Resent without pdf attachments.
Bob Heller
3M EMC Laboratory, 76-1-01
St. Paul, MN 55107-1208
Tel: 651- 778-6336
Fax: 651-778-6252
=========================
----- Forwarded by Robert E. Heller/US-Corporate/3M/US on 05/05/2007 07:48
AM -----
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Subject: Fw: MRA with Japan
This is the response that I received from NIST and the FCC. If you have
concerns I would email/call Mary Jo and/or George as I will be doing.
Bob Heller
3M EMC Laboratory, 76-1-01
St. Paul, MN 55107-1208
Tel: 651- 778-6336
Fax: 651-778-6252
=======================================
====================================================
----- Forwarded by Robert E. Heller/US-Corporate/3M/US on 05/05/2007 07:39
AM -----
Mary Jo
DiBernardo
<maryjo.dibernard To
[email protected]> [email protected]
[email protected]
05/04/2007 11:43 cc
AM [email protected]
[email protected]
[email protected]
Subject
Fwd: RE: Re: MRA with Japan
George, thank you for the thorough explanation.
Bob, please see the response below and respond as appropriate.
Thanks,
Mary Jo
>Subject: RE: Re: MRA with Japan
>Date: Fri, 4 May 2007 09:27:08 -0400
>From: "George Tannahill" <[email protected]>
>To: "Mary Jo DiBernardo" <[email protected]>
>Cc: "William Hurst" <[email protected]>
>
>Hi Mary Jo,
>Information Technology (IT) equipment can be either an unintentional
>radiator or ISM equipment is regulated by VCCI. Articles 3 and 4 of the
>attached presentation titled "VCCI Rules for Voluntary Control Measures
>Revised April 1, 2007.pdf provide some additional guidance as to what is
>included. Also attached are two slides from Japanese presentations that
>show sketches of the process. As for specific examples: VCCI is
>responsible for computers and peripherals which are unintentional
>radiators. Japans "Radio Law" which is covered by the MRA has
>requirements for Telephone Terminal Equipment which can be an
>unintentional radiator. With regard to ISM devices, Consumer ISM,
>non-consumer ISM and ultrasonic equipment is regulated by Japan's "Radio
>Law" which is covered by the MRA.
>
>As the previous VCCI process was explained to me, even though the process
>was called "voluntary", a product could not be marketed in Japan without
>VCCI approval because the consumers would not purchase the product without
>the VCCI approval. The previous process to register with VCCI required a
>US test firm to be evaluated by VCCI and pay a fee for the evaluation, the
>registration and an annual fee before being able to test and submit test
>reports to VCCI for equipment that was to be marketed in Japan.
>
>In the new process a US test firm who is accredited to ISO 17025 to VCCI
>standards by a recognized accreditation body only has to register with
>VCCI. There is no evaluation or registration fee but there is an annual
>fee. Once registered and the annual fee is paid a US test firm may test
>and submit test reports to VCCI for equipment that is marketed in Japan.
>
>If 3M has specific examples where the above processes work differently and
>the US "lost out", we can review them and bring them up with Japan.
>George
>
>
>
> >Date: Thu, 03 May 2007 12:22:12 -0400
> >To: [email protected]
> >From: Mary Jo DiBernardo <[email protected]>
> >Subject: Re: MRA with Japan
> >
> >Bob, I don't have a copy on hand of the VCCI Rules, which were updated
> >effective April 1. Article 4 defines IT Equipment. Does the VCCI
> >definition of ITE include unintentional radiators? Please let me know.
> >
> >Thanks,
> >Mary Jo
> >
> >At 11:57 AM 5/3/2007, you wrote:
> >>Mary Jo, thank you for your response.
> >>
> >>The VCCI answer to Ms. Broadbent's letter seems to say that in order
> >>for US test results to be accepted by Japan (VCCI), the US testing
> >>laboratories must join the VCCI and pay dues and the US test
> >>laboratories must submit their test results to VCCI for approval
> >>(items numbered 3 and 4 in the VCCI response). These were not required
>
> >>prior to the exchange of letters and the VCCI letter now makes it more
>
> >>difficult to get US test results accepted by Japan.
> >>
> >>Best regards,
> >>Bob Heller
> >>3M EMC Laboratory, 76-1-01
> >>St. Paul, MN 55107-1208
> >>Tel: 651- 778-6336
> >>Fax: 651-778-6252
> >>======================================================================
> >>================
> >>
> >>
> >>
> >>
> >> Mary Jo
> >> DiBernardo
> >> <maryjo.dibernard
>To
> >> [email protected]> [email protected]
> >>
>cc
> >> 05/03/2007 10:32 [email protected]
> >> AM [email protected]
> >> [email protected]
> >> [email protected]
> >>
>Subject
> >> Re: MRA with Japan
> >>
> >>
> >>
> >>
> >>
> >>
> >>
> >>
> >>
> >>
> >>Dear Bob,
> >>
> >>Thanks for your message. The letters that were exchanged between the
>U.S.
> >>and Japanese Governments are posted on the NIST web site at
> >>http://ts.nist.gov/Standards/Global/mra_rebuild_japan.cfm. Please note
>
> >>that this arrangement is for mutual acceptance of test reports and is
> >>separate and different from the MRA for product certification, which
> >>has not yet been implemented.
> >>
> >>The letter from U.S. Trade Representative Broadbent to Japanese
> >>Minister Yokoi specifically states that neither Unintentional
> >>Radiators (with the exception of IT Equipment) nor ISM Equipment are
> >>subject to VCCI requirements for EMC.
> >>
> >>In the United States, assuming all other requirements of the
> >>arrangement are met, the FCC will accept a DoC from a Japanese test
> >>lab with respect to
> >>
> >>Unintentional Radiators and ISM Equipment for EMC.
> >>
> >>Does this satisfy your question?
> >>
> >>Best regards,
> >>Mary Jo
> >>
> >>At 06:57 AM 5/1/2007, you wrote:
> >>
> >> >Maryjo, it appears that the MRA with Japan has placed a barrier to
> >> >trade regarding EMC test reports for unintentional radiators. If I
> >> >am correctly reading the letter from Japan regarding unintentional
> >> >radiators,
> >>accredited
> >> >test houses in the US will now have to join the VCCI in order to get
>
> >> >their test results accepted. This was not the case before the MRA.
> >> >Prior to the MRA, joining the VCCI was always an option but not
> >> >necessary. Why have we apparently "lost out" due to the MRA?
> >> >
> >> >Best regards,
> >> >Bob Heller
> >> >3M EMC Laboratory, 76-1-01
> >> >St. Paul, MN 55107-1208
> >> >Tel: 651- 778-6336
> >> >Fax: 651-778-6252
> >>
> >>Mary Jo DiBernardo
> >>National Institute of Standards and Technology 100 Bureau Drive, Mail
> >>Stop 2150 Gaithersburg, MD 20899-2150
> >>Tel: 301/975-5503
> >>[email protected]
> >
(See attached file: VCCI Update March 12 2007.pdf)(See attached file: VCCI
Rules for Voluntary Control Measure Revised April 1 2007.pdf)(See attached
file: Japan Procedures for IT Equipment.pdf)[attachment "VCCI Update March
12 2007.pdf" deleted by Robert E. Heller/US-Corporate/3M/US] [attachment
"VCCI Rules for Voluntary Control Measure Revised April 1 2007.pdf" deleted
by Robert E. Heller/US-Corporate/3M/US] [attachment "Japan Procedures for
IT Equipment.pdf" deleted by Robert E. Heller/US-Corporate/3M/US]
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