By Anne Marie Gebhart, Ph.D.

In October 1997, the Japanese government revised its requirements and certification process for plumbing products sold in the East Asian country. Government standards defining minimum testing requirements are now the same across Japan and can be met by international certification organizations.

Third-party mark builds brand
When the Japanese Ministry of Health and Welfare (MHW) established this nationwide standard under the Japanese Water Works Law, foreign-made plumbing products gained further access to the market in Japan. According to this law, so long as plumbing products comply with the national standard, they can no longer be prohibited from being installed due to noncompliance with local or jurisdictional requirements.

However, plumbing distributors, installers and consumers may specify that products also meet the requirements of additional standards. These requirements, such as those specified by the Japanese Industrial Standards (JIS) and the Centre for Better Living (CBL), are typically more stringent than the minimum testing requirements of the government’s MHW and are perceived as providing added value.

Changing Japanese lifestyles appear to be creating a demand for high quality, foreign-made plumbing products. This trend will likely be slow in developing because of the traditional conservatism of Japanese industry and society. Nevertheless, U.S. and Canadian plumbing manufacturers can start building market acceptance now by making Japanese consumers aware of their expanding product options. It may be difficult to compete with more widely known domestic brands if the brand of a foreign manufacturer lacks consumer and user recognition in Japan. To that end, manufacturers may find they can leverage third-party product certification from a known and trusted organization while they build recognition of their products among consumers and users.

New law education
As it became clear the Japanese government would revise the requirements and certification process for plumbing products installed in Japan, UL and its Japanese subsidiary, UL Japan Co. Ltd., entered into discussions with the U.S. Embassy in Tokyo, MHW and plumbing organizations in Japan on the emerging regulations and acceptance of products manufactured outside of Japan into the national market. Few attendees at the Japan Housing/Plumbing Fair in Tokyo in 1998 were aware of the new law allowing organizations other than the Japanese Water Works Association (JWWA) to certify plumbing products in Japan. At the Fair, UL was able to help educate representatives of Japan industry, plumbing contractors and building officials on the value of certified products of U.S. manufacturers.

Drawing a comparison
After translating the new Japanese regulations into English, UL developed a comparison of Japanese plumbing product regulations and standards with those in the U.S. and Canada. UL ran laboratory comparison tests to determine whether differences in testing protocols in the MHW standards resulted in more stringent regulations than those for the U.S. and Canada. Requirements for plumbing products can generally be classified into three categories: 1) Performance criteria; 2) health effects criteria; and 3) lifecycle or durability criteria. The new MHW regulations provide very basic, general standards for performance criteria while they provide much more detailed and definitive criteria for health effects evaluations. Products certified by JWWA are required by the organization to meet additional performance criteria set forth in the JIS and CBL standards.

The results of UL’s laboratory comparison tests showed that products tested against U.S. and Canadian performance standards, in most instances, must comply with more stringent performance criteria than those found in the Japanese standards. Health effects standards are more comparable between the U.S. and Japan, but the specific testing protocols and contaminant levels vary. Table 1 provides a comparison of the health effects criteria for several contaminants. In several of the examples cited, the Japanese criteria are more stringent.

A first in Japan
In April 1998, UL completed its first certifications of U.S.-made plumbing products in compliance with the Japanese Water Work Law. While its test data for electrical products have been accepted in Japan for many years, this was the first time UL evaluated and certified products in any product category in accordance with Japanese standards. UL staff met with JWWA and CBL, as well as plumbing suppliers and contractor groups, to educate them about testing procedures, accreditations and the follow-up program to solicit their acceptance of UL Listed products in Japan. The staff also negotiated with groups responsible for the Japan Common Water Mark to obtain permission to use that recognized mark. The UL certifications issued to Delta Faucet Co. were the first from a non-Japanese third-party certifier to be accepted in Japan.

Expanding markets
Sally Remedios, codes and standards manager with Delta Faucet Co., worked closely with UL staff and others from the company to test and certify these products to both U.S. and Japanese requirements. She said, “UL certifications to the Japan MHW standard have provided Delta Faucet with an entry into the Japanese market for our lines of modified domestic and international faucets. We were extremely pleased with the efforts UL put into translating the standard and, along with the International Council of Building Officials (ICBO), creating a forum through the U.S. Embassy to show Japan the plumbing products that North America has to offer. Masco Japan has been able to use this certification to start into the construction market in Japan.”

Since then, Remedios has joined UL’s Water Advisory Group. “This group provides a two-way dialogue between UL and its industry clients. Clients get to know what UL is planning and have an opportunity to bring issues to the table related to UL’s EPH Program. The Water Advisory Group provides a forum to work jointly on industry issues with other members and present a united front where changes are required from governments, standards developing organizations and others,” she said.

Conclusion
UL Japan Co. Ltd. will continue to work with the Japanese government, the U.S. Embassy and other organizations involved in promoting quality plumbing products in Japan. They will assure that products bearing the organization’s certification mark will clearly meet the standards required there.

About the author
Dr. Ann Marie Gebhart is senior staff toxicologist for Underwriters Laboratories Inc., of Northbrook, Ill. She joined UL in 1999, after serving as executive officer of the American Society for Clinical Nutrition; vice president of Technical Operations for NSF International, and safety assessment supervisor for Parke-Davis Pharmaceutical Research Division/Warner-Lambert Co. She holds a master’s degree in environmental and public health and a doctorate in toxicology, both from the University of Michigan, and is a member of the University of Michigan School of Public Health’s board of governors and the Society of Toxicology. Gebhart can be reached at (847) 272-8800, ext. 41782, or email: [email protected]

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