Radio Law Certification proves that radio equipment complies with technical regulations of the law. There are two types of certifications in Japan: Technical Regulations Conformity Certification and Attestation of the Construction Design. They are certification rules and systems that Specified Radio Equipment is conformed to the technical regulations in the law by Registered Certification Body who is registered by Ministry of Internal Affairs and Communications.
Technical Regulations Conformity Certification and Attestation of the Construction Design certify that radio equipment complies with the regulations of the law. By obtaining one of these certifications, products can be attached the Technical Conformity Mark as a proof of conformity.

In this article, you can learn mainly about Attestation of the Construction Design that certifies compliance with the Radio Law and its system, and, additionally, the necessity of Technical Conformity Mark and the risk of violating the law by not obtaining the certification.
Please note that all Kaga FEI's modules with built-in antennas have obtained Attestation of the Construction Design in Japan, as well as Radio Law Certification in the United States and Canada.

Radio Law and Certification

In order to develop and provide radio equipment such as IoT devices, it is essential to obtain Radio Law Certification on the devices from the perspective of legal compliance. However, if a wireless module, which is embed in the device, has already been certified, it is not necessary to obtain it redundantly on the device as long as it is under the conditions of Radio Law Certification of the module. Since Kaga FEI's wireless modules are certified to Radio Law Certification in Japan, the U.S., and Canada, the users don’t have to apply for redundant Radio Law Certifications on the devices for these countries.
This makes it possible to reduce the time and cost to obtain the certifications, and you can introduce your products to the market more quickly.

Let's look at the Radio Law, which is the standard for certification.
Radio Law was established to use the limited resource of radio waves fairy and efficiently and to prevent interference to surrounding equipment and other important communications caused by illegal or overly powerful radio waves.
Under Radio Law, all devices which emit radio waves for communication are recognized as radio stations. In principle, licenses are required to use radio equipment, that is to establish radio stations. However, it is exceptionally allowed to use small-scale radio stations without license, as described below about the Technical Regulations Conformity Certification System.

“ In this system a person registered by the Minister for Internal Affairs and Communications (registered certification body) certifies specific radio equipment such as cellular telephones used in small-scale radio stations specified by applicable ordinances of the Ministry of Internal Affairs and Communications as conforming to technical regulations prescribed in the Radio Act (Article 38-2-2 (1)) prior to the installation.
Certified specified radio equipment will be granted either a simplified license application procedure, which does not require an inspection after the completion of construction work, a blanket license that covers specified radio stations, or will not require a license, depending on the type of the equipment.” 
（(Source: “MIC Radio Use Portal” https://www.tele.soumu.go.jp/e/sys/equ/tech/)）

For users of small-scale radio stations to receive the exceptional measures above, Technical Regulations Conformity Certification and Attestation of the Construction Design are required to certify that the stations have inspections and certification by certification organization based on Radio Law and the stations meet technical regulations without licenses.
It is considered “Technical Regulations Conformity certified”, which means that the product is certified to Technical Regulations Conformity Certification or Attestation of the Construction Design of Japanese Radio Law.

Differences between Technical Regulations Conformity Certification and Attestation of the Construction Design

Both are systems to certify the conformity with technical regulations of radio equipment based in Radio Law.

In the Technical Regulations Conformity Certification system, each product must be tested individually. A lot of products are required to conduct testing, so it tends to take substantial costs. The certification is for sample unit or low volume product since the number of test objects will be limited.
On the other hand, in the system of Attestation of the Construction Design, each type of radio equipment will be conducted testing. Because the test object is each construction design not each individual radio equipment, the finished radio equipment is manufactured after the certification, which is the biggest difference compared with Technical Regulations Conformity Certification. It is good certification system for design of mass-manufactured radio equipment because there is no limitation of the number of the equipment in each certified design. However, it is more difficult to be certified to it than Technical Regulations Conformity Certification as there are many documents required to explain in detail the quality of the product and the testing methods to ensure that all radio equipment manufactured conforms to the regulations and the examination is stricter.
KAGA FEI’s modules with built-in antennas are certified to Attestation of the Construction Design as mass-manufactured products.

Technical Conformity Mark and Validity of Radio Law Certification

Technical Conformity Mark

Technical Conformity Mark shows you the product is a radio equipment complies with technical regulations based on Radio Law, which is certified with either Technical Regulations Conformity Certification or Attestation of the Construction Design.
You can confirm the date and method of certification by checking the certification number of Technical Regulations Conformity Certification or Attestation of the Construction Design.
It is common that Technical Conformity Mark and the certification number of Attestation of the Construction Design are incused or attached on the back or bottom of the device, or behind of battery cover. The number of Attestation of the Construction Design may be found by opening the setting screen from the software in the case of smartphone. In addition, if product is too small to be indicated Technical Conformity Mark and the number of Attestation of the Construction Design, this information is written in package and user’s manual.
While many electronic devices such as smartphones or PC peripherals in Japanese market have Japanese Radio Law Certification and have the number of Attestation of the Construction Design, some non-Japanese products in Japanese market do not have any markings, which may not be certified to Japanese Radio Law in the import phase. You should be cautioned before using such products, as it may be illegal to use them in Japan.

Validity of Radio Law Certification

It is mandatory to obtain Radio Law Certification to use the radio equipment in Japan. However, you can skip the process of Radio Law Certification on the end product by incorporating a radio module that has already acquired the Attestation of the Construction Design. If a module that has not been certified is incorporated into the end product, the end product must be certified in accordance with the Radio Law.
However, even when using a module with Attestation of the Construction Design, if the module is to be used under different conditions than when the certification was obtained, the end product must obtain Radio Law Certification on itself.

The Radio Law Certification system differs from country to country. In some countries, the Radio Law Certification is only valid if it has been obtained in a certain country. After confirming which country or region the radio equipment will be used in, it is necessary to obtain the appropriate Radio Law Certification for each country.

Necessity and Legal Aspects of Radio Law Certification

What happens if you use radio equipment without Technical Conformity Mark?

Penalties and Troubles for Violation of Radio Law

Except for some radio equipment, it may be against Radio Law to use radio equipment without Technical Conformity Mark in its body or user’s manual. There is a possibility that personal users of equipment which is against the law are subject to fines and other severe penalties. This is because that the nation controls radio waves as public property and it must protect important communications from interference by unregulated radio transmissions.
Radio equipment certified under the Radio Law can be used without the need for a license. You need to be careful that Radio Law Certification can be invalid if radio equipment fails to meet regulations due to unregulated modifications or damage.

Thus, the act of using radio equipment without the Technical Conformity Mark or equipment that has been modified after obtaining Radio Law Certification and no longer meets the regulations is treated as a violation of the Radio Law and may result in administrative or criminal penalties. Even individuals can be fined up to 1 million yen or imprisoned. From a legal standpoint, it is important to select equipment with Radio Law Certification in mind. Since there are many extralegal disadvantages to using a radio equipment that is not Radio Law certified, and the risk of continuing to use the equipment in an illegal state is high, it is essential to check for the presence of the Technical Conformity Mark.

The importance from safety standpoint

It is also crucial to obtain Radio Law Certification from a safety perspective. For example, if radio communications of aircraft or medical equipment are interfered with by strong radio waves, it could cause serious accidents. The existence of the Radio Law Certification system prevents such unforeseen situations and ensures an environment in which users can enjoy communication technology with peace of mind.

Radio Law Certification issues on non-Japanese products in Japanese market

Some smartphones and radio equipment imported in Japan are not certified under Radio Law in Japan, even though they meet regulations of export origin. Using such equipment in Japan may be a violation of the law, and great care must be taken when purchasing and using them. It is important to check in advance whether they have Japanese Technical Conformity Mark when you use non-Japanese products in Japan.

Summary

Japanese Radio Law Certification system, like the radio laws of other countries, was established to maintain healthy radio environment in Japan and to use radio equipment with peace of mind. The certification is essential requirement for radio equipment to use without serious troubles or violations of the law. It is essential to check if the product has Technical Conformity Mark, especially when you use non-Japanese products in Japan.
Obtaining Radio Law Certification through the proper procedures provides you with many advantages in terms of legal and safety aspects as well as product reliability. While the duty may seem like a high barrier for manufacturers to introduce their products to market, it delivers peace of mind to users, and it is an indispensable process to ensure comfortable communication environment.

Please feel free to contact us about anything regarding Radio Law Certification and wireless modules.