October 11, 2021

State Administration for Market Regulation(Standardization Administration of the P.R.C.)
Dear Sirs
The Japan Machinery Center for Trade and Investment (“JMC”) is a non-profit
organization with the character of a public-interest corporation. It was established inDecember 1952 in accordance with the Japanese Export and Import Trade Law under theauthorization of the Minister of Economy, Trade and Industry of Japan. The objective of
the JMC is to engage in activities that enhance the common benefit of member companiesand promote the sound development of international trade and investment by themachinery industry. The JMC comprises member companies engaged in machinery andsystems-related exports and foreign investments such as machinery manufacturers,
trading houses and engineering companies. At present, the total number of JMC member
companies is about 240.
Our committee handles environmental and product safety issues of products for tradeand is strongly concerned with overseas environment and product safety-related
regulations on products. From this standpoint, we would like to send the attachedcomment on the draft of National Standard of the P.R.C., Limits of Hazardous Substancesfor Musical Instruments.
If you have any questions, please feel free to contact our secretariat (Mr. ChiakiMorikawa, E-mail: morikawa@jmcti.or.jp).
Sincerely yours,KANNO Yasuhiko
Chairman
Environment Law CommitteeOur comment on the draft of National Standard of the P.R.C.,
Limits of Hazardous Substances for Musical Instruments.
October 11, 2021
Dear Sirs,
We, the Japan Machinery Center for Trade and Investment (JMC), would like to express
our gratitude for your efforts on the consultation document regarding National Standardof the P.R.C., Limits of Hazardous Substances for Musical Instruments.
https://members.wto.org/crnattachments/2021/TBT/CHN/21_5205_00_x.pdf
We are firmly committed to protecting human health, product safety and theenvironment, as well as complying with various regulations as defined by countries
worldwide.
In this spirit, we have carefully and conscientiously examined the proposed document
regarding the National Standard of the P.R.C., Limits of Hazardous Substances forMusical Instruments and would like to offer the following comments toward making theproposed decree more practicable, feasible and permanent, while ensuring appropriate
and sufficient protection of the environment. We would greatly appreciate it if you could
take them into careful consideration.
We are concerned about where this draft is inconsistent with global chemical regulations
that have been established as safe for users and practicable. We believe it would bedesirable for them to be harmonized with such existing standards.
The following comment is based on the draft of the National Standard of the P.R.C.,
Limits of Hazardous Substances for Musical Instruments.

1. Regarding individual requirements
 As for hazardous substances in electronic components (5.6 and 6.6)
Electronic components need exemptions for technically irreplaceable applications. We
would like you to set the same exemption as those in the EU RoHS Directive 1.

1

EU RoHS Directive 2011/65/EU
https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX:32011L0065
2

 As for Polycyclic Aromatic Hydrocarbons (PAH) (5.2, 6.2 and Appendix A)
Sixteen substances of Polycyclic aromatic hydrocarbons (PAHs) are listed in Appendix
A, as opposed to eight substances in the EU REACH Regulation 2 . We believe it isdesirable for them to be harmonized with the EU REACH regulation.
 As for Volatile Organic Compounds (5.4, 6.4, Appendix C, and Appendix D)
The requirements for volatile organic compounds are the same as those in the past (GB/T28489-2012), but similar regulations are unprecedented, and it seems premature to makethem mandatory standards. It may be desirable to keep them at the current recommended
standard.
In addition, the colorimetric analysis method using MBTH specified in the formaldehyde
measurement method is not very common. We would also like you to consider a highperformance liquid chromatography method using a DNPH cartridge that is the current
generally applied test method. As for the measurement method of benzenes and total
volatile organic compounds, we would like you to approve the measurement method aswell according to the international standard ISO for the same reason as the above.
 As for aromatic amine dyes, tetrachlorophenols, and pentachlorophenols (5.5,6.5, and Appendix B)
Twenty-four aromatic amines are listed in Appendix B, which exceed the EU REACH
Regulation. We believe that the same Twenty-two substances as the EU REACH
Regulation 3 are desirable.
Tetrachlorophenol (TeCP) has no existing chemical regulations in articles. It may bedesirable to remove it from the limiting substances.
A 5 mg/kg limit amount for pentachlorophenol (PCP) 4 should be appropriate and is thesame as in the POPs regulations.
2. Regarding Inspection method (7.1, 7.2 and 7.3)
We believe that it is rational to inspect parts and raw materials instead of conducting atype inspection of finished musical instruments.

2EU REACH Annex XVII Entry 50 - Polycyclic-aromatic hydrocarbons (PAH)
https://echa.europa.eu/documents/10162/4f099937-658f-8b86-2f62-5e767fab4d6e
3
EU REACH Annex XVII Entry 43 - Azocolourants - List of aromatic amines
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:02006R190720210825&from=EN:#page=542
4
COMMISSION DELEGATED REGULATION (EU) 2021/277
https://eur-lex.europa.eu/eli/reg_del/2021/277/oj
3For hazardous substances contained in products, we would like you to consider aninspection method for parts and raw materials based on the risk assessment results, suchas IEC63000, and for a method for inspecting Volatile Organic Compounds, we would
like you to approve an inspection method for the part / raw material according to US
TSCA Title VI 5.
3. Regarding the schedule
A sufficient preparation period of at least eighteen months is required, including
evaluation and verification of product design and quality in accordance with the standards,
ordering of alternate materials, mass production, and dealing with the clearance of stock
products that do not comply with the standards.

End5

Formaldehyde Emission Standards for Composite Wood Products
https://www.epa.gov/formaldehyde/formaldehyde-emission-standards-composite-woodproducts4