Pinephone regulatory approval in Japan

[b.tomik]

I have seen the threads on FCC and CE testing where tllim kindly outlined the timing for regulatory approval testing.

I saw no mention of regulation in Japan which has its own regulatory framework... According to this: https://www.quectel.com/product/eg25g.htm the modem is apparently TELEC (Japanese approvals agency) approved already.

I understand that Japan may not be the largest target market, but I have chatted with a few individuals who are very interested in acquiring a pinephone but will not do so unless the Technical Conformity Mark 　[in Japanese 技適 (giteki)]  is present somewhere on the device. Without this approval using the phone may be technically illegal or at least possibly so.

Could anyone from Pine64 kindly clarify the status of regulatory approval in Japan? If said regulatory testing has not yet been applied for, are there plans to do so and if so, is there any expected timeframe?

From my research, I have discovered that even devices that have not passed the regulatory framework can be used for development / experimental purposes for up to 180 days while testing is carried out so long as this "experimental" use is expressed to the appropriate authority - getting this experimental use licence is free of charge; although unfortunately I don't know about the price of the Technical Conformity Mark certification.

I live in Japan and am quite concerned that I may have to cancel my Braveheart order and that if this hurdle is not passed, and that myself and others will not be able to use the pinephone in the future either. This in turn might hinder the progress of multilingual support in the future with fewer language-specific bug reports being posted etc.

Some indication of what the future holds would be very much appreciated, and if approval is on the way, I'll be sure to spread the message as far and wide as I can.

In case they are useful, I found the following resources which have some information about applications / rules etc.:

TELEC site (in English) for application procedures https://www.telec.or.jp/eng/services/ter...index.html

Telecommunications Bureau of the Ministry of Internal Affairs and Communications which details some things about mobiles (in English) https://www.tele.soumu.go.jp/e/adm/monit...mobile.htm

[fire219]

The current plan for regulatory testing is to get testing done for FCC and CE marks, but not for the single country tests.

This isn't due to lack of interest in certain markets, it's simply cost prohibitive for P64 to put the devices through all these tests. For example, the FCC/CE testing alone costs $50k. Due to the low profit margins that the business side of P64 runs on, it just is not feasible to go through all the worldwide testing.

If regulatory conformity beyond FCC/CE is necessary for you to buy a PinePhone, unfortunately you may have to pass on it.

[TG127]

I’m not exactly sure what it says, as I’m not that great at Japanese, but I found this site http://welte.jp/ca7/170/ .
It seems like they would import the PinePhone for you, but they ask for more money. Not entirely sure though. Hope this helps in some way.

[b.tomik]

The current plan for regulatory testing is to get testing done for FCC and CE marks, but not for the single country tests.

This isn't due to lack of interest in certain markets, it's simply cost prohibitive for P64 to put the devices through all these tests. For example, the FCC/CE testing alone costs $50k. Due to the low profit margins that the business side of P64 runs on, it just is not feasible to go through all the worldwide testing.

If regulatory conformity beyond FCC/CE is necessary for you to buy a PinePhone, unfortunately you may have to pass on it.

Thank you very much for the prompt and informative response. I can understand the policy decision and think that it's quite reasonable given the budgetary constraints and the myriad of single country certifications that would be required for a fully global device. Doing some research, I discovered that even the big industry smartphone makers release unique models in the Japanese market to avoid needing said certification in other markets.

In practice, many people in Japan buy phones from other countries and use them back in Japan with no real issues; although this is technically wrong. Indeed you can even buy foreign phones on Amazon Japan. As it turns out, I bought my previous smartphone from Amazon Japan and it (Galaxy note 8) is also not certified for use in Japan - despite still being in use here every day! 

It is very helpful to know the Pine64 official direction, so people don't sit around waiting for certification that is not coming and make their decisions either way. Therefore would-be Pinephone buyers in Japan will have to proceed at their own risk. It is a shame that the lack of certification will dissuade some would be users and contributors to the project, but nothing is perfect, and at least this forum discussion could act as a clear point of reference.

@TG127 - thanks for the link; unfortunately it doesn't matter who imports or sells the phone (these activities are allowed), the risk lies with the end-user choosing to use the device in Japan. So any would-be buyers who are happy to proceed despite the certification issue can go ahead and do so directly from Pine64 as usual.

Also as a side note, although I'm sure you don't need my advice here; Pine64 is not doing anything wrong by selling / shipping to Japanese customers, as users are  free to buy foreign devices legally and do so frequently.

[FutureBucket]

In practice, many people in Japan buy phones from other countries and use them back in Japan with no real issues; although this is technically wrong. Indeed you can even buy foreign phones on Amazon Japan. As it turns out, I bought my previous smartphone from Amazon Japan and it (Galaxy note 8) is also not certified for use in Japan - despite still being in use here every day! 

こんにちは!

Is their the same restrictions on foreigners visiting Japan? I was in Tokyo for 2 weeks in April 2019 and had no problem using my phone with a data only sim. Now I'm kind of worried if I go back and I bring the PinePhone... will it work or would I need to get a Japanese Phone?


また...私... 日本 は とても きす です!!!!!

[b.tomik]

こんにちは!

Is their the same restrictions on foreigners visiting Japan? I was in Tokyo for 2 weeks in April 2019 and had no problem using my phone with a data only sim. Now I'm kind of worried if I go back and I bring the PinePhone... will it work or would I need to get a Japanese Phone?


また...私... 日本 は とても きす です!!!!!

こんにちは！

Thankfully the Japanese government is rather practical about this, especially with the upcoming olympics - so, foreigners have no restrictions and can use whatever device they like for up to (I think) 90 days.

It's not unique to the PinePhone though, pretty much all android phones not sold in the Japanese market similarly lack the necessary certification so it would be essentially impossible to enforce a more restrictive policy.

Long and short of it is, if you're a resident - be careful; if you're a visitor - anything goes.

私も好きですので、日本に住んでいます！

[FutureBucket]

こんにちは！

Thankfully the Japanese government is rather practical about this, especially with the upcoming olympics - so, foreigners have no restrictions and can use whatever device they like for up to (I think) 90 days.

It's not unique to the PinePhone though, pretty much all android phones not sold in the Japanese market similarly lack the necessary certification so it would be essentially impossible to enforce a more restrictive policy.

Long and short of it is, if you're a resident - be careful; if you're a visitor - anything goes.

私も好きですので、日本に住んでいます！

Whoops, I made a mistake... it's suki(好き/すき), I had typed it backwards (kisu).

Thank you for the information!! I know it's kind out out of place for this forum but I really wanted to ask. I plan to go back to Japan and I always do my best to be respectful and follow the laws. I even studied Japanese for ~8 months before I went so I could better find my way around and ask the police for directions or help in Japanese.


I hope you get to enjoy the PinePhone with the rest of us! I've been on here pretty much daily looking for updates and following Manjaro ARM. I have the PineBook Pro, PinePhone and PineTime all coming Now that I think about it, I've never actually looked up the Canadian Laws on this. I guess I assumed stuff approved in the USA is good up here too...



どうも ありがとうございました!
げんきでね!

[mini-DIN]

I am neither a lawyer nor an engineer, but if someone were to ask me to prove that my phone can be used in Japan, I would just pop the back cover off and point to the giteki mark on the modem.

As a consumer, I purchased a device with the mark on it.

[MikeMan]

I am neither a lawyer nor an engineer, but if someone were to ask me to prove that my phone can be used in Japan, I would just pop the back cover off and point to the giteki mark on the modem.

As a consumer, I purchased a device with the mark on it.

I'm inclined to agree. The Japanese authorities have a fairly 'common sense' approach to such things and, God Love 'Em, almost never set out to find trouble for trouble's sake. lololol Just don't mess with the immigration laws!

[ngkz]

I am neither a lawyer nor an engineer, but if someone were to ask me to prove that my phone can be used in Japan, I would just pop the back cover off and point to the giteki mark on the modem.

As a consumer, I purchased a device with the mark on it.

The giteki mark on the modem is invalid because PinePhone uses a non-certified antenna. The giteki is issued against a pair of the antenna and the modem.  Also the giteki of EG25-G doesn't cover Bluetooth and Wi-Fi.

To comply PinePhone with Japanese regulatory, PINE64 or the importer need to do:

• Obtain Gijyutsu kijyun tekigō shōmei(技術基準適合証明) per device or Kōji sekkei ninsyo(工事設計認証) per model for 6 bands(W-CDMA, HSDPA, FDD-LTE, TD-LTE, 2.4GHz Wi-Fi, Bluetooth)
  The modem will pass the giteki test without doubt, but I'm not sure WiFi+BT chip (RTL8723CS) supports the Giteki test pattern, which is different from the FCC test pattern.
  The giteki requires the device to be impossible to easily modify to increase output power, so RTL8723CS and its peripheral circuit may have to be covered with a soldered shield, like the modem.
  
• Obtain Gijyutsu kijyun tekigō nintei (技術基準適合認定)
  This is required by the terms and conditions of Japanese phone carriers.
  
• Show the giteki label on the device or operating system
  
• Verify EG25-G and RTL8723CS firmware updates don't change radio characteristics.
  
• Provide repair service (optional)
  The giteki certified device must be repaired by the manufacturer or MIC authorized repairer. Otherwise, the giteki will void.
  I don't think MIC authorized repair shops repair this exotic device.
  
• Comply product liability act (if the importer slaps giteki label on the device and resell)
  If PinePhone injured someone or damaged something, the importer must compensate for the damage due to the PL Act. The importer should take out PL insurance.
  

Since the cost of the giteki for 4G device is expensive and there aren't many Japanese PinePhone users, it won't likely happen.

Fortunately, MIC has not been actively cracking down on illegal Cellular/Wi-Fi/Bluetooth devices. You can just give MIC a middle finger and use your PinePhone. Cops may exploit your PinePhone for arrest on a separate charge, through.