CROSS-STANDARD public interest · Lithium battery / power bank
China-to-Japan Lithium Battery & Power Bank 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 China lithium battery and power bank documentation against Japan requirements: DENAN (Electrical Appliances and Materials Safety Act), diamond PSE mark via a Registered Conformity Assessment Body (JET/JQA), JIS C 8712/8714 cell safety, VCCI/Giteki EMC and radio, UN 38.3 + ICAO/IMDG transport, and CSCL chemical notification.
Dataset 2026-06-11
Last verified 2026-06-15
5 rows
GAP MATRIX
Compliance Gap Matrix
| Compliance item | Common China baseline | Japan (PSE/JET) | Gap / action | Source + verification date |
|---|---|---|---|---|
| Japan DENAN Act (Electrical Appliances and Materials Safety Act) — PSE Regime, Labelling and Chemical Notification | China does not have a directly equivalent single regulation. Portable lithium battery packs for export are primarily subject to GB 31241-2022 (safety), product registration with customs (import/export declarations), and for certain rechargeable battery products, mandatory CCC certification under CNCA catalogue. There is no CN equivalent of the EU Battery Passport, carbon footprint declaration framework, or cobalt/lithium supply chain due diligence law for battery exporters. China's own EPR scheme (producer responsibility for waste batteries under the Solid Waste Law and the 2021 Battery Recycling Management Measures) applies domestically but differs structurally from EU EPR.GB 31241-2022 — Safety requirements for portable sealed secondary lithium cells and batteries for use in portable electronic equipment (SAC/SAMR) PRC Solid Waste Pollution Prevention and Control Law (2020 revision) — domestic EPR framework MIIT/NDRC Battery Recycling Management Measures (2021) — domestic recycling obligations |
Japan does not regulate batteries through a single EU-style battery regulation. Instead, lithium-ion secondary batteries fall under the DENAN Act (Electrical Appliances and Materials Safety Act, 電気用品安全法), administered by METI (Ministry of Economy, Trade and Industry). Key obligations for in-scope portable lithium secondary batteries: (1) Classification — lithium-ion secondary batteries within the rated volumetric energy density threshold are listed as Specified Electrical Appliances (特定電気用品) in the Appended Table of the DENAN Enforcement Order, requiring the diamond PSE mark. (2) Business notification — the manufacturer or importer must file a business notification (事業届出) with METI before placing products on the market and retain conformity inspection records. (3) Labelling — the diamond PSE mark, the name of the notifying business operator, and rated values must be marked on the product per the Ordinance. (4) Chemical notification — substances may require notification under CSCL (Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc., 化審法) where new chemical substances are involved. There is no Japanese equivalent of the EU Battery Passport, carbon footprint declaration, or critical-mineral supply chain due diligence law.Electrical Appliances and Materials Safety Act (DENAN, 電気用品安全法) — METI — Specified Electrical Appliances regime and diamond PSE mark DENAN Enforcement Order (電気用品安全法施行令) Appended Table — listing of lithium-ion secondary batteries as Specified Electrical Appliances Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc. (CSCL, 化審法) — chemical substance notification where applicable |
Japan's DENAN Act imposes obligations with no Chinese equivalent: (1) classification of lithium-ion secondary batteries as Specified Electrical Appliances requiring the diamond PSE mark via third-party conformity assessment; (2) business notification (事業届出) to METI before market placement, with retained conformity records; (3) Japan-specific product labelling (diamond PSE mark, notifying operator name, rated values) per the Ministerial Ordinance; (4) CSCL chemical substance notification where new substances are involved. Unlike the EU, Japan has no Battery Passport, no carbon footprint declaration, and no critical-mineral due diligence law for batteries. The core structural gap for Chinese exporters is the PSE conformity assessment and METI notification pathway, which is entirely separate from Chinese GB compliance.[INFORMATIONAL] Japan's DENAN Act is the central compliance gap for Chinese portable lithium battery / power bank exporters. In-scope lithium-ion secondary batteries are Specified Electrical Appliances requiring the diamond PSE mark obtained via a Registered Conformity Assessment Body, business notification to METI, Japan-specific labelling, and retained conformity records; CSCL notification may apply for new chemical substances. JIS C 8712/8714 supports the technical-standards conformity, but the legal obligations come from the DENAN Act and its Ordinances. None of these obligations have direct equivalents in Chinese domestic export requirements. | Ministry of Economy, Trade and Industry (METI) — Electrical Appliances and Materials Safety Act (DENAN)2026-06-15 · reference |
| Cell and Battery Pack Safety — JIS C 8712 / JIS C 8714 | China's primary safety standards for portable lithium battery packs are GB 31241-2022 (Safety requirements for portable sealed secondary lithium cells and batteries for use in portable electronic equipment — revised edition) and GB 18287-2013 (General specification for lithium-ion batteries for mobile phones, under revision). GB 31241 is technically derived from IEC 62133-2 but contains national deviations in test severity and acceptance criteria. Testing by a Chinese CNAS-accredited laboratory to GB 31241 is NOT recognised by Japanese Registered Conformity Assessment Bodies or under the DENAN Act PSE conformity assessment pathway.GB 31241-2022 — Safety requirements for portable sealed secondary lithium cells and batteries for use in portable electronic equipment (SAC/SAMR) GB 18287-2013 — General specification for lithium-ion batteries for mobile phones (SAC) |
Portable lithium-ion secondary cells and battery packs placed on the Japanese market must meet the technical standards under the DENAN Act (Electrical Appliances and Materials Safety Act). For in-scope lithium-ion secondary batteries listed as Specified Electrical Appliances, conformity to the Ministerial Ordinance technical standards is mandatory, and these reference JIS C 8712 (Safety requirements for portable sealed secondary cells and batteries) and JIS C 8714 (Safety tests for portable lithium-ion secondary cells and batteries for use in portable electronic equipment). JIS C 8712 is technically aligned with IEC 62133 and covers abuse testing (overcharge, short-circuit, crush, drop, thermal abuse, forced discharge); JIS C 8714 adds internal short-circuit evaluation. Conformity must be assessed by a Registered Conformity Assessment Body (e.g., JET or JQA) for the diamond PSE mark, and records retained.JIS C 8712 — Safety requirements for portable sealed secondary cells and batteries, and for batteries made from them, for use in portable applications (JISC) JIS C 8714 — Safety tests for portable lithium-ion secondary cells and batteries for use in portable electronic equipment (JISC) Electrical Appliances and Materials Safety Act (DENAN) Ministerial Ordinance — technical standards for Specified Electrical Appliances |
Exporters must build evidence for the DENAN Act technical-standards obligation. JIS C 8712 and JIS C 8714 testing assessed by a Registered Conformity Assessment Body (e.g., JET or JQA) is the route to the mandatory diamond PSE mark for in-scope lithium-ion secondary batteries. Existing GB 31241 reports may support engineering analysis but do not automatically establish DENAN conformity. Key gaps: (1) test scope and severity differences, including JIS C 8714 internal short-circuit testing not mirrored one-to-one in GB 31241; (2) Japan requires third-party conformity assessment by a Registered Conformity Assessment Body for Specified Electrical Appliances (self-declaration is not sufficient for the diamond PSE category); (3) the diamond PSE mark and notifying-operator labelling have no equivalent in Chinese domestic export requirements.[INFORMATIONAL] Japanese market placement of in-scope lithium-ion secondary batteries requires conformity to the DENAN Act technical standards, which reference JIS C 8712 and JIS C 8714, assessed by a Registered Conformity Assessment Body (e.g., JET or JQA) for the diamond PSE mark. Chinese GB 31241 certification does not by itself satisfy the DENAN conformity assessment, so exporters should prepare Japan-facing JIS testing and third-party certification for the diamond PSE pathway. | Japan Electrical Safety & Environment Technology Laboratories (JET) — PSE certification for lithium-ion batteries2026-06-15 · reference |
| EMC (VCCI) and Radio (MIC Giteki) for Power Banks with Integrated Electronics | China's domestic EMC requirements for electronic products are governed by GB/T 9254.1-2021 (Limits and methods of measurement of radio disturbance characteristics of information technology equipment — Part 1: Class B equipment) for emissions, and GB/T 17618-2015 (Limits and methods of measurement of immunity characteristics of information technology equipment) for immunity. Products with wireless functions require SRRC (State Radio Regulation of China) type approval under MIIT administration, which is specific to Chinese radio frequencies and protocol implementations. Chinese GB/T EMC test reports and SRRC approval are NOT recognised under Japan's VCCI scheme or the Radio Act Giteki conformity pathway.GB/T 9254.1-2021 — Information technology equipment — Radio disturbance characteristics — Part 1: Class B equipment (SAC/SAMR) GB/T 17618-2015 — Information technology equipment — Immunity characteristics — Limits and methods of measurement (SAC) SRRC type approval — State Radio Regulation of China, MIIT — required for products with wireless functions sold in China |
Power banks (portable battery packs with integrated charging circuitry, USB outputs, and display) are electronic apparatus subject to Japan's EMC framework. EMC for IT/multimedia equipment in Japan is principally addressed through the VCCI (Voluntary Control Council for Interference) self-regulatory scheme based on CISPR limits (e.g., CISPR 32 / J55032), with VCCI conformity widely treated as the de-facto market expectation. If the power bank incorporates wireless functionality (e.g., Qi wireless charging output, Bluetooth state-of-charge indicator, NFC), it becomes radio equipment under the Radio Act (電波法) and requires MIC (Ministry of Internal Affairs and Communications) technical conformity certification — the Giteki mark (技適マーク) — issued by a Registered Certification Body. The diamond PSE mark under DENAN remains required for the battery itself; VCCI EMC and Giteki radio obligations are additional and parallel.VCCI Council Regulations — Voluntary Control Council for Interference by ITE (based on CISPR 32 / J55032 emission limits) Radio Act (電波法) — Japan, administered by MIC — technical conformity (Giteki, 技適) for radio equipment Ordinance Regulating Radio Equipment (無線設備規則) — MIC technical standards for wireless modules J55032 / CISPR 32 — Electromagnetic compatibility of multimedia equipment — Emission requirements |
Power banks with integrated electronics (USB charging IC, protection circuit, display, or wireless function) must address Japan's EMC and radio framework, which is structurally different from China's. EMC is handled via VCCI self-regulation (CISPR-based) rather than a single mandatory directive, but VCCI registration and marking is the practical market expectation for ITE/multimedia equipment. Key gaps: (1) for wireless variants, MIC Giteki (技適) technical conformity certification under the Radio Act is mandatory and is issued by a Japan-Registered Certification Body — SRRC approval is not transferable; (2) Japan radio rules restrict permitted frequency bands and power levels (e.g., 2.4 GHz channel/power rules), so devices designed for the Chinese market may need re-characterisation; (3) the Giteki mark must be displayed on the product or screen. Chinese GB/T 9254 and SRRC approvals may support engineering review but are not accepted as standalone evidence for Japanese VCCI registration or Giteki certification.[INFORMATIONAL] Power banks are electronic apparatus subject to Japan's EMC framework via the VCCI self-regulatory scheme (CISPR-based), which is the practical market expectation rather than a single mandatory directive. Wireless variants are subject to mandatory MIC Giteki (技適) technical conformity certification under the Radio Act, issued by a Japan-Registered Certification Body. Chinese GB/T 9254 and SRRC approvals are not standalone Japanese conformity evidence. These EMC/radio obligations apply in parallel with the DENAN diamond PSE mark for the battery itself. | VCCI Council — Voluntary Control Council for Interference by Information Technology Equipment (Japan)2026-06-15 · reference |
| Japan Market Access — Diamond PSE Mark, METI Business Notification, JET/JQA Conformity and Recycling Obligations | China's domestic market access for lithium battery products uses a different framework: CCC (China Compulsory Certification, administered by CNCA/SAMR) is mandatory for certain rechargeable battery product categories sold domestically (e.g., mobile phone lithium batteries are CCC-listed). However, CCC certification is a Chinese domestic market requirement and is NOT recognised by Japan; it does not substitute for the PSE mark. Chinese manufacturers do not need to appoint a Japanese notifying business operator for domestic Chinese sales. There is no Chinese equivalent of Japan's METI business notification or JBRC recycling participation obligation for exporters. WEEE-style obligations have no direct Chinese counterpart in the Japanese sense; China has the Regulations on the Administration of the Recovery and Disposal of Waste Electrical and Electronic Products (废弃电器电子产品回收处理管理条例) for domestic use.CCC — China Compulsory Certification (CNCA/SAMR) — domestic China market access only; not recognised in Japan PRC Regulations on the Administration of the Recovery and Disposal of Waste Electrical and Electronic Products (2011, amended 2019) — domestic recycling equivalent |
Non-Japanese manufacturers placing portable lithium secondary batteries or power banks on the Japanese market must fulfil the following market access obligations: (1) Diamond PSE mark — for in-scope lithium-ion secondary batteries (Specified Electrical Appliances), conformity must be assessed by a Registered Conformity Assessment Body (e.g., JET or JQA), and the diamond PSE mark affixed after certification. (2) Business notification (事業届出) — the importer or domestic manufacturer must file a business notification with METI before placing products on the market, and must be a Japan-established notifying business operator (届出事業者) who carries the legal responsibility (a foreign maker typically works through a Japanese importer/operator). (3) Conformity records — the operator must conduct and retain the required conformity inspections. (4) Recycling — under the Act on the Promotion of Effective Utilization of Resources (資源有効利用促進法), small rechargeable batteries (including lithium-ion) are designated for recycling, and producers participate in the JBRC collection scheme; in-store collection and the recycling mark may apply. The round PSE mark applies only to Non-specified appliances via self-declaration and does not cover the diamond-PSE lithium-ion secondary battery category.Electrical Appliances and Materials Safety Act (DENAN) — diamond PSE mark via Registered Conformity Assessment Body; round PSE for Non-specified appliances via self-declaration DENAN Act business notification (事業届出) to METI — notifying business operator obligations Act on the Promotion of Effective Utilization of Resources (資源有効利用促進法) — small rechargeable battery recycling (JBRC scheme) Registered Conformity Assessment Body certification — e.g., JET, JQA (METI-registered) |
Chinese manufacturers exporting portable lithium batteries to Japan face four structural market access gaps with no Chinese domestic equivalent: (1) the diamond PSE mark obtained through third-party conformity assessment by a Registered Conformity Assessment Body (e.g., JET or JQA) before market placement — self-declaration (round PSE) is not available for in-scope lithium-ion secondary batteries; (2) a Japan-established notifying business operator (届出事業者) must file the METI business notification and carry legal responsibility — a foreign maker typically must work through a Japanese importer or operator; (3) retained conformity inspection records under the DENAN Act; (4) participation in the JBRC small rechargeable battery recycling scheme under the Resource Effective Utilization Act, with recycling marking. CCC certification (Chinese domestic) is not transferable. Total compliance cost may include Registered Conformity Assessment Body certification fees, importer/operator arrangement, and recycling-scheme participation.[INFORMATIONAL] Chinese portable lithium battery and power bank exporters must address four market access obligations before Japanese market entry: the diamond PSE mark via a Registered Conformity Assessment Body (e.g., JET or JQA), a Japan-established notifying business operator filing the METI business notification, retained conformity inspection records under the DENAN Act, and JBRC small rechargeable battery recycling participation. The round PSE self-declaration route does not cover in-scope lithium-ion secondary batteries. CCC certification does not transfer to or substitute for any of these Japanese requirements. | Ministry of Economy, Trade and Industry (METI) — Electrical Appliances and Materials Safety Act (DENAN) market access2026-06-15 · reference |
| Transport Safety — UN 38.3, ICAO/IATA Air and IMDG Sea (Lithium Batteries) | China requires UN 38.3 test reports for all lithium batteries transported by air, consistent with ICAO and CAAC (Civil Aviation Administration of China) requirements. For domestic road transport, GB 12268 (Dangerous Goods List) and JT/T 617 (Road Transport of Dangerous Goods) apply. For sea transport, IMDG Code (International Maritime Dangerous Goods Code) requirements apply globally. Chinese exporters shipping lithium batteries by air already typically obtain UN 38.3 test reports; however, the Japan-side implementing rules and documentation requirements (Civil Aeronautics Act / JCAB for air, Ship Safety Act / MLIT for sea, packing and marking inspections at Tokyo/Yokohama and Kobe) are additional obligations not mirrored in Chinese domestic transport rules.GB 12268-2012 — List of dangerous goods (SAC/SAMR) — domestic road transport classification JT/T 617-2018 — Road transport of dangerous goods — requirements (Ministry of Transport, PRC) CAAC Order No. 55 — Provisions on the Transport of Dangerous Goods by Civil Aviation (CAAC) |
Lithium batteries (cells, battery packs, and power banks) are classified as dangerous goods for transport purposes. For air transport to or within Japan, ICAO Technical Instructions and IATA Dangerous Goods Regulations (DGR) apply, implemented domestically by the Civil Aeronautics Act and JCAB (Japan Civil Aviation Bureau); lithium-ion cells are UN 3480, batteries packed with or in equipment are UN 3481. For sea transport — the dominant route via Tokyo/Yokohama and Kobe — the IMDG Code applies, implemented in Japan through the Ship Safety Act and related Ministerial Ordinances (MLIT). All lithium batteries — regardless of origin — must have a valid UN 38.3 test report (UN Manual of Tests and Criteria, Part III, Section 38.3: Lithium Metal and Lithium-Ion Batteries) before transport. The UN 38.3 test covers altitude simulation, thermal test, vibration, shock, external short-circuit, impact/crush, overcharge, and forced discharge.UN Manual of Tests and Criteria, Part III, Section 38.3 — Lithium Metal and Lithium-Ion Batteries (UN 38.3) IMDG Code (International Maritime Dangerous Goods Code) — Class 9, UN 3480 / UN 3481 — implemented in Japan via the Ship Safety Act and Ministerial Ordinances (MLIT) ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air (Doc 9284) — implemented via the Civil Aeronautics Act (JCAB) IATA Dangerous Goods Regulations (DGR), current edition — Section 3.9 (UN 3480 / UN 3481) |
UN 38.3 test reports are required globally (air and sea) and most Chinese exporters already hold them. The Japan-specific gap is in the implementing transport regime: most China-to-Japan battery volume moves by sea, so IMDG Code compliance as implemented through Japan's Ship Safety Act and MLIT Ministerial Ordinances is the primary concern — packages must carry UN 3480/3481 markings and Class 9 lithium battery marks, with conforming dangerous-goods documentation accepted at Tokyo/Yokohama and Kobe. For air shipments via Narita/Haneda or Kansai, ICAO/IATA DGR state-of-charge limits (30% maximum for loose lithium-ion cells shipped as cargo) and JCAB requirements under the Civil Aeronautics Act apply. Exporters should confirm their UN 38.3 reports are from an accredited laboratory and cover the specific cell/pack configuration, and ensure Japan-side consignees and forwarders hold appropriate dangerous-goods handling capability.[INFORMATIONAL] UN 38.3 testing is a universal transport requirement — Chinese exporters shipping lithium batteries to Japan must hold valid UN 38.3 test reports from accredited laboratories. Japan-specific additions are in the implementing regime: IMDG Code compliance via the Ship Safety Act and MLIT Ordinances for sea transport (the dominant route via Tokyo/Yokohama and Kobe), and ICAO/IATA DGR state-of-charge limits with JCAB requirements under the Civil Aeronautics Act for air cargo. Most compliant Chinese exporters already meet UN 38.3; the gap is typically in Japan-side dangerous-goods documentation and consignee handling capability. | United Nations Economic Commission for Europe (UNECE) — Manual of Tests and Criteria (UN 38.3)2026-06-15 · reference |
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SOURCES
Official-source register.
- Ministry of Economy, Trade and Industry (METI) — Electrical Appliances and Materials Safety Act (DENAN) · accessed 2026-06-15 · reference · used in 1 rows
- Japan Electrical Safety & Environment Technology Laboratories (JET) — PSE certification for lithium-ion batteries · accessed 2026-06-15 · reference · used in 1 rows
- VCCI Council — Voluntary Control Council for Interference by Information Technology Equipment (Japan) · accessed 2026-06-15 · reference · used in 1 rows
- Ministry of Economy, Trade and Industry (METI) — Electrical Appliances and Materials Safety Act (DENAN) market access · accessed 2026-06-15 · reference · used in 1 rows
- United Nations Economic Commission for Europe (UNECE) — Manual of Tests and Criteria (UN 38.3) · accessed 2026-06-15 · reference · used in 1 rows