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Following this and the implementation of the new procedures, it sisud be easier to increase U.S. electric appliance exports to Japan, particularly by U.S. companies without current representation in Japan.
Further progress has been made with MITI's announcement on October 8, 1979, that it had decided in principle to accept U.S. test data for type approval (T-mark). This bas resulted from numerous meetings held between the U.S. government and the Japanese government since the November 1978 TSG meeting mentioned above.
i:aportant progress was made when both countries reached almost cornplete agreement on the acceptance of UL data on the occasion of the U.S. - japan Electric Appliance Industry meeting in the fall oí 1979.
All the issues presented to MITI by the TSG through the Task Force, and their status to date, have been summarized in the chart on page 24.
The Electrical Appliances Task Force believes that true recip:ocity in trade relations is vital if exports to Japan of U.S. manufactured appliances are to increase. The Task Force has concerned itself specifically with the question of reciprocity in standards and testing procedures. It will continue to seek to ameliorate conditions where reciprocity is not complete by bringing such issues to the attention of those concerned.
SUMMARY OF RESULTS OF TSG-MITI CONSULTATIONS
Market access problems previously identiiled by TSG
MTTI ections so far to alleviate market access issues
Lack of acceptance by MITI OE U.S. test data for type approval (T-mark):
U.S. testing organizations' test data not acceptęd
Progressing MITI has agreed to accept U.S. test dat.
tion tests" performed by JET in Japan
Lack of adequate access by U.S. manufacturers to Japanese testing organizations and MITI:
U.S. manufacturers cannot apply directly to
Partially resolved MITI has agreed to direct
applications for "prior certificacion" test, but
apply for "type test"
b Partially resolved JET currently offers informal Review". procedure in dealing with Japanese
consultations to Japanese and forcign manufacturers testing organizations
and will endeavor to meet our request for establish
ment of some formal procedure
Resolved MITI has agreed to participation of u.s.
Industry representatives on JEA advisory conmittee
version of standards
MITI has agreed to consider specific U.S. requests harinonization between Japanese and U.S. Standards d. U.S. manufacturers are not notified of impending d Resolved Implementation being worked out
changes in standards
AUTOMOTIVE TASK FORCE
According to the Japan Automotive Manufacturers Association, the number of Japanese cars exported to the United States in 1979 totalled 2,072, 666, while that of American exports to Japan was 16,224 in the same year. This discrepancy is due to a number of factors, including a consumer preference for small cars, which must be recognized and dealt with by both the United States and Japan.
The Japanese government has already taken a number of steps to make its market more accessible to foreign vehicles. In 1971 the government eased barriers to foreign investment, permitting U.S. firms to acquire equity positions in Japanese automotive manufacturers. In 1973, the rate of commodity tax on automobiles with over 2000 cc displacement was lowered from 40% to 20%. In the spring of 1978 Japan reduced the tariff on imported cars to zero and has subsequently initiated a program to improve the type approval/certification system of the Ministry of Transportation. The improved type approval process includes in-country inspection of vehicles to be imported to Japan and permits earlier introduction of new model cars in the Japanese market. Also in 1978 Japan waived certain Japanese exhaust control requirements for imported vehicles until 1981. Finally, in October 1979 the Ministry of Transportation posted technical personnel in the New York office of JETRO to further communications between the Ministiy of Transportation and the U.S. automobile manufac
However, further steps are needed to deal with the problems dis cussed below.
The Task Force, composed largely of U.S. auto manufacturers, has been concent:ating its efforts, with the cooperation of MITI, through two Japanese government channels: the Ministry of Transportation (MOT) and the Ministry of Finance (MOF).
While some progress has been made in certain areas, little or no improvement is in sight in others. The Task Force is confident, however, that continued eliort and discussion with the parties concerned will bring about a reduction of deterrents to auto imports into Japan.
MINISTRY OF TRANSPORTATION
The Automotive Task Force has beea discussing with MOT issues related to Japanese certification, registration, and homologation* require
Discussions have ranged from proposals for the Japanese government to accept U.S. certification requirements as an equivalent for those required in Japan, to proposals for elimination of, or allowances for alter. natives to, certain safety or pollution prevention requirements.
The Task Force realizes that Japanese standards for safety and pollution prevention are not specifically directed against imports. Nevertheless, requirements have considerably more impact, in many cases, imports thar on domestically produced cars because of the significant amounts of extra work and time loss involved in adapting imported cars to domestic requirements wherever requirements vary between the two countries, with a consequent efiect on prices. The TSG strongly believes that, where they are within the limits of reason, requests for concessions should be given maximum consideration by the Japanese government.
The certification, registration, and homologation issues brought to MOT's attention during informal discussion meetings by the Automotive Task Force żad the current status of these issues are as follows:
Acceptance by the Japanese goverament of U.S. Federal Motor Vehicle Safety Standard certification for equivalent Japanese Traffic Safety and Nuisance Research Institute of Automobile Type. Approval Test Standards in lieu of the massive documentation now required.
Status: Some progress. Although MOT recognizes equivalent standards, test results must be obtained according to Japaneseaccepted test procedures and documentation. MOT believes they cannot rely solely on the test judgement of the applicants.
The term is applied to a vastly inclusive process of making imported vehicles eligible for sale and registration in the market. Also the term is sometimes used as the equivalent of "to be granted as the model Type Approved or Type Certified," which includes completion of all such steps as certification documentation, test reports, actual witaess tests and their reports, subsequent vehicle modification work and reports as the result of pretests and/or witness tests by the designated government officials (MOT).
B. Acceptance by the Japanese government of performance data fo: new products and equipment in lieu of detailed engineering iníor.r.ation, i.e., electronic digital speedometers.
Status: Some progress. MOT will attempt to minimize such re. quirements, but will request this type of information based on their judgement.
C. Acceptance by MOT of representative cars, i.e., car line families for witnessed testing and certification.
Status: Progress has been made in this area, with MOT accepting representative cars, i.e., Mustang for Capri, and T-Bird for Cougar XR-7. This effectively reduces the total cumber of vehi. cles required for presentation to MOT and reduces total workload for certification.
1: ' Vehicle Registration
After manufacturers receive vehicle-type approval, dealers must present each vehicle for inspection prior to registration to ensure compli. ance. (This procedure is not limited to imported vehicles; Japanese cars produced in small numbers as well as modified vehiclės must undergo the same procedure.) With the recent growth in total vehicle imports, dealers are encountering costly delays in registering vehicles. It has been proposed that MOT adopt a sampling technique and eliminate individual inspections,
No progress has been made on this issue.
It should be emphasized that MOT has only agreed to discuss these items informally in order to exchange information and not on a negotiation basis. MOT has recently reiterated its position that any regulatory changes would result only from negotiations with officially recognized organizations such as the Japan Automobile Importers Association or the Motor Vehicle Manufacturers Association. Examples of specific problems in the area of homologation are as follows:
A. Elimination of the need for the installation of a separate low
Status: Potential progress. The current test requirements for parking lamp systems, which includes a 12-hou: test period after which the batie:y must contain sufiicient power to start the car, cannot be met by U.S. or European cars. MOT has indicated a willingness to review the staccards.
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