CROSS-STANDARD public interest · LED luminaire
China-to-Japan LED Luminaire Compliance Gap Matrix
AI-compiled from official public sources — cross-checked by multiple AI models, not human-verified. Informational only; see disclaimer. Public-interest, source-linked comparison of common China LED luminaire documentation against Japan's DENAN (Electrical Appliances and Materials Safety Act) PSE marking (diamond / round), JIS C 8105 / JIS C 8155 luminaire standards, the Top Runner Program for LED energy efficiency, J-Moss (JIS C 0950) hazardous-substance marking, and VCCI EMC requirements versus Chinese GB standards and CCC certification.
Dataset 2026-06-11
Last verified 2026-06-15
11 rows
GAP MATRIX
Compliance Gap Matrix
| Compliance item | Common China baseline | Japan (PSE/JET) | Gap / action | Source + verification date |
|---|---|---|---|---|
| Top Runner Minimum Energy Efficiency for LED Lamps and Luminaires | China's equivalent is GB 30255-2019 (Energy efficiency requirements for LED room luminaires). It defines three energy efficiency grades: Grade 1 (highest): ≥90 lm/W; Grade 2: ≥80 lm/W; Grade 3: ≥70 lm/W. Grade 3 is the minimum required for market entry in China. The China Energy Label (CEL) registration is mandatory for GB 30255-covered products; labels are administered by SAMR. GB 30255 does not comprehensively cover power factor, CRI minimums, or lifetime requirements in the same binding way as the EU Ecodesign Regulation.GB 30255-2019 — Energy efficiency requirements for LED room luminaires (SAC/SAMR) | Japan regulates LED lamp and luminaire energy efficiency through the Top Runner Program under the Act on the Rational Use of Energy (Energy Conservation Act), administered by METI. LED lamps and LED luminaires are designated Top Runner product categories, each with a target fiscal-year (target standard value) by which the sales-weighted average efficacy (lm/W) of a manufacturer's or importer's shipments must meet or exceed a category benchmark. The benchmark efficacy is grouped by product type (e.g. bulb-shaped LED lamps, straight-tube LED lamps, ceiling luminaires) and is generally demanding — typical target values for LED products sit in the ~100 lm/W and above range depending on category (verify the exact target value table for the specific product type in the current METI Top Runner notice). The obligation is a fleet-average obligation on the business operator, enforced by reporting, recommendation, public disclosure, and ultimately order/penalty for non-compliant operators. The 統一省エネルギーラベル (Uniform Energy-Saving Label) and 多段階評価 (multi-stage star rating) are used to communicate efficiency to consumers.Act on the Rational Use of Energy (Energy Conservation Act) — Top Runner Program for LED lamps and LED luminaires (METI) METI Top Runner target standard value notices for LED lamps / luminaires (target fiscal-year benchmark efficacy by product category) |
Japan's Top Runner benchmark efficacy for LED products is generally high (commonly around or above ~100 lm/W depending on category), which is more demanding than China's GB 30255 Grade 3 (≥70 lm/W) and may also exceed Grade 2 (≥80 lm/W). A more fundamental structural gap: China's GB 30255 is a per-unit pass/fail grade applied at market entry, whereas Japan's Top Runner is a sales-weighted fleet-average obligation on the manufacturer/importer measured against a target fiscal-year — there is no per-unit certificate; compliance is assessed across the operator's whole shipment mix and reported to METI. A Chinese product meeting only CN Grade 3 would drag down a Japanese importer's fleet average and is unlikely to be acceptable in a competitive Top Runner category. Manufacturers must verify the exact target value table for the specific product category (bulb-shaped, straight-tube, ceiling luminaire, etc.) in the current METI Top Runner notice, and the importer must factor the product into its Top Runner reporting and labelling (統一省エネルギーラベル).[INFORMATIONAL] Japan's Top Runner Program sets demanding category benchmark efficacy (commonly around or above ~100 lm/W depending on product type) for LED lamps and luminaires as a sales-weighted fleet-average obligation on the manufacturer/importer, not a per-unit pass/fail like China's GB 30255. Chinese Grade 3 products (≥70 lm/W) are unlikely to be acceptable and may even fall short of Grade 2 levels. Verify the exact target standard value for the specific product category in the current METI Top Runner notice, and ensure the importer accounts for the product in Top Runner reporting and the Uniform Energy-Saving Label before market entry. | METI / Agency for Natural Resources and Energy (Top Runner Program)2026-06-15 · reference |
| Uniform Energy-Saving Label and Multi-Stage Star Rating for LED Products | China's China Energy Label (CEL) under GB 30255-2019 is mandatory for LED room luminaires. Products must be registered with the CQC (China Quality Certification Centre) or CECP (China Energy Conservation Programme) before affixing the CEL. The CEL shows Grade 1–3 based on absolute lm/W thresholds. There is no mutual recognition between the EU EPREL registry and the CN CEL registration scheme.GB 30255-2019 — Energy efficiency requirements for LED room luminaires (SAC/SAMR) China Energy Label (CEL) scheme — administered by SAMR/CQC/CECP |
Under Japan's energy-labelling framework administered by METI, LED lamps and luminaires that are Top Runner designated products are subject to the 統一省エネルギーラベル (Uniform Energy-Saving Label) and the 多段階評価制度 (Multi-Stage Rating System), which assigns a star rating (e.g. 1.0 to 5.0 stars) reflecting how the product performs relative to the Top Runner target standard value, together with estimated annual energy cost. Scope note: the labelling obligation is tied to designation as a Top Runner product, so it attaches to the LED lamp / luminaire as the regulated unit; for an integrated luminaire the whole product is the labelled unit, while for replaceable-lamp systems the lamp itself is generally the labelled product — verify the product configuration and the relevant METI notice for which unit bears the label. Retailers are expected to display the label at point of sale and in catalogues. There is no national online registry equivalent to the EU EPREL database; the obligation is delivered through the standardised label format and retailer display rather than a central product-registration database.Act on the Rational Use of Energy (Energy Conservation Act) — Uniform Energy-Saving Label and Multi-Stage Rating System for designated products (METI) | Japan's Uniform Energy-Saving Label expresses performance as a star rating relative to the Top Runner target standard value plus estimated annual running cost, whereas the CN CEL uses absolute lm/W Grade 1–3 thresholds — the two are calculated differently and a product's CN grade does not determine its Japanese star rating. Unlike the CN CEL, the Japanese label does not require pre-market registration with a central body (there is no EPREL-style registry); instead the standardised label is generated against the Top Runner target and displayed at retail. Both schemes are non-mutual: a CN CEL registration does not satisfy the Japanese labelling obligation, and the Japanese star rating must be derived from the applicable Top Runner category benchmark. The importer/retailer in Japan bears the practical display obligation, so a Chinese manufacturer must supply efficacy data sufficient for the Japanese label to be produced for the relevant product category.[INFORMATIONAL] Japan's Uniform Energy-Saving Label and Multi-Stage star rating are mandatory for Top Runner designated LED lamps and luminaires under the Energy Conservation Act. Scope clarification: the label attaches to the regulated unit — for an integrated luminaire the whole product, for replaceable-lamp systems generally the lamp itself; verify the product configuration and the relevant METI notice. Unlike China's CEL there is no central pre-market registry (no EPREL equivalent); the standardised label is derived against the Top Runner target and displayed at retail. Chinese CEL registration does not substitute for the Japanese label, and the star-rating basis (relative to Top Runner target) and the lm/W-based CN grade cannot be directly cross-mapped. Supply Japanese importers with efficacy data sufficient to generate the correct label for the product category. | METI / Agency for Natural Resources and Energy (Uniform Energy-Saving Label)2026-06-15 · reference |
| EMC Emissions — VCCI / CISPR 15 for Lighting Equipment | China's equivalent is GB 17743-2017 (Limits and methods of measurement of radio disturbance characteristics of electrical lighting and similar equipment), which is technically aligned with CISPR 15. For luminaires sold in China, GB 17743 compliance is required as part of CCC certification (which covers both safety and EMC for relevant product categories). Testing must be conducted at CNAS/CMA-accredited laboratories in China. Chinese CCC EMC test reports are not accepted under the EU EMC Directive conformity assessment pathway.GB 17743-2017 — Limits and methods of measurement of radio disturbance characteristics of electrical lighting and similar equipment (SAC/SAMR, aligned with CISPR 15) | Electromagnetic emissions of LED luminaires sold in Japan are addressed primarily through the VCCI (Voluntary Control Council for Interference by Information Technology Equipment) framework and the associated JIS adoption of CISPR 15. VCCI membership and conformity is a voluntary, industry-administered self-regulatory scheme: the manufacturer or importer tests the product against the applicable CISPR-derived limits, registers/declares conformity to VCCI, and may apply the VCCI mark. The applicable Japanese standard for lighting radio disturbance is the JIS C 8147 / JIS adoption aligned with CISPR 15, covering conducted disturbance on mains terminals (150 kHz–30 MHz) and radiated disturbance (30 MHz–300 MHz). Note that for the lighting product category Japan does not impose a single mandatory pre-market EMC law equivalent to the EU EMC Directive — VCCI is voluntary — but compliance is a strong market expectation and is effectively required by major retailers and distributors. Separately, if the luminaire incorporates radio (Wi-Fi / Bluetooth), the Radio Act and MIC Giteki (技適) certification apply and are mandatory.VCCI (Voluntary Control Council for Interference) — voluntary EMC self-regulatory scheme, CISPR-based limits JIS C 8147 series / JIS adoption of CISPR 15 — radio disturbance characteristics of electrical lighting equipment Radio Act and MIC Giteki (技適) certification — mandatory for luminaires incorporating radio (Wi-Fi / Bluetooth) |
Japan's VCCI lighting EMC limits and China's GB 17743 are both CISPR 15-derived, so emission limits are largely harmonized at the technical level. Key gaps: (1) the legal structure differs — in China GB 17743 EMC is folded into mandatory CCC, whereas in Japan EMC for lighting is delivered through the voluntary VCCI self-regulatory scheme rather than a mandatory pre-market EMC law for this product category, so the conformity route and documentation differ; (2) a Chinese CCC EMC report is not automatically accepted for VCCI declaration — VCCI conformity is registered through the VCCI scheme and the test data must support the CISPR-based VCCI limits; (3) testing for VCCI should be performed to a VCCI-recognised method/lab, although CNAS/ILAC-accredited data may be usable as supporting evidence — confirm acceptance with the VCCI scheme; (4) if the luminaire is wireless-enabled, the mandatory Radio Act / Giteki (技適) certification is an additional, separate obligation with no counterpart in a basic CCC EMC report.[INFORMATIONAL] EMC emissions for LED luminaires in Japan are addressed mainly through the voluntary VCCI self-regulatory scheme and the JIS adoption of CISPR 15, not a single mandatory pre-market EMC law for this product category. Emission limits are broadly harmonized with CN GB 17743 (both CISPR 15-derived), but a Chinese CCC EMC report is not automatically accepted for VCCI — conformity must be registered through the VCCI scheme. VCCI compliance is voluntary in law but effectively expected by Japanese retailers. Smart luminaires with wireless functions additionally require mandatory Radio Act / MIC Giteki (技適) certification. | VCCI Council (Voluntary Control Council for Interference by Information Technology Equipment)2026-06-15 · reference |
| EMC Immunity — JIS C 61547 / IEC 61547 (Lighting Equipment Immunity) | China's equivalent is GB/T 18595-2014 (General requirements for the electromagnetic immunity of lighting equipment), which is technically equivalent to IEC 61547:2009. GB/T 18595 is a recommended standard (T = tuijian, recommended) and is less strictly enforced than the CN emissions standard GB 17743. CCC certification for CN luminaires generally focuses more on safety and emissions than immunity. Passing EN 61547 immunity testing typically demonstrates performance beyond the requirements typically enforced in the CN market.GB/T 18595-2014 — General requirements for the electromagnetic immunity of lighting equipment (SAC/SAMR — recommended standard, aligned with IEC 61547:2009) | Japan addresses lighting-equipment electromagnetic immunity through JIS C 61547 (the JIS adoption of IEC 61547, Equipment for general lighting purposes — EMC immunity requirements). Unlike emissions (covered by the VCCI scheme), immunity for lighting in Japan is not subject to a mandatory pre-market law for general luminaires; JIS C 61547 / IEC 61547 testing is used where a manufacturer or major customer requires demonstrated immunity performance. The tests mirror the international set: electrostatic discharge (ESD, IEC 61000-4-2), electrical fast transient/burst (IEC 61000-4-4), surge (IEC 61000-4-5), conducted RF disturbances (IEC 61000-4-6), power frequency magnetic field (IEC 61000-4-8), and voltage dips/interruptions (IEC 61000-4-11). Where immunity evidence is requested, it is typically documented in the technical file supporting the product's Japanese market placement.JIS C 61547 / IEC 61547 — Equipment for general lighting purposes — EMC immunity requirements (JIS adoption of IEC 61547) | Japan's JIS C 61547 and China's GB/T 18595 are both adoptions of IEC 61547, so the technical immunity requirements are largely harmonized. Neither jurisdiction enforces lighting immunity as a hard mandatory pre-market requirement for general luminaires: in China GB/T 18595 is a recommended standard, and in Japan immunity is not subject to a mandatory pre-market law (the VCCI scheme addresses emissions, not immunity). The practical gap is therefore mainly a documentation/customer-requirement gap rather than a legal access barrier: a product tested to GB/T 18595 will generally meet JIS C 61547 levels owing to the shared IEC base, but where a Japanese customer or distributor requests immunity evidence, JIS C 61547 / IEC 61547 test reports should be provided in the technical file. Re-testing burden is usually low because the test set and limits are common to IEC 61547.[INFORMATIONAL] Lighting-equipment EMC immunity in Japan is addressed through JIS C 61547 (adoption of IEC 61547) and is not a mandatory pre-market requirement for general luminaires; the VCCI scheme covers emissions, not immunity. Chinese GB/T 18595 is also a recommended standard, and both share the IEC 61547 technical base, so products already tested to GB/T 18595 typically meet JIS C 61547 levels with a low re-testing burden. Where a Japanese customer or distributor requests immunity evidence, JIS C 61547 / IEC 61547 test reports should be included in the technical file supporting Japanese market placement. | JISC (Japanese Industrial Standards Committee) / JSA2026-06-15 · reference |
| Photobiological Safety — Blue Light Hazard (JIS C 7550 / IEC 62471 Risk Groups) | China has adopted GB/T 20145-2006 (Photobiological safety of lamps and lamp systems), which is technically equivalent to IEC 62471:2006 (the predecessor to the 2008 edition used in EU). GB/T 20145 is a recommended standard (T = tuijian, recommended) and is not universally mandatory for all LED luminaires in the Chinese market. Enforcement and testing obligations are less prescriptive for residential luminaires compared to the EU Ecodesign framework.GB/T 20145-2006 — Photobiological safety of lamps and lamp systems (SAC/SAMR — recommended standard) | Japan assesses photobiological safety of lamps and lamp systems through JIS C 7550 (the JIS adoption of IEC 62471, Photobiological safety of lamps and lamp systems), which is the referenced technical method commonly used to derive the risk group for an LED light source or luminaire. Unlike the EU, Japan does not impose a single horizontal Ecodesign-style regulation that makes photobiological risk-group classification a stand-alone legal obligation for all LED products; instead, where photobiological safety is relevant it is handled within the applicable JIS luminaire standards (JIS C 8105 / JIS C 8155, which incorporate or reference photobiological safety considerations) and via JIS C 7550 risk-group assessment. Risk groups range from RG0 (Exempt — no hazard) to RG3 (High risk), determined by blue-light weighted radiance and irradiance limits. Products classified RG2 or above are expected to carry appropriate warnings and usage information, and the risk-group assessment should be documented in the technical file supporting Japanese market placement.JIS C 7550 — Photobiological safety of lamps and lamp systems (JIS adoption of IEC 62471) JIS C 8105 / JIS C 8155 — luminaire and LED module / lamp standards incorporating or referencing photobiological safety considerations |
Both Japan (JIS C 7550) and China (GB/T 20145) adopt IEC 62471, so the technical method for deriving the risk group is largely common. The structural difference is that, unlike the EU which makes risk-group classification a stand-alone legal obligation, neither Japan nor China imposes a single horizontal mandatory photobiological classification law for all LED luminaires: in China GB/T 20145 is recommended-only, and in Japan photobiological safety is handled within the applicable JIS luminaire standards (JIS C 8105 / JIS C 8155) and JIS C 7550 assessment rather than a universal regulation. The practical gap for a Chinese manufacturer is documentation: where the Japanese product category or a customer requires it, a defensible risk-group assessment to JIS C 7550 / IEC 62471 should be in the technical file; RG2 luminaires should carry warnings and usage instructions, and RG3 products face usage restrictions (typically professional/industrial use). Most general-purpose LED luminaires target RG0 or RG1 with no usage restrictions, but the classification should be formally documented.[INFORMATIONAL] Photobiological risk-group classification in Japan uses JIS C 7550 (adoption of IEC 62471) and is handled within the applicable JIS luminaire standards rather than as a single horizontal mandatory regulation as in the EU. Chinese GB/T 20145-2006 is likewise recommended-only and shares the IEC 62471 base, so the technical method is common. Manufacturers should formally document a JIS C 7550 / IEC 62471 risk-group assessment in the technical file; RG2/RG3 products require additional labelling and usage warnings. | JISC (Japanese Industrial Standards Committee) / JSA2026-06-15 · reference |
| Blue Light Hazard Information on Japanese Product Labelling / Documentation | China's Energy Label (China Energy Label, CEL) mandatory under GB 30255 (LED room luminaires energy efficiency) does not include a blue light hazard class. The Chinese labelling regime focuses on energy efficiency grades (Grade 1–3) and lumen output. There is no CN regulatory requirement to display photobiological risk group information on luminaire packaging equivalent to EU Delegated Reg 2019/2015.GB 30255-2019 — Energy efficiency requirements for LED room luminaires (SAC/SAMR — no blue light class requirement) | Japan does not have a mandatory horizontal product-label rule equivalent to the EU's blue light hazard class on the energy label (the EU obligation under Delegated Reg 2019/2015 has no direct Japanese counterpart). In Japan, blue-light / photobiological information is communicated where the applicable JIS luminaire standard (JIS C 8105 / JIS C 8155) or a JIS C 7550 risk-group assessment requires marking or instructions — for example, products classified RG2 or above are expected to carry warnings and usage guidance, and manufacturers commonly provide photobiological risk-group information in product documentation, instruction sheets, or specification literature rather than on a regulated energy label. Industry guidance from JLMA (Japan Luminaires Association) and the relevant JIS standards inform the form of any photobiological warning. The obligation is therefore standard/assessment-driven and product-specific, not delivered through a single mandatory consumer label format.JIS C 7550 — Photobiological safety of lamps and lamp systems (risk-group marking / instructions where applicable) JIS C 8105 / JIS C 8155 and JLMA (Japan Luminaires Association) industry guidance — photobiological warnings and usage information |
Neither Japan nor China has the EU-style mandatory blue light hazard class on a regulated energy label — the Chinese CEL omits it, and Japan's Uniform Energy-Saving Label does not carry a blue-light class either. So a Chinese manufacturer's CN-spec packaging will not have such a class, and for Japan no equivalent regulated energy-label class needs to be added. However, the obligations are not identical: in Japan, where the applicable JIS luminaire standard or a JIS C 7550 risk-group assessment requires it (notably for RG2 and above), the product must carry appropriate photobiological warnings and usage instructions in its documentation/marking, informed by JLMA industry guidance. For export to Japan the practical steps are: (1) document a JIS C 7550 / IEC 62471 risk-group assessment; (2) include any required photobiological warnings/usage information in product documentation or marking per the applicable JIS standard for products at RG2 or above; (3) confirm whether the specific Japanese product category and customer require explicit blue-light information. This is a documentation/marking step rather than a regulated consumer energy-label class.[INFORMATIONAL] Japan has no EU-style mandatory blue light hazard class on a regulated energy label, and neither does China's CEL — so no regulated consumer energy-label class needs to be added for Japan. However, where the applicable JIS luminaire standard or a JIS C 7550 (IEC 62471) risk-group assessment requires it (notably RG2 and above), photobiological warnings and usage information must appear in the product documentation/marking, informed by JLMA guidance. Document the risk-group assessment and confirm category/customer requirements before market entry. | JLMA (Japan Luminaires Association) / JISC2026-06-15 · reference |
| J-Moss — Restricted Substance Marking (JIS C 0950) | China's equivalent is GB/T 26572-2011 (Requirements for concentration limits for certain restricted substances in electrical and electronic products), covering the original 6 RoHS substances (Pb, Hg, Cd, Cr(VI), PBB, PBDE) with the same concentration thresholds as EU RoHS. China RoHS 2 (Management Measures for the Restriction of the Use of Hazardous Substances in Electrical and Electronic Products, SJ/T 11364-2014) requires a hazardous substance disclosure label (orange for contains substances above threshold / green for below threshold) on EEE products sold in China. As of 2026, the 4 phthalates (DEHP, BBP, DBP, DIBP) added by EU Directive 2015/863 are not yet in the CN mandatory restricted list under GB/T 26572.GB/T 26572-2011 — Requirements for concentration limits for certain restricted substances in EEE (SAC/SAMR — covers original 6 substances) SJ/T 11364-2014 — Marking for the restricted use of hazardous substances in electronic and electrical products (China RoHS 2 disclosure label) |
Japan controls hazardous substances in electrical and electronic products through J-Moss (JIS C 0950 — Marking for the presence of the specific chemical substances for electrical and electronic equipment), implemented under the Act on the Promotion of Effective Utilization of Resources (Resource Recycling Act). J-Moss covers 6 substances at the same concentration thresholds as the original RoHS list: Lead (Pb) ≤0.1%, Mercury (Hg) ≤0.1%, Cadmium (Cd) ≤0.01%, Hexavalent chromium (Cr(VI)) ≤0.1%, Polybrominated biphenyls (PBB) ≤0.1%, and Polybrominated diphenyl ethers (PBDE) ≤0.1%. Unlike EU RoHS, J-Moss is fundamentally a marking/disclosure scheme rather than a market-access ban: products that comply carry a green mark (G mark), and products containing a designated substance above threshold carry an orange mark (R mark) together with a content-disclosure table (often published on the manufacturer's website). The four phthalates (DEHP, BBP, DBP, DIBP) added by EU Directive 2015/863 are not within the J-Moss substance list as of 2026. Note: J-Moss historically applies to specified product categories (e.g. certain household appliances, IT equipment) — verify whether the specific LED lamp/luminaire falls within the designated J-Moss product scope.JIS C 0950 (J-Moss) — Marking for presence of specific chemical substances for electrical and electronic equipment Act on the Promotion of Effective Utilization of Resources (Resource Recycling Act) — implementing framework for J-Moss |
Japan's J-Moss (JIS C 0950) and China's RoHS 2 (GB/T 26572 + SJ/T 11364) are structurally very similar: both cover the same original 6 substances at the same thresholds, and both are disclosure/marking schemes (green vs orange/R mark) rather than outright market bans — so a Chinese manufacturer's CN RoHS 2 disclosure work transfers conceptually to J-Moss with low additional substance-testing burden. Key gaps: (1) the marking format and content-disclosure table must follow JIS C 0950 (green G mark / orange R mark plus the prescribed content table, commonly web-published), which differs from the SJ/T 11364 label format; (2) J-Moss historically applies to designated product categories, so confirm whether the specific LED lamp/luminaire is in J-Moss scope (scope and applicability differ from the broad CN coverage); (3) like CN RoHS, J-Moss does not cover the 4 EU phthalates — neither regime requires phthalate testing, so this is not an added burden for Japan (unlike the EU). The main work is re-formatting the disclosure to the JIS C 0950 marking convention and confirming product scope.[INFORMATIONAL] Japan's J-Moss (JIS C 0950) under the Resource Recycling Act is a marking/disclosure scheme covering the same original 6 RoHS substances at the same thresholds as China's GB/T 26572, using a green G mark / orange R mark plus a content-disclosure table. It is structurally close to China RoHS 2, so the substance work largely transfers; the main task is re-formatting the disclosure to the JIS C 0950 convention and confirming the specific LED product falls within J-Moss designated scope. Neither J-Moss nor CN RoHS covers the 4 EU phthalates, so no phthalate testing is required for Japan. | METI (Resource Recycling Act / J-Moss) / JISC2026-06-15 · reference |
| Chemical Substance Control (CSCL / Chemical Substances Control Law) vs CN Chemical Regulations | China does not have a direct equivalent to the REACH SVHC Article 33 supply chain notification obligation. The closest CN instruments are: MEP (Ministry of Ecology and Environment) Order No. 12 (2010, revised) on new chemical substance registration; GB 30981-2020 (Rules for the classification and labelling of chemicals) for hazardous chemicals labelling; and the Measures for the Environmental Management of New Chemical Substances (MEE Order 12, 2020). None of these create an equivalent obligation to proactively notify B2B customers when an SVHC is present in an article above 0.1% w/w.MEE Order No. 12 (2020) — Measures for the Environmental Management of New Chemical Substances (China) GB 30981-2020 — Rules for the classification and labelling of chemicals (China) |
Japan does not have a REACH-style SVHC supply-chain Article 33 notification obligation. Instead, chemical substances are managed primarily under the CSCL (Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc. — 化審法) administered jointly by METI, MHLW, and the Ministry of the Environment, and the ISHL (Industrial Safety and Health Law) for workplace chemical hazards. CSCL classifies substances (e.g. Class I and Class II Specified Chemical Substances, Monitoring Chemical Substances) and restricts or monitors their manufacture and import, but it operates as a substance manufacture/import control regime rather than an article-level downstream-communication duty. There is no general legal obligation, equivalent to REACH Article 33, to proactively notify business customers or consumers when an article (such as an LED luminaire) contains a listed substance above 0.1% w/w. For the substances relevant to LED luminaires, the practical Japanese controls are J-Moss marking (see ledjp-rohs-01) plus any CSCL restrictions on specific chemicals used in components.Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc. (CSCL / 化審法) — METI / MHLW / Ministry of the Environment Industrial Safety and Health Law (ISHL) — workplace chemical hazard controls (Japan) |
Helpfully for a Chinese exporter, Japan — like China — has no REACH Article 33-style article-level downstream SVHC notification duty, so the heavy ongoing supply-chain SVHC communication obligation that applies for EU export does NOT apply for Japan. Both Japan (CSCL) and China (MEE Order 12) operate substance manufacture/import control and new-substance registration regimes rather than article-level disclosure duties. The practical Japanese obligations for an LED luminaire are therefore narrower: (1) ensure no component uses a CSCL Class I/II Specified Chemical Substance in a restricted manner; (2) complete J-Moss marking (ledjp-rohs-01); (3) if importing chemical substances/preparations as such (not just finished articles), check CSCL/ISHL notification thresholds. There is no biannual ECHA-Candidate-List-style screening duty and no SCIP-style database for finished LED luminaires in Japan. The gap versus the EU is that Japan is significantly lighter on downstream article-level chemical communication.[INFORMATIONAL] Japan, like China, has no REACH Article 33-style article-level downstream SVHC notification duty, so the ongoing supply-chain SVHC communication burden required for EU export does not apply for Japan. Japan's CSCL (化審法) is a substance manufacture/import control regime, not an article-level disclosure duty, and there is no SCIP-style database for finished LED luminaires. The practical Japanese chemical obligations are narrower: confirm no restricted CSCL Specified Chemical Substance is used in a non-compliant way, complete J-Moss marking, and check CSCL/ISHL thresholds only if importing chemical substances as such. | METI (Chemical Substances Control Law / CSCL)2026-06-15 · reference |
| PSE Overall Process and Importer Obligations vs CCC / CQC | In China, the primary mandatory certification for luminaires sold in the residential market is CCC (China Compulsory Certification), administered by CNCA (Certification and Accreditation Administration of China). CCC requires mandatory third-party certification by a CNCA-authorized certification body (e.g., CQC — China Quality Certification Centre). CQC voluntary certification is also available for products not covered by mandatory CCC. For wireless-enabled luminaires (e.g., smart LED with Wi-Fi/Bluetooth), SRRC (State Radio Regulation Commission) type approval is additionally required in China. CCC certification bodies are not recognised for EU CE marking purposes.CNCA-C10-01 — CCC certification rules for luminaires (CNCA/CQC) SRRC type approval — required for wireless-enabled luminaires in China |
Placing an LED luminaire on the Japan market under the DENAN (Electrical Appliances and Materials Safety Act) requires: (1) Determine the product's PSE category — Specified electrical appliance (requiring the diamond ◇ PSE mark via mandatory third-party certification by a Registered Conformity Assessment Body such as JET or JQA, including factory inspection) or Non-specified electrical appliance (round ◯ PSE mark via manufacturer/importer self-conformity-assessment and self-testing); (2) Conduct conformity testing to the applicable DENAN technical requirements / JIS standards (JIS C 8105 / JIS C 8155); (3) For Specified products, obtain the conformity certificate from the RCAB and undergo factory inspection; (4) The business operator (manufacturer or, for imports, the importer/届出事業者) must file a business notification (事業届出) with METI within 30 days of starting business, conduct conformity inspections, retain records, and apply the appropriate PSE mark with the operator's name; (5) Apply the PSE mark (◇ or ◯) on the product before sale. A domestically established importer of record bears the notification, inspection, record-keeping, and marking responsibilities. Market surveillance is conducted by METI.DENAN — Electrical Appliances and Materials Safety Act (電気用品安全法) — PSE mark framework (diamond ◇ Specified / round ◯ Non-specified) JIS C 8105 / JIS C 8155 — luminaire and LED module / lamp technical standards Registered Conformity Assessment Body (JET / JQA) — third-party certification for Specified products; MIC Giteki (技適) required for wireless-enabled luminaires |
Japan's PSE regime splits by category: Non-specified products use a self-conformity-assessment / self-declaration route (round ◯ PSE), which is lighter than China's universally mandatory third-party CCC; but Specified products require mandatory third-party certification by an RCAB (JET/JQA) including factory inspection (diamond ◇ PSE), comparable in burden to CCC. The PSE and CCC processes are parallel with no mutual recognition — separate testing, certification, and marking apply for each market, and a Chinese CCC certificate does not satisfy DENAN. Key Japan-specific requirements with no direct CN equivalent: (1) the business operator must file a METI business notification (事業届出) within 30 days of starting business and conduct/retain conformity inspections; (2) a domestically established importer of record (届出事業者) bears the notification, inspection, record-keeping, and marking duties — analogous in spirit to an EU Authorised Representative but structured as a notified domestic business operator; (3) the PSE mark (◇ or ◯) must carry the operator's name; (4) the correct Specified vs Non-specified category determines whether third-party RCAB certification or self-declaration applies — this category determination is critical and product-specific. Wireless-enabled luminaires additionally require mandatory MIC Giteki (技適) certification (parallel to SRRC in CN). Top Runner energy reporting and J-Moss marking are further obligations not covered by CCC.[INFORMATIONAL] PSE marking under the DENAN is required before Japan market placement: diamond ◇ via mandatory RCAB (JET/JQA) third-party certification with factory inspection for Specified products, or round ◯ via self-declaration for Non-specified products — so the correct category determination is critical and product-specific. PSE and CCC are parallel non-mutual processes; a Chinese CCC certificate does not satisfy DENAN. A METI business notification (事業届出) and a domestically established importer of record carry the notification, inspection, record-keeping, and marking duties. Wireless luminaires additionally need MIC Giteki (技適), and Top Runner reporting plus J-Moss marking add to the compliance scope. | METI (Electrical Appliances and Materials Safety Act / DENAN)2026-06-15 · reference |
| Electrical Safety — General Luminaire (DENAN / PSE + JIS C 8105 / JIS C 8155) | China's current general luminaire safety standard is GB/T 7000.1-2023 (Luminaires — Part 1: General requirements and tests), replacing GB 7000.1-2015 from 1 January 2026. The edition change also changes the standard designation from mandatory GB to recommended GB/T; CCC obligations for in-scope luminaires remain governed by the applicable CNCA rules and implementation requirements rather than by the GB/T designation alone. CCC testing is conducted by CNCA-authorized laboratories. CCC certification covers safety aspects broadly comparable to GB/T 7000.1, but the conformity assessment process, documentation language, and CE marking obligations are separate and non-mutual with LVD.GB/T 7000.1-2023 — Luminaires — Part 1: General requirements and tests (replaces GB 7000.1-2015 from 1 January 2026; recommended GB/T designation) CNCA-C10-01 — CCC certification rules for luminaires |
LED luminaires placed on the Japan market must comply with the DENAN (Electrical Appliances and Materials Safety Act). The applicable safety technical standards are the JIS C 8105 series (Luminaires — general and safety requirements, aligned with IEC 60598) and JIS C 8155 (LED modules and integrated LED lamps for general lighting). Depending on the product's PSE category, conformity is demonstrated either by mandatory third-party certification by a Registered Conformity Assessment Body such as JET or JQA (Specified products — diamond ◇ PSE, including factory inspection) or by manufacturer/importer self-conformity-assessment and self-testing (Non-specified products — round ◯ PSE). Key requirements cover protection against electric shock (touch current, insulation resistance, creepage and clearance distances), thermal protection, mechanical strength, and wiring terminals — and must account for Japan's 100/200 V, 50/60 Hz supply (different voltage and a split frequency versus China's 220 V, 50 Hz). The PSE mark with the operator's name must be applied, and the business operator must file a METI business notification (事業届出) and retain conformity inspection records.DENAN — Electrical Appliances and Materials Safety Act (電気用品安全法) JIS C 8105 series — Luminaires: general and safety requirements (aligned with IEC 60598); JIS C 8155 — LED modules / integrated LED lamps for general lighting |
Japan's PSE route depends on category: Non-specified luminaires use manufacturer/importer self-declaration (round ◯ PSE), while Specified products need mandatory RCAB (JET/JQA) third-party certification with factory inspection (diamond ◇ PSE) — versus China's universally mandatory third-party CCC for residential luminaires. PSE and CCC are parallel with no mutual recognition. JIS C 8105 / JIS C 8155 and GB 7000.1 share an IEC 60598 base, but Japan's standards include national deviations and — critically — the design must suit Japan's 100/200 V, 50/60 Hz supply (different voltage and split frequency versus China's 220 V, 50 Hz), which can affect creepage/clearance assumptions, transformer/driver rating, and thermal behaviour. Existing CN test reports cannot be directly reused for PSE — testing to the applicable JIS standard via a JET/JQA or recognised lab is needed, especially for Specified products. The PSE mark must carry the operator's name, a METI business notification (事業届出) is required, and a domestically established importer of record bears the inspection and record-keeping duties.[INFORMATIONAL] PSE marking under the DENAN is mandatory for LED luminaires entering the Japan market, using JIS C 8105 / JIS C 8155 as the technical standards. The route depends on the PSE category — diamond ◇ via mandatory RCAB (JET/JQA) third-party certification with factory inspection for Specified products, or round ◯ via self-declaration for Non-specified products. Chinese CCC certification and GB/T 7000.1-2023 evidence do not satisfy the DENAN pathway, and the design must suit Japan's 100/200 V, 50/60 Hz supply. Test to the applicable JIS standard, apply the PSE mark with the operator's name, file the METI business notification, and use a domestically established importer of record for inspection and record-keeping. | METI (Electrical Appliances and Materials Safety Act / DENAN)2026-06-15 · reference |
| LED Driver / Control Gear Safety (JIS C 8147-2-13 / DENAN PSE) | China's equivalent is GB 19510.14-2014 (Control gear for lamps — Particular requirements for DC or AC supplied electronic controlgear for LED modules), which is technically aligned with IEC 61347-2-13. CCC certification may be required for LED drivers in certain power ranges sold in the Chinese residential market. Chinese CCC test reports under GB 19510.14 are not accepted under the EU LVD conformity assessment pathway.GB 19510.14-2014 — Control gear for lamps — Part 2-13: Particular requirements for DC or AC supplied electronic controlgear for LED modules (SAC/SAMR) | LED drivers (control gear for LED modules) intended for the Japan market are regulated under the DENAN (Electrical Appliances and Materials Safety Act). The applicable safety standard is JIS C 8147-2-13 (Lamp controlgear — Part 2-13: Particular requirements for DC or AC supplied electronic controlgear for LED modules, the JIS adoption aligned with IEC 61347-2-13). It specifies isolation class, dielectric strength, thermal endurance, and safety marking requirements for LED drivers, and the rating must suit Japan's 100/200 V, 50/60 Hz supply. Whether a driver requires the diamond ◇ PSE (RCAB third-party certification) or round ◯ PSE (self-declaration) depends on its DENAN category designation. If the driver is sold as a separate product (not integrated into the luminaire), it requires its own PSE conformity and marking in addition to the luminaire-level PSE; the business operator must file a METI business notification (事業届出) and retain inspection records.DENAN — Electrical Appliances and Materials Safety Act (電気用品安全法) — PSE for LED control gear JIS C 8147-2-13 — Lamp controlgear — Part 2-13: Particular requirements for DC or AC supplied electronic controlgear for LED modules (JIS adoption of IEC 61347-2-13) |
JIS C 8147-2-13 and GB 19510.14 are both derived from IEC 61347-2-13 and are largely harmonized in technical content. Key Japan-specific gaps: (1) the driver must be rated for Japan's 100/200 V, 50/60 Hz supply rather than China's 220 V, 50 Hz, which affects input rating, components, and thermal margins; (2) if the LED driver is sold as a standalone product separately from the luminaire, separate PSE conformity and marking is required for the driver itself under the DENAN, with the route (diamond ◇ via RCAB or round ◯ via self-declaration) set by its DENAN category designation; (3) a Chinese CCC report under GB 19510.14 does not satisfy DENAN — testing to JIS C 8147-2-13 (via JET/JQA or recognised lab for Specified products) is needed; (4) the PSE mark must carry the operator's name and a METI business notification (事業届出) is required. A domestically established importer of record bears the inspection and record-keeping duties — analogous in spirit to an EU Authorised Representative but structured as a notified domestic business operator.[INFORMATIONAL] LED drivers placed on the Japan market as standalone products require PSE marking under the DENAN, using JIS C 8147-2-13 as the applicable safety standard, with the route (diamond ◇ via RCAB third-party certification or round ◯ via self-declaration) set by the DENAN category. The driver must be rated for Japan's 100/200 V, 50/60 Hz supply rather than China's 220 V, 50 Hz, and a Chinese GB 19510.14 CCC report does not satisfy DENAN. When the driver is integrated into a luminaire and not sold separately, its safety evidence forms part of the luminaire PSE technical documentation alongside JIS C 8105 / JIS C 8155 evidence. | METI (Electrical Appliances and Materials Safety Act / DENAN)2026-06-15 · reference |
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