on certain wireless equipment that received certification; • 5 mm or larger in diameter; • 3 mm or larger in diameter for wireless equipment with a volume of 100 cc or less; • As for certain wireless equipment implanted or temporarily retained in persons (specific low-power wireless stations), display marks in the user manuals and in a conspicuous place on packages or containers.

  45. Labeling of radio equipment • Revised regulation regarding the GITEKI mark: • Display in a conspicuous place on certain wireless equipment that received certification; • 3 mm or larger in diameter; • As for certain wireless equipment implanted or temporarily retained in persons and certain wireless equipment where sufficient space may not be secured to attach labels of 3 mm or larger in diameter, display labels in the user manual and in a conspicuous place on packages or containers.

  46. Labeling of radio equipment • Added note to the revised regulation regarding the GITEKI mark:“where sufficient space may not be secured to attach labels of 3 mm or larger in diameter, display labels in the user manual and in a conspicuous place on packages or containers”This may also be interpreted as:“where sufficient space may not be secured, or where it is unreasonable, to attach labels of 3 mm or larger in diameter, display labels in the user manual and in a conspicuous place on packages or containers”

  47. Labeling of radio equipment • For TTE equipment the same labeling as in the previous slide 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).

  48. 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.

  49. Modular approval • 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 close 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 R-certificate and certification number is then required to be issued for the combination of host product and radio module(s).

  50. Modular approval • 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 R-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.

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