Sectoral Study:
Standards, technical regulation andconformity assessment in the Japanese andEuropean offshore wind power market:
current implementation and best practices
July 2022

Project reference: EuropeAid/139634/DH/SER/JP
Support facility for the implementation of EU-Japan
Economic Partnership Agreement (EPA)

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices.2

Disclaimer This document has been prepared for the European Commission by the Technical University ofDenmark, Department of Wind and Energy Systems (Society, Markets and Policy Section), and the Renewable
Energy Institute, Japan, with the support of SD Policies Limited and Development Solutions Europe Ltd. The
study is part of the Support Facility for the implementation of the EU-Japan Economic Partnership Agreement(EPA). It reflects the views only of the authors, and the Commission cannot be held responsible for any use
which may be made of the information contained therein.

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices.3

TABLE OF CONTENTS
1

Background and scope of the study ...............................................................................................................8
1.1

Purpose ....................................................................................................................................................................................................8

1.2

Scope ........................................................................................................................................................................................................8

1.3

Approach .................................................................................................................................................................................................8

1.4Structure .................................................................................................................................................................................................82

International standards organisation ...........................................................................................................93

Overview of Japanese OWP technical regulations and standards .................................................. 11
3.1

Laws and Regulations ..................................................................................................................................................................11

3.1.1

Electricity Business Act ..................................................................................................................................................................................... 11

3.1.2

Port and Harbour Act ......................................................................................................................................................................................... 12

3.1.3

Ship Safety Act (for floating) ........................................................................................................................................................................ 12

3.1.4

Act on Promoting the Utilization of Sea Areas for the Development of Marine Renewable Energy Power

Generation Facilities and Port and Harbour Act .................................................................................................................................................. 12
3.1.5

3.2

Standards ............................................................................................................................................................................................14

3.2.1

ISO/IEC and JIS ...................................................................................................................................................................................................... 14

3.2.2

Transition to IECRE and Japan's response............................................................................................................................................ 16

3.3“Official Explanation” ....................................................................................................................................................................17

3.3.1

Official Explanation of Technical Standards for Offshore Wind Power Generation Facilities .............................. 17

3.3.2

Official Explanation of Operation and Maintenance for Offshore Wind Power Generation Facilities ............ 20

3.3.3

The role of standards in the technical regulations ......................................................................................................................... 20

3.4

4

Building Standards Act ..................................................................................................................................................................................... 13

Examinations on technical regulations and third-party certification procedures ......................................21

3.4.1

Examination under the Electricity Business Act ................................................................................................................................ 22

3.4.2

Examination under the Port and Harbour Act .................................................................................................................................... 26

3.4.3

Examination under the Ship Safety Act and Classification survey ....................................................................................... 28

International and European standards ...................................................................................................... 31
4.1

Overview of the structure for international and European standardisation .................................................31

4.1.1

Mirror committees in the international standardisation work ................................................................................................. 31

4.1.2

Adoption of international standards ........................................................................................................................................................ 33

4.2

Overview of EU standards, certification and technical regulation ......................................................................33

4.2.1

EU Legislation......................................................................................................................................................................................................... 33

4.2.2

Certification in the EU ....................................................................................................................................................................................... 35

4.2.3

Elements of project certification ................................................................................................................................................................ 37

4.2.4

Site investigations ............................................................................................................................................................................................... 39

4.2.5

Site-specific assessment of loads and load cases ......................................................................................................................... 41

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices
4.2.6

5

Steel standards in Europe ............................................................................................................................................................................... 43

Comparison between Japanese and European standards and regulations .................................. 44
5.1

Differences between Japanese and European practices..........................................................................................44

5.1.1

Project Certification ("Wind Farm Certification") and Permitting............................................................................................ 45

5.1.2

Site investigations ............................................................................................................................................................................................... 47

5.1.3

Seismic Load evaluation .................................................................................................................................................................................. 49

5.1.4

Materials .................................................................................................................................................................................................................... 49

5.2
6

.4

Best practices identified that may be relevant for Japan .......................................................................................50

Accreditation procedures and certification system for conformity assessment bodies inJapan ............................................................................................................................................................................... 53

7

6.1

Procedures for accreditation of conformity assessment bodies .........................................................................53

6.2

Outline and activities of the accredited body in Japan.............................................................................................54

6.3

Conformity assessment practice............................................................................................................................................55

6.3.1

The modules of Wind farm certification................................................................................................................................................ 55

6.3.2

Issues related to the practice ....................................................................................................................................................................... 57

Accreditation procedures and certification system for conformity assessment bodies in the

EU 58
7.1

System for conformity assessment in the EU ................................................................................................................58

7.1.1

Accreditation bodies and their organisation ....................................................................................................................................... 59

7.1.2

The procedure of accreditation in European countries ................................................................................................................. 60

7.1.3

Certification bodies in Europe ...................................................................................................................................................................... 61

7.1.4

Certification activity for offshore wind in Europe ............................................................................................................................ 61

7.1.5

International recognition of conformity assessment bodies .................................................................................................... 63

7.2

Best practices identified that may be relevant for Japan .......................................................................................64

REFERENCES .................................................................................................................................................................. 66
APPENDIX A ................................................................................................................................................................... 68
APPENDIX B ................................................................................................................................................................... 70

LIST OF TABLES
Table 1 Major international and domestic standards for wind power generation systems .....................................14
Table 2 IECRE Certification Bodies in the Wind Energy Sector .................................................................................................16
Table 3 Ship inspections based on the Ship Safety Act ................................................................................................................30
Table 4 General certification requirements for offshore wind in key European countries .......................................35
Table 5 Examples of design load cases related to power production from IEC 61400-3-1 ...................................42
Table 6 Overview of similarities and difference identified in the technical regulation and use of standards inJapan and Europe: ...............................................................................................................................................................................................44
Table 7 Accreditation body for each major country leading offshore wind development in Europe ..................59

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices.5

Table 8 Certification bodies in Europe ....................................................................................................................................................61
Table 9 Total number of valid certifications for each certification body............................................................................62
Table 10 Total number of valid certifications per certification type .....................................................................................62

LIST OF FIGURES
Figure 1 Structure of IEC ...............................................................................................................................................................................10
Figure 2 Scope of the Electricity Business Act, Port and Harbour Act, and Ship Safety Act ....................................13
Figure 3

Flow of examination and the application of the Official Explanation of Technical Standards (in red

frame) .........................................................................................................................................................................................................................19
Figure 4 Flow of examination and application of the Official Explanation of Operation and Maintenance (inred frame) ................................................................................................................................................................................................................20
Figure 5 Adoption of technical standards at the initiative of private sector ...................................................................21
Figure 6 Current review process for conformity assessment in construction plans for OSW ................................23
Figure 7 Comparison between current and new review process for conformity assessment in constructionplans for OSW ........................................................................................................................................................................................................25
Figure 8 Unification of the procedure of conformity verification under the Port and Harbour Act and a thirdparty certification for wind power generation facilities .................................................................................................................27
Figure 9 Compliance with laws and regulations for offshore wind turbines ...................................................................29
Figure 10 The case of Danish Standard organization ..................................................................................................................32
Figure 11 Typical European project certification phases ............................................................................................................38
Figure 12 Information required for the load analysis ...................................................................................................................41
Figure 13 Examples of seabed condition (upper: Tsugaru Strait, lower: English channel) .......................................48
Figure 14 Wind farm certification modules and flow ...................................................................................................................56
Figure 15 Flow of the review of ClassNK certification related to the RNA (upper) and the support structure(lower) .........................................................................................................................................................................................................................57

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices

LIST OF ABBREVIATIONSACDApproved for Committee Draft

ACDVApproved for CDV

AfN

Accreditation for Nofitication

BELAC

Belgian Accreditation Body

CAB

Conformity Assessment Board

CABs

Conformity Assessment Bodies

CC

Component Certificate

CD

Draft circulated as Committee Draft

CDIT

Coastal Development Institute of Technology

CDV

Committee Draft for Vote

CEN

European Committee for Standardisation

CENELEC

European Committee for Electrotechnical Standardization

CGC

China General Certification Center

COFRAC

French Accreditation Body (Comité français d'accréditation)

CPT

Cone Penetration Test

CS

Design evaluation and conformity statement

DAkkS

German Accreditation Body (Deutsche Akkreditierungsstelle)

DANAK

Danish Accreditation Body (Danske Akkrediteringsfond)

DIS

Draft International Standard

DLC

Design Load CaseDS

Danish Standards

DTU

Technical University of Denmark

EA

European Accreditation

EIA

Environmental Impact Assessment

EN

European Standards

ETSI

European Telecommunications Standards Institute

EXCO

Executive Committee

FDIS

Final Draft International Standards

IACS

International Association of Classification Societies

IAF

International Accreditation Forum

IEC

International Electrotechnical Commission

IECRE

IEC conformity assessment framework for renewable energy

ILAC

International Laboratory Accreditation Cooperation

IPAC

Portugal's national accreditation body (Instituto Português de Acreditação)IS

International Standards.6Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices

ISO

International Organisation for Standardisation

JAB

Japan Accreditation Board

JEMAJapan Electrical Manufacturers' Association

JIS

Japanese Industrial Standards

JISC

Japanese Industrial Standards Committee

LRFD

Load and Resistance Factor Design

METI

Ministry of Economy, Trade and Industry

MLA

Multilateral Agreement

MLIT

Ministry of Land, Infrastructure, Transport and Tourism

MT

Maintenance TeamNANDO

New Approach Notified and Designated Organisations

NSBs

National Standards Bodies

Ods

Operational Documents

OSW

Offshore Wind

OWP

Offshore Wind Power

PCC

Preparation of Compilation of Comments

PT

Project TeamREI

Renewable Energy Institute

RFDIS

FDIS received and registered

RPUB

Publication received and registeredRVA

The Netherlands national accreditation body (Raad voor Accreditatie)SC

Sub committee

SMB

Standardization Management Board

SPT

Standard Penetration Test

SWEDAC

Swedish Board for Accreditation and Conformity Assessment

TC

Technical Committee

TP

Type Certificate

TS

Technical Specification

UKAS

National Accreditation Body for the United Kingdom

WG

Working Group.7

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices.8

1 Background and scope of the study
1.1 Purpose
The purpose of the study is to give an overview of the current standards, technical regulations, and conformity
assessment applicable for offshore wind in Japan, compare it with European use of standards and technicalregulation in the area, and identify some areas of best practice that are potentially relevant for the Japanesemarket.

1.2 Scope
The scope of the study comprises standards and technical regulations in relation to type certification,
component certification, as well as project certification. It includes third-party conformity assessment byaccredited certified bodies and the processes and regulation in regard to accreditation. It deep dives into theareas that are most relevant for the Japanese market right now. It aims as capturing the whole life cycle ofprojects, but with an emphasis on the design and permitting phases. Mostly, the scope is on bottom-fixedoffshore wind, floating wind is mentioned where relevant and possible. European countries analysed forcomparison are France, Germany, Denmark, Belgium, Netherlands, UK (and wherever relevant also Portugal).
Compliance to other local regulations, such as environmental impact assessment, administrative permitting
procedures, fishing rights, etc. are out of scope of this analysis.

1.3 Approach
The study is undertaken as independent research project by the Technical University of Denmark (DTU) and
Renewable Energy Institute (REI), with funding by the European Commission through a contract with
consultancy firm Development Solutions. The study approach comprises (1) desktop research and analysis
of official documents, regulations, industry standards and process documents, scientific literature, as well aspress releases and other ‘grey literature’ in English, Japanese, and additional European languages; (2) Morethan ten interviews with relevant stakeholders in Japan and Europe, from which notes were taken andaggregated insights are included in the report.

1.4 Structure
The study is structured in two major parts: the first part (chapters 1-5) deals with technical regulations andstandards, and the second part (chapters 6-7) deals with accreditation procedures and certification systemfor conformity assessment bodies. In each part, we first give a broad introduction to the topic, then describe
the Japanese and European system, respectively. We then highlight some differences between the twosystems, and then identify best practices from Europe that may potentially be relevant for Japan.

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices.9Part I Technical regulations and standards

2 International standards organisation
The ISO (International Organisation for Standardisation) is a worldwide federation of national standards
bodies from more than 160 countries. ISO members collaborate in the development and promotion ofinternational standards for technology, scientific testing processes, working conditions, societal issues andmore (ISO, 2022). ISO and its members then sell documents detailing these standards. The International
Electrotechnical Commission (IEC) is a separate international standards body that establishes standards. It
works closely together with ISO. Standards that the ISO and IEC jointly develop are identified by the prefix
ISO/IEC.
For offshore wind energy, the IEC standards describe the design requirements of offshore wind turbines andwind farms as well as measurable requirements, reliable tests and reproducible methods. They are
documented in the IEC 61400 series. Standards are used for design, construction, testing, inspection,
performance, operations, and maintenance monitoring, etc. Standards are important to make sure that an
offshore wind farm is safe, reliable and performs as expected.
Standards can be useful for industry in itself and can work as voluntary industry practices. In many cases, adocumentation on compliance with standards is desired or necessary (e.g., from business contract partners
or regulation). In this case, an external conformity assessment is undertaken. In the end of a successful
conformity assessment process (certification process), a conformity certificate is issued. Standards andconformity assessment are mutually dependent as conformity assessment refers to the applicable standards
to draw conclusions. ISO/IEC as organisations do not undertake conformity assessments or issue certificateson any particular product or project themselves – they are concerned with defining the rules and proceduresof such activities. For this, IEC has a Committee on Conformity Assessment that works on standards related
to the certification process. In 2010 the IEC issued the IEC 61400-22 standard to provide a framework forwind energy conformity assessment and testing. Initially, third-party conformity assessment was provided bycertification bodies using their own conformity procedures, and rules - to fill in gaps in the standards andalign to common structural design review from other industries (e.g., ships, buildings, etc.). The establishmentof the IEC conformity assessment framework for renewable energy (IECRE) and its Operational Documents(ODs) in 2014 mitigated this and provided transparency and consistency for the assessment. Consequently,
IEC 61400-22 has been withdrawn with effect from 1st of September 2018. However, this does not meanthat conformity assessment based on IEC 61400-22 has stopped. IECRE wind certification schemes OD-501
and OD-502 still need to be properly implemented internationally, and many regulations still refer to IEC
61400-22.

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 10

The organisation in IEC including the relation between standards and conformity assessment work is
illustrated in the figure below.

Figure 1 Structure of IEC
Source: ARESCA, American Renewable Energy Standards and Certification Association

The establishment of an international standard for conformity assessment / certification processes under the
IECRE enabled multilateral recognitions agreements, which are today frequently used, especially on type andcomponent certification. Countries participate in ISO/IEC work via national standards bodies (NSBs), as wellas through input received from liaison organisations. National positions on ISO/IEC work are developed by
the NSBs on an ongoing basis.
Relevant Technical Committees (TC) in the ISO/IEC structure are e.g. the ‘IEC TC 88 Wind Energy Generation
Systems’, the ‘ISO TC60 Gear’ and the ‘IEC TC 14 Power Transformers’.
Relevant IEC standards (all handled within the TC88):▪

IEC 61400-1 Design requirements▪

IEC 61400-2 Small wind turbines▪

IEC 61400-3 Design requirements for offshore wind turbines▪

IEC 61400-4 Gears for wind turbines▪

IEC 61400-(5) Wind Turbine Rotor Blades▪

IEC 61400-11, Acoustic noise measurement techniques▪

IEC 61400-12-1 Power performance measurements

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices▪

IEC 61400-13 Measurement of mechanical loads▪

IEC 61400-14 Declaration of sound power level and tonality▪

IEC 61400-21 Measurement of power quality characteristics▪

IEC 61400-22 Conformity Testing and Certification of wind turbines▪

IEC 61400-23 TR Full scale structural blade testing▪

IEC 61400-24 TR Lightning protection▪

IEC 61400-25-(1-6) Communication▪

IEC 61400-26 TS Availability▪

IEC 61400-27 Electrical simulation models for wind power generation. 11

Related IEC standards waiting for publication are as below: They will be expectedly published between July
2022 to May 2023.
▪

IEC61400-50: Wind measurements (publishing schedule 2022-07)▪

IEC61400-50-1: Wind measurements application of meteorological mast, nacelle and spinner
mounted instruments (publishing schedule 2022-07)▪

IEC61400-50-2: Wind Measurement - Application of Ground Mounted Remote Sensing Technology(publishing schedule 2022-07)▪

IEC61400-50-4: Use of floating lidars for wind measurements (publishing schedule 2023-05)

3 Overview of Japanese OWP technical regulations and standards
3.1 Laws and Regulations
Among the laws and regulations related to offshore wind power in Japan, the main ones concerning technicalstandards are presented in the subsections below. Offshore wind farms are required to comply with thetechnical regulations set by each Act.
3.1.1

Electricity Business Act

Offshore wind power generation facilities fall under the category of Electric Facilities for Business Use under
the Electricity Business Act (Article 38, Paragraph 2 of the Electricity Business Act). Electric Facilities for
Business Use shall conform to the technical standards established by Ordinances of the Ministry of Economy,

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 12

Trade and Industry (METI) (Article 39)12.
3.1.2

Port and Harbour Act

The Support structures for offshore wind power generation facilities are mooring facilities where vessels formaintenance come ashore, and therefore must conform to the technical regulations for port facilities under
the Port and Harbour Act and the related ministerial ordinance established by the Ministry of Land,
Infrastructure, Transport and Tourism (MLIT) (Article 56-2-2).
3.1.3

Ship Safety Act (for floating)

Floating offshore wind facilities are classified as "special vessels" under Article 1, Paragraph 4 of theOrdinance for Enforcement of the Ship Safety Act and are subject to safety regulations based on this Act3.
3.1.4

Act on Promoting the Utilization of Sea Areas for the Development of Marine
Renewable Energy Power Generation Facilities and Port and Harbour Act

When offshore wind power generation facilities are installed in the Promotion Zones for the Development ofMarine Renewable Energy Power Generation Facilities (hereinafter, the Promotion Zone) under the Act on
Promoting the Utilization of Sea Areas for the Development of Marine Renewable Energy Power Generation
Facilities (hereinafter, the Renewable Energy Sea Area Utilization Act), the project details are described in the
Exclusive Occupancy and Use Plan over Public Bidding (hereinafter, the Exclusive Occupancy and Use Plan).
The offshore wind power generation facilities and maintenance methods described in the Exclusive
Occupancy and Use Plan must conform to the technical regulations specified by the ordinances of METI and
MLIT (Article 15, Paragraph 1, Item 3 of the Renewable Energy Sea Area Utilization Act). Article 5 of theordinance for enforcement of this act specifically defines the regulatory standards, and the MLIT’s
Notification defines the performance requirements, basics of performance verification and settings, among
others4.
When offshore wind power generation facilities are installed in the areas to be occupied in the waters within
the port limits, etc. under the Port and Harbour Act, the details of the project are described in the occupancy
plan for public tender. The facilities put out to public tender and their operation and maintenance methods
must conform to the technical regulations specified by an ordinance of MLIT (Article 37-5, Paragraph 1, Item

Specifically, there is the "Ministerial Ordinance Establishing Technical Standards for Electrotechnical Technology" that
establishes standards for general electrical safety, and the "Ministerial Ordinance Establishing Technical Standards forWind Power Equipment for Electricity Generation" that establishes standards for the safety performance of wind turbinesand supporting structures.
2
In general, technical regulations in the Electricity Business Act are performance requirements, that are clear but
abstract. Hence, METI provides "Interpretations" that indicate specific means and numerical values to meet thosestandards, "Commentaries" explaining the background of ministerial ordinances, the "Interpretation," and supplementary
information on the interpretations. This characteristic of technical regulation related to OSW is the same as in other acts
and the competent authorities publish explanative documents for these acts as well.
3
The contents of Technical Standard for Floating Offshore wind Power Generation Facilities related to the issues coveredin this report are shown in Appendix C.
4
Public Notice of Necessary Matters Concerning Standards for Offshore Renewable Energy Power Generation Facilities
or Methods of Maintenance and Management Thereof1Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 13

3 of the Port and Harbour Act).
3.1.5

Building Standards Act

In 2007, the safety regulations of the Building Standards Act were imposed on support structures for wind
power generation facilities with hub heights exceeding 60 m, requiring performance evaluation by adesignated performance evaluation body and approval by MLIT. Subsequently, in 2014, the regulations wereconsolidated from separate assessments based on the Building Standards Act and the Electricity Business
Act to safety regulations based on the Electricity Business Act, on the assumption that regulations equivalent
to those of the Building Standards Act would be imposed.
Therefore, the Building Standards Act is now not directly applied to offshore wind power generationequipment. However, because of this historical background, the provision of Article 37 of the BuildingStandards Act and related public notices are referenced with regard to materials and components used in
offshore wind power generation equipment.
Specifically, Article 10, Item 9 of the Interpretation of Article 7 of the Ministerial Ordinance Establishing
Technical Standards for Wind Power Equipment for Electricity Generation requires conformity to the JIS
standards in Appended Table 1 of Notification No. 1446 of the Ministry of Construction in 2000, and its
commentary states that "In the case where materials that have been approved by MLIT under Article 37, Item
2 of the Building Standards Act or materials that have mechanical properties, scientific components andother qualities equivalent or superior to those of materials conforming to the Japanese Industrial Standards
are used, they are deemed to conform to Article 7 of the Ministerial Ordinance”5.
Electricity Business Act（entire wind turbine facilities）

OnshoreGravity BaseMonopile

JacketBottom fixedSemi-submersible

Floating

Spar
Tension Leg

Ship Safety Act（Tower, Floating structure,
Mooring systems）

Port and Harbour Act（entire wind turbine facilities）

Figure 2 Scope of the Electricity Business Act, Port and Harbour Act, and Ship Safety Act

5 "Annotations of the Explanation of the Ministerial Ordinance Establishing Technical Standards for Wind Power
Generation Facilities and Interpretation Thereof" (p. 20).

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 14

Source: created by REI based on ClassNK, “Wind Turbine Certification and Related Services” p.276

3.2 Standards
3.2.1

ISO/IEC and JIS

Japanese Industrial Standards (JIS) are established in accordance with ISO (International Organization forStandardization) and IEC (International Electrotechnical Commission) standards. ISO and IEC are applied inJapan as they are, but to facilitate their application in Japan, the major ones that are expected to be usedwidely in the country are incorporated into JIS standards. Specifically, the Japanese Industrial Standards
Committee (JISC) deliberates on JIS drafts proposed by related organizations, and the competent ministerestablishes or revises them. However, due to translation into Japanese and the addition of supplementary
explanations, new or updated JIS standards are not established or updated until several years after the
ISO/IEC standards are changed7. Supplementary explanations include explanations of terms that are not incommon use in Japan and addition of references to the national standards (e.g., earthquakes) where thestandards indicate to do so.
For wind energy generation systems, the Japan Electrical Manufacturers Association (JEMA) has establisheda technical committee on wind energy generation systems as a domestic deliberative body for IEC/TC88(Technical committees 88), which deliberates, proposes, and votes on approval of draft international
standards, and prepares draft JIS for the domestic market.
Based on a proposal from Japan, in IEC61400-1 ED4.0 (Design requirements), in addition to the existing windturbine classes (I, II, III, and S), Class T (Tropical) was added as a requirement for Japan and Southeast Asia,
where typhoon attacks and turbulent flow intensity are significant. In IEC61400-24 ED2.0 (Lightning
protection), in addition to the existing requirements of 150 and 300 coulombs, a new requirement of 600
coulombs has been added for regions with high lightning energy.

Table 1 Major international and domestic standards for wind power generation systems
Title

IEC

Current

JIS

stage
Wind energy generation systems - Part 1: Design

IEC 61400-1 Ed. 4:2019

ISrequirements
Wind turbines - Part 2: Small wind turbines

JIS C 1400-1:2017
JIS C 1400-1:20XX

IEC 61400-2 Ed. 3:2013

IS

JIS C 1400-2:2020

https://www.classnk.or.jp/hp/pdf/authentication/renewableenergy/en/RD2101_202108_Eng.pdf
To speed up the information dissemination after the ISO/IEC publishment, some operational reforms are underdiscussion, including publishing Technical Specification/Technical Reports earlier than the enactment of JIS standards.
(METI, Japanese Industrial Standards Committee, Basic Policy Committee, “Draft Interim Report” (May 30, 2022)
https://www.jisc.go.jp/app/jis/general/GnrRoundList?toGnrDistributedDocumentList )67

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices
Wind energy generation systems - Part 3-1: Design

IEC 61400-3-1 Ed. 1:2019

ISrequirements for fixed offshore wind turbines. 15

JIS C 1400-3-2014
JIS C 1400-3-1:20XX

Wind energy generation systems - Part 3-2: Design

IEC TS 61400-3-2 Ed.

TS

JIS C 1400-3-2:20XX

requirements for floating offshore wind turbines

1:2019Wind energy generation systems - Part 3-2: Design

IEC 61400-3-2 Ed. 1

PCC―

Wind turbines - Part 4: Design requirements for wind

IEC 61400-4 Ed. 1:2012

IS―

turbine gearboxes

IEC 61400-4 Ed. 2

PCC

Wind energy generation systems - Part 5: Wind turbine

IEC 61400-5 Ed. 1:2020

IS

IEC 61400-6 Ed. 1:2020

IS

IEC 61400-8 Ed.1

PCC―

Wind energy generation systems - Part 12-1: PowerIEC 61400-12-1 Ed. 2:2017

IS

JIS C 1400-12-1:2010

performance measurements of electricity producing wind

IEC 61400-12-1 Ed. 3

RPUB

JIS C 1400-12-1:20XXIS

JIS C 1400-12-2:20XX

requirements for floating offshore wind turbines―

bladesWind energy generation systems - Part 6: Tower and

JIS C 1400-6:20XX

foundation design requirements
Wind energy generation systems - Part 8: Design of windturbine structural components

turbines
Wind turbines - Part 12-2: Power performance ofIEC 61400-12-2 Ed. 1:2013

electricity-producing wind turbines based on nacelleIEC 61400-12-2 Ed. 2

RPUB

anemometry
Wind turbines - Part 13: Measurement of mechanical loads

IEC 61400-13 Ed. 1.1 :2021

IS

Wind turbines - Part 22: Conformity testing and certification

IEC 61400-22 Ed. 1:2010

IS

JIS C 1400-22:2014(remains effective)（abolished in August 2018）

Wind turbines - Part 23: Full-scale structural testing of rotor

IEC 61400-23 Ed. 1:2014

IS

bladesIEC 61400-23 Ed. 2

ACD

Wind energy generation systems - Part 24: Lightning

IEC 61400-24 Ed. 2:2019

ISprotection
Wind energy generation systems - Part 30: Safety of Wind――JIS C 1400-24:2014
JIS C 1400-24:20XX

IEC TS 61400-30 Ed. 1

PCC―

IEC 61400-50 Ed. 1

RPUB

―

IEC 61400-50-1 Ed. 1

RFDIS

―

Turbine Generator Systems (WTGs) - General principles fordesignWind energy generation systems - Part 50: Wind
measurements
Wind energy generation systems - Part 50-1: Wind
Measurement - Application of Meteorological Mast, Nacelleand Spinner Mounted Instruments

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices
Wind energy generation systems - Part 50-2: Wind

IEC 61400-50-2 Ed. 1

. 16

RPUB

―

IEC 61400-50-3 Ed. 1:2022

IS―

IEC 61400-50-4 Ed. 1

ACD―

IEC 61400-101 Ed. 1

ACD―

Measurement - Application of Ground Mounted Remote
Sensing Technology
Wind energy generation systems - Part 50-3: Use of
nacelle-mounted lidars for wind measurements
Wind energy generation systems - Part 50-4: Use offloating lidars for wind measurements
Wind energy generation systems - Part 101: General
requirements for wind turbine plants
Note: Letters in italic means under deliberation
IS: International Standards, TS: Technical Specification, RPUB: Publication received and registered, FDIS: Final Draft International
Standards, RFDIS: FDIS received and registered, ACDV: Approved for CDV, CDV: Committee Draft for Vote, ACD: Approved for Committee
Draft, CD: Draft circulated as Committee Draft, PCC: Preparation of Compilation of Comments
Source: created by REI based on the data from IEC, TC 88 dashboard and JEMA89

3.2.2

Transition to IECRE and Japan's response

The IEC standard on Conformity testing and certification for wind turbines (IEC 61400-22 Ed. 1.0) was
discontinued at the end of August 2018 under the policy of separating technical and certification standards
and was replaced by IECRE, a certification system for renewable energy equipment including not only wind
power systems but also other renewable such as photovoltaic systems10. Regarding wind power, 15 countries
including Japan participate in its activities. It aims to promote international trade in equipment and services
used in the renewable energy sector. The following 10 certification bodies are registered with IECRE.
Table 2 IECRE Certification Bodies in the Wind Energy Sector
Country/Location

RE Certification Body Name

China

China Classification Society Certification Co., Ltd. (CCSC)

China

China General Certification Center (CGC)

China

China Quality Certification Centre

FranceBureau Veritas Certification France

Germany

DNV Renewables Certification

GermanyTÜV NORD CERT GmbHTC 88 Wind energy generation systems
https://www.iec.ch/dyn/www/f?p=103:22:0::::FSP_ORG_ID:1282
https://www.iec.ch/dyn/www/f?p=103:23:0::::FSP_ORG_ID:1282
9
List of IEC and JIS standards related to wind power generation (as of December 2020) Japan Electrical Manufacturers'
Association
https://www.jema-net.or.jp/Japanese/res/wind/kikaku.html
10
IECRE - RENEWABLE ENERGY- IEC SYSTEM FOR CERTIFICATION TO STANDARDS RELATING TO EQUIPMENT FOR USE IN
RENEWABLE ENERGY APPLICATIONS
https://www.iecre.org
8Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices
GermanyTÜV Rheinland Industrie Service GmbHGermany

TÜV SÜD Industrie Service GmbHGermany

UL

United Kingdom

Lloyd's Register Verification Limited (new organisational status under review). 17

Source: IECRE11

In Japan, however, JIS C 1400-22:2014, which is equivalent to IEC61400-22 Ed.1.0, remains valid and applies
to wind power system, although IECRE is used as a reference. It could be a transitional measure, but thecompetent authority has not announced yet when IECRE system would be officially applied in the country.
Before IECRE system would be applied, wind turbines obtained type certification under IECRE in othercountries would be utilized in Japan under the mutual recognition if the equivalence to IEC61400-22 isconfirmed. Regarding the certification body, even after IECRE system will be officially applied, it would benecessary for an entity which wants to operate activities as a certification body in relevant countries to beaccredited by the competent accreditation body of each country.

3.3“Official Explanation”

3.3.1

Official Explanation of Technical Standards for Offshore Wind Power Generation
Facilities

Offshore wind farms are required to comply with the technical regulations stipulated by the relevant Acts.
Therefore, to reduce the burden on operators and streamline the examination procedures, it is necessary to
avoid duplication of procedures and complications due to differences in regulations. From this perspective,the "Official Explanation of Technical Standards for Offshore Wind Power Facilities (March 2020 Edition)"(hereinafter referred to as the "Official Explanation") was published as "an explanation of the unified approachof each Act regarding the technical regulations to which offshore wind power facilities must conform basedon the Electricity Business Act, Port and Harbour Act, and the Renewable Energy Sea Area Utilization Act"12.
The contents of the Official Explanation apply to the examination of the structure of offshore wind power
generation facilities, based on the Electricity Business Act, the Port and Harbour Act, and the Renewable
Energy Sea Area Utilization Act (p.14)13. The "Official Explanation" mainly applies to bottom-fixed offshore
wind turbines, and floating offshore wind is separately required to comply to the “Technical Standards for

IECRE RE Certification Bodies (RECBs), https://www.iecre.org/dyn/www/f?p=110:7:::::P7_ORG_TYPE:RECB
The contents of the document were discussed by the "Offshore Wind Power Facility Review Committee," a council of
METI and MLIT.
13
Although the main subject of this document is support structures for offshore wind power generation facilities among
offshore wind power generation facilities, it is said that offshore wind power generation facilities can be read as offshoretransition facilities and observation towers and applied to them respectively. In the design of submarine transmission
lines and communication cables, the design methods for support structures covered in this commentary may not bedirectly applicable, and in such cases, international and national standards and certification standards may be referred
to.
11
12

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 18

Floating Offshore Wind Power Facilities”14 and to receive inspections based on the Ship Safety Act.
The Figure 3 shows the flow of conformity assessment by each act. The OSW developers undergo theirassessments after they are selected in the tender processes15.
Electricity BusinessAct
Director of
Electricity
SafetyDivision(experts *1)

Director of
Regional
Industrial
Safety andInspection
Department

OSW developer

Port and Harbour Act

Port and Harbour Act(Related to Art. 37 3～11)(Related to Art. 56.2 2～22)

Portmanagement
body

Experts *2

Minister of
MLIT

Registeredverification
agencySelection of prospective
occupant
EIA, zone investigation,
etc.
Detailed design of OSW
facilities

Construction
Plan

Occupancy
Plan forPublicTenderOpinion inquiry
Opinioninquiry
regarding theconformity
assessment

SubmitSubmitExaminationofConstruction
Plan

Apply

Review ofOccupancy
plan forpublic tender

Opinionhearing

Conformity
assessment*
4

Conformity
assessmentt

OpinionAnswerNo order tochange/abolish*3

Execute the examinations based on each Act
by utilizing the Official Explanation ofTechnical Standards for Offshore Wind Power
Generation Facilities

Construction starts

Permit for theoccupation*1: Opinion inquiry to experts pursuant to the assessment guideline regarding the installation and change of the Construction Plan of wind power(surely executed for OSW)
*2: Consider executing opinion inquiry to experts pursuant to Art. 37-5, paragraph(4) of the Act*3: Developer cannot start construction until certain period has passed after Construction Plan was received. During this period, the Plan is examined.
Minister of METI may order to change or abolish the Construction Plan if it is not conformed to the conditions required by the Act and related
regulations.
*4: Minister of MLIT doesn t proceed with conformity assessment conducted by a registered verification agency.
A registered verification agency assesses only a mooring facility which is designed in considering damages, etc. caused by the action of load
received from marine renewable electricity generation facilities, etc.

Technical Standard for Floating Offshore Wind Power Facilities March 2020
https://www.mlit.go.jp/common/001331375.pdf
15Regarding the project development under the Renewable Energy Sea Area Utilization Act, it may take about five or
six years from the stage of Selection of developer to Construction starts, with one to two years or more for detailed
design and more than two years for EIA. Design and EIA phases may progress in parallel. It may need about two or three
years for the construction.
14

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices
Electricity BusinessAct
Director of
Electricity
SafetyDivision(experts *1)

Director of
Regional
Industrial
Safety andInspection
Department

OSW developer

Renewable Energy Sea
Area Utilization Act(Related to Art. 56.2

Minister of
METI

Minister of
MLIT

Minister of
MLIT

. 19

Port and Harbour Act
2～22)

Registeredverification
agencySelection of theappointed business
operator
EIA, zone investigation,
etc.
Detailed design of OSW
facilities

Construction
Plan

Opinion inquiry
Opinioninquiry
regarding theconformity
assessment

Occupancy
Plan forPublicTender

Apply

SubmitExaminationofConstructionPlanAnswerNo order tochange/abolish*3

Construction starts

Execute the examinations based on each Act
by utilizing the Official Explanation ofTechnical Standards for Offshore Wind Power
Generation Facilities

Examination of exclusive
occupancy and use plan overpublic bidding
Examination of conformity
assessment(Art.15, paragraph (1) )Assessment of structure
and construction, etc.
(Art. 15, paragraph (2) )Conformity
assessment*
4

Conformity
assessment

Permit for theoccupation*1: Opinion inquiry to experts pursuant to the assessment guideline regarding the installation and change of the Construction Plan of wind power(surely executed for OSW)
*3: Developer cannot start construction until certain period has passed after Construction Plan was received. During this period, the Plan is examined.
Minister of METI may order to change or abolish the Construction Plan if it is not conformed to the conditions required by the Act and related
regulations.
*4: Minister of MLIT doesn t proceed with conformity assessment conducted by a registered verification agency.
A registered verification agency assesses only a mooring facility which is designed in considering damages, etc. caused by the action of load
received from marine renewable electricity generation facilities, etc.

Figure 3 Flow of examination and the application of the Official Explanation of Technical Standards (in red frame)(Page 18: Port area Page 19: Offshore Renewable Energy Generation Facilities Promotion Area)
Source: Created by REI, based on Offshore Wind Power Facility Review Committee, “Official Explanation of Technical Standards for
Offshore Wind Power Generation Facilities (March 2020 edition),” Figure 1.1.1, p.15

This "Official Explanation" lists the main regulations and guidelines related to the installation of offshore
wind power generation facilities. Those include international standards (e.g., IEC61400 series), overseas
certification standards (e.g., DNV-GL standards), IALA recommendations, UK Marine Guideline Note (Maritime
and Coastguard Agency), and the "Guidelines for Design of Wind Turbine Support Structure and Foundations"(Japan Society of Civil Engineers, JSCE), among others. “In applying them, it is necessary to refer to the latest
editions of the respective codes and standards" (p. 30).
The specific contents of the Official Explanation include performance requirements to meet the technicalregulations specified in each act, the concept of evaluation of natural conditions affecting offshore windfacilities, and structural design methods. However, "...methods to prove that the technical requirements areSectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 20

met are not limited to those referred to in this Explanation. If there exists a technical basis to ensure asufficient level of security in light of each ministerial ordinance, it may be adopted in place of the method
shown in this Explanation" (p. 18). For example, with regard to the design of support structures, "Whenadopting a method other than the design method indicated in this Explanation, it is desirable to refer togenerally recognized design standards and guidelines for offshore wind power generation facilities" (p. 47).
3.3.2

Official Explanation of Operation and Maintenance for Offshore Wind Power
Generation Facilities

Conformity of offshore wind power facilities to regulations is required by law to be verified in the operationand maintenance phase as well. As with the design and construction phase, the operation and maintenanceof offshore wind power facilities are subject to multiple laws and regulations (Electricity Business Act, Portand Harbour Act, and Renewable Energy Sea Area Utilization Act). In order to reduce the burden on operatorsand streamline the review process, the "Official Explanation of Operation and Maintenance for Offshore Wind
Power Generation Facilities (March 2020 edition)" was published. In addition to operation and maintenance,
this Official Explanation covers matters related to decommissioning (removal).
Electricity Business Act
Director of
Electricity Safety
Division(experts)

Director ofIndustrial Security
Supervision
Department

Port and Harbour Act
OSW developerPortmanagement
body

Experts

Construction starts

Construction finish
Pre-use Safety
Management
Inspection

Initial Inspection

Periodic Safety
Management
Inspection

Normal condition# Daily Inspection# Periodic Inspection
In case of abnormality# Temporary Inspection

Operation and MaintenanceDecommissioning

Figure 4 Flow of examination and application of the Official Explanation of Operation and Maintenance (in red frame)
Source: Created by REI based on Offshore Wind Power Facility Review Committee, “Official Explanation of Operation and Maintenancefor Offshore Wind Power Generation Facilities (March 2020 edition),” Figure 1.1.1, p.27

3.3.3

The role of standards in the technical regulations

As mentioned earlier, METI and MLIT publish respectively various documents including “Official Explanation”
in order to show specific methods for conformity assessment to each regulatory requirement. The

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 21

International standards and JIS standards are the referenced information for this objective alongside of the
Guidelines published by JSCE, among others.
Due to the speed of technical innovation, it is important for the regulation to follow the latest technology
development flexibly. In this sense, METI started a new scheme to incorporate standards developed at theinitiative of the private sector into technical regulations since 2020. Under the scheme, METI accredits a
Private Standard Evaluation body, which receives a draft standard from a Standard Drafting entity (industrial
institution or academia). The Private Standard Evaluation body examines the conformity of the draft totechnical regulations, conducts public consultation and publishes as the standards. The ministry controls theaccredited body by participating in its meetings and periodic checks. When receiving a report from theaccredited body, METI amends the interpretation of the technical regulations, after public consultation basedon the Administrative Procedure Act.

METI

Certificationof Private
Standard
Evaluation
Body

Stipulated criteria andprocedure to certificate a
private standard evaluationbody (in 2020)

after the certification

Standard draftingStandard drafting entity
entityJapan Electric Association, Institute ofElectrical Engineers in Japan, Japan
Electrical Manufacturers Association, etc.

Technical regulations as
quality requirements

Published private Standard
Publishedprivateevaluation
body
after theStandard
evaluation bodycertification

Conformity
examination
process ofprivatestandards

Private Standard
Evaluation body

Apply for private standard
evaluation body
Japan Electrotechnical Standards andCodes Committee, JESC, is certified in2020. The committee members consist ofexpert, consumer, journalist, lawyer,
related industry, etc.

Certified Evaluation body fulfils
accountability for the standards
evaluated and certified by itself

Draft private standards
Draft
standards

Review evaluation process(participation of officials)

Examine conformity toregulations
Public consultation for 30days or more

Request for conformity
evaluation of standards toregulations

Public consultation under the
Administrative Procedure Act

Report to request
amendment

Report to Standard drafting
entity in case there isinconformity to regulations

Amend
Interpretation ofofAmend Interpretation
technical regulations
regulations
technical

Publishlist ofof certified
certifiedPublish a list
private standards
standards on
privateon
websitewebsiteFigure 5 Adoption of technical standards at the initiative of private sector
Source, created by REI based on METI, Industrial Structure Council, Subcommittee on Safety and Consumer Product Safety, “Immediate
reform and important issues for the future in the field of industrial safety” (December 21, 2021), Figure 64, p.65

3.4 Examinations on technical regulations and third-party certification
procedures
Examination procedures for conformity to related technical regulations have been changing with theintroduction and spread of third-party certification. Duplication of certification procedures and regulatory
reviews, reworking, and prolonged procedures have become issues. In light of these circumstances, someSectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 22

institutional and operational reforms have been made and discussed, and currently in a transitional periodof change.
3.4.1

Examination under the Electricity Business Acta) Planning Phase
When installing an offshore wind power generation facility, a business operator shall notify METI of theConstruction plan (Article 48, Paragraph 1 of the Electricity Business Act). METI shall examine whether theConstruction plan conforms to the technical regulations established in the Electricity Business Act, and if it
finds that the Construction plan does not conform to the technical regulations, it may order the revision or
discontinuation of the Construction plan within 30 days (Article 48, Paragraph 4 of the said Act; the period
may be extended, Article 48, Paragraph 5).
The procedures for technical regulation conformity assessment are stipulated in the "Guidelines for
Examination of Construction Plans for Establishment or Modification of Wind Power Plants" (METI, Minister's
Secretariat, Director-General for Technology Policy Coordination and Industrial and Product Safety, May 2021).
According to this, the operator is required to submit (1) the documents specified in Appended Table 3 of theOrdinance for Enforcement of the Electricity Business Act (regarding the outline of electric facilities), (2) thetype certificate of the wind turbine, (3) the Wind farm certificate16 for the local site conditions, (4) the Wind
farm certificate for both or either the specified support and foundation under the local site conditions. The
Director of a Regional Industrial Safety and Inspection Department will confirm whether the equipment andmaterials used are "general equipment" or "special equipment". If the requirements for "general equipment"
are satisfied, construction work may begin. The Director of a Regional Industrial Safety and Inspection
Department may request the opinion of the Director of the Electric Power Safety Division as to whether theequipment falls under the category of special equipment. If the equipment falls under the category of special
facilities, the Director of the Electric Power Safety Division will ask for the opinion of the Expert Committee
for Safety Examination of New Energy Power Generation Facilities (established in the Electric Power Safety
Division to consult with the Director of the Electric Power Safety Division of METI, hereinafter, METI Expert
Committee) and confirm the conformity of the equipment. Once the conformity is confirmed, the constructionof the special facilities can be started.

According to the explanation of ClassNK, one of the certification bodies in Japan, the "Wind farm certification"
evaluates “the environmental conditions on the site where the wind farm is to be constructed and verified that thestrength and safety of the wind turbine and support structure are secured in terms of the design based on theenvironmental conditions”, and “ is unique to Japan and is intended for use in the Construction Plan Notification review
under the Electricity Business Act” (see below for details). Compared to full project certification, it is equivalent to thesite suitability evaluation (Site suitability evaluation in IECRE OD-502 Edition 1.0)
16

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices

OSW developer
Construction
plan

. 23

Third-party certification body accredited by JAB

Confirmation
note

Conformity assessment of design at the installation site
(wind farm certification)

Regional Industrial
Safety and Inspection
Department

Electricity Safety
Division

Experts committee

submission ofConstruction plan(if needed)
Notification ofextension of
examination period

Decide whether
general facility or special
facility (*1)

Necessity of opening
Experts committee
Examine equipment
other than special facility,
etc.

Construction
startsAfter Lapse of
examination
period (*2)

Compile and receive theexamination results of all
facilities

Conformity assessment ofdesign at the installation site
Verification of certificate ofconformity

Notification (request for
examination of special facility)

If necessary(*3)

If unnecessary(will start within
this year

Conformity
assessment on special
facilities(possibly several times)

Notification of verification
results
Notification(*1) defined by the Guideline for examination of Construction plan of implementation and change of wind farm(*2) In the case of observing a violation of technical standards as a result of the examination, METI may order to change or abolish the plan.
(*3) Further examination may be conducted at the Regional Industrial Safety and Inspection Department by utilizing the result of verification by Experts committee

Figure 6 Current review process for conformity assessment in construction plans for OSW
Source：Created by REI, based on METI, “Examination under the Electricity Business Act to promote the introduction of offshore wind
power generation facilities” (September 21, 2021) p.117

In the procedures before the guidelines’ revision in May 2021, a "Wind farm certification" was positioned asa pre-review of the METI Expert Committee, and the procedures for a "Wind farm certification" and those of
METI were duplicated. The revision of the guidelines has opened the way to avoid duplication of proceduresby omitting the METI Expert Committee meeting through the acquisition of third-party certification. However,the current guidelines are limited to onshore wind turbines, and offshore wind power generation facilities arestill required to hold an expert meeting as "special facilities”.
In this regard, METI has discussed an arrangement as a further streamlining measure to make it unnecessary
for wind farm certified facilities to hold an expert meeting (all facilities will be classified as general facilities)
by involving the METI Expert Committee members in the assessment process of "Wind farm certification" atthird-party certification bodies. METI announced in September 2021 that the measure would be to be
implemented within 2021.
On top of that, in 2022, METI has also proposed to establish a new body for conformity assessment to replace
METI's examination process (including the METI Expert Committee review) with the review by the new body.
17

https://www8.cao.go.jp/kisei-kaikaku/kisei/conference/energy/20210921/210921energy06.pdf

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 24

According to the bill for amendment of the Electricity Business Act 18, the new body, registered by METI,
conducts conformity assessment of the “Special Electric Facilities19”, which would assumably include OSW.
METI registers mandatorily the applicant entity if it meets all the criteria for registration, some of which
includes involving two or more experts in the assessment process. The registration shall be renewed every
three years. As the bill delegates to a ministerial ordinance to specify the scheme detail, including the method
in which the body shall perform, it is not clear how this new scheme would be coordinated with the thirdparty certification system.

OSW developer

Third-party certification body accredited by JAB

Construction
plan

Certificate

Conformity assessment of design at the installation site

METI
Submission ofConstruction plan

Examination of Construction plan

Conformity assessment

Experts committee
Request for review if needed

Review of conformity
assessment by experts

Securing the smooth supply

Construction
startsAnswerReflection of EIA

Certificate

The bill was passed at the Diet in June 2022.
“Special Electric Facilities” are defined as those specified by an Ordinance of METI as requiring a particularly safe
structure against loads and external forces.
18
19

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices

OSW developer
Construction
plan

. 25

Conformity verification body (tentative)

Conformity assessment of design at the installation site

Confirmation
document

METI
Submission ofConstruction plan

Examination of Construction plan

Conformity assessment

Experts committee
Request for review if needed

Review of conformity
assessment by experts

Securing the smooth supply

Construction
startsAnswerReflection of EIA

InCertificate
principle, METI (incl. Regional
departments) does not review what
Conformity verification body verified

Figure 7 Comparison between current and new review process for conformity assessment in construction plans for OSW(Page 24: current process, Page 25: new process)Source : Created by REI, based on the report “Immediate actions for institutionalization in the field of industrial safety and important
issues for the future,” METI, Industrial Structure Council, Industrial Safety and Consumer Product Safety Committee (December 21,2021)20, Figure 60, p.60b) Pre-commercial operation phase
Before starting to use an offshore wind power generation facility, the operator shall conduct a Pre-use Safety
Management Inspection (Article 51 of the Electricity Business Act). Specifically, before the start of use, theoperator shall conduct a self-inspection of the relevant Electric Facilities for Business Use, record the resultsof the inspection, and preserve them. The self-inspection shall confirm that the construction work has been
performed in accordance with the Construction plan and that the work conforms to the technical regulations21.
In addition, the operator shall submit the system for conducting a pre-use self-inspection to undergo
examination by METI.
c) Operation and maintenance phase
The operators must maintain offshore wind power generation facilities to ensure that they comply withtechnical regulations (Electricity Business Act, Article 39, Paragraph 1), and offshore wind power generation
facilities are subject to periodic inspections (Electricity Business Act, Article 55, Paragraph 1, Item 2;
Ordinance for Enforcement of the Electricity Business Act, Article 94, Item 10). The inspection frequency is20
21https://www.meti.go.jp/shingikai/sankoshin/hoan_shohi/pdf/20211221_1.pdf
Interpretation of Pre-use Self-inspection and Pre-use Self-confirmation Methods (p. 43)
https://www.meti.go.jp/policy/safety_security/industrial_safety/law/files/20200729shiyoumae.pdf

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 26

six months or one year, depending on the part of the wind turbine222324.
Meanwhile, project certification is not widespread in Japan. The reasons for this are: the technical regulations
conformity assessment based on the Electricity Business Act focuses on safety; METI, rather than a thirdparty certification body, has been conducting site suitability assessments for the climatic, geological, andseismic conditions of the construction site for wind turbines with type certification; Pre-use Safety
Management Inspections and periodic inspections are legally required; insurance companies and financial
institutions have not made obtaining project certification a condition for contracting or financing, althoughmarine warranty survey (MWS) is one of the conditions for contracting or financing. In addition, the cost ofobtaining project certification has been pointed out as a factor.
Recently, a new inspection scheme, so-called “Advanced Safety Implementation system” using smart
technologies was proposed by METI and the bill for the amendment of Electricity Business Act to implement
it has passed. According to the bill, a certified business operator by METI shall conduct self-inspection using
advanced technologies and will be exempted from undergoing examinations by METI. This new system will
be expected to reduce administrative burdens and to facilitate for the capable business operator to undertake
the O&M by using their own know-how.

3.4.2

Examination under the Port and Harbour Acta) Planning Phase
For safety inspections based on the Port and Harbour Act, the Coastal Development Institute of Technology(CDIT)25, a verification agency registered by MLIT, conducts the conformity verification inspections. CDIT is
responsible for confirming conformity with technical regulations with respect to port facilities (the Ordinancefor Enactment of Port and Harbour Act, Article 28-2).
□ Target FacilitiesoOuter facilitieso

Mooring facilities *1oRoads and bridgesoFixed and track-type cargo handling equipment *2oWaste landfill revetments

Official Explanation of Operation and Maintenance for Offshore Wind Power Generation Facilities, p. 73. Note that
Article 94-2, Paragraph 1, Item 5 of the Ordinance for Enforcement of the Electricity Business Act stipulates that theinspection frequency is within a period not exceeding three years, but the details are determined by the Interpretationof this ordinance.
23
There are also provisions for periodic inspections under the Renewable Energy Sea Area Utilization Act and the Portand Harbour Act.
24
Interpretation of the periodic inspection method by the operator prescribed in Article 94-3, Paragraph 1, Items 1 and
2 of the Ordinance for Enforcement of the Electricity Business Act (p. 11)https://www.meti.go.jp/policy/safety_security/industrial_safety/law/files/20210414teiken-kaisyaku.pdf
25
Coastal Development Institute of Technology
https://www.cdit.or.jp/
22Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practicesoBeachesoGreen space and open space *2

. 27

※1
1. Mooring facilities with a water depth of 7.5 m or more
2. Mooring facilities for mooring vessels carrying dangerous goods, passenger ships or car carriers
3. Mooring facilities with seismic resistance to level 2 earthquake motion
4. Mooring facilities equipped with offshore renewable energy power generation facilities, etc.
※2 Only those facilities that are specified as large-scale earthquake-resistant facilities in the port plan forthe port in question.

In order to avoid duplication of procedures for the Wind farm certification and the verification under the Portand Harbour Act, the assessment documents have been standardized and a joint assessment has been
started by a third-party certification body (Nippon Kaiji Kyokai, ClassNK) and a registered verification body
(CDIT). This concept could be applied to the procedure of other third-party certification bodies by a bilateralagreement with CDIT, even though there has been no case until now that other body conduct the certification
process.

Figure 8 Unification of the procedure of conformity verification under the Port and Harbour Act and a third-party certification forSectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 28wind power generation facilities26
Source：ClassNK, “ClassNK Wind Turbine Certification and Related Services”(August 2021) p.29b) Pre-commercial operation phase
The Initial inspection and diagnosis is conducted by an operator at the completion stage immediately after
construction or improvement, or at the stage of formulating an operation and maintenance plan for an
existing facility, in order to grasp the initial state of operation and maintenance not only for the facility as awhole, but also for each component and ancillary equipment (“Guidelines of the Inspection and Diagnosis forPort Facilities” revised March 2021, MLIT, Ports and Harbours Bureau).
The contents of the Initial inspection and diagnosis are the same as those of the Periodic inspection anddiagnosis. The Initial inspection and diagnosis for new construction should preferably be conducted within
two years of completion of construction, but the initial condition may be ascertained based on the results ofquality and form inspections at the time of completion of construction.
c) Operation and Maintenance Phase
The operator must maintain mooring facilities to ensure that they comply with technical regulations (Article
56-2-2 of the Port and Harbour Act), and offshore wind power generation facilities are subject to periodic
inspections. The Port and Harbour Act applies to underwater sections of offshore wind power facilities, andthe frequency of inspection ranges from one year to ten years, depending on the section.27

3.4.3

Examination under the Ship Safety Act and Classification surveya) Planning Phase
Under the Ship Safety Act, floating offshore wind power generation facilities fall under the category of special
vessels (Article 1, Paragraph 4 of the Ordinance for Enforcement of the Ship Safety Act, and the public notice
stipulating vessels with special structures or facilities in Article 1, Paragraph 4 of the Ordinance for
Enforcement of the Ship Safety Act), and survey details regarding the floating facilities and tower as support
structures follow the technical regulations for floating offshore wind power generation facilities. The survey
is conducted by the District Transport Bureau. However, floating offshore wind power generation facilities
that have undergone a classification survey by ClassNK, a classification society registered by MLIT as
stipulated in Article 8 of the Ship Safety Act, are deemed to have undergone and passed a survey by the

6th Meeting of Electrical Safety System Working Group, Electricity Safety Subcommittee, Subcommittee on Safety
and Consumer Product Safety, Industrial Structure Council
Document 3: Review of Construction Plan Examination to Promote the Introduction of Offshore Wind Power Generation
Facilities METI June 2021
https://www.meti.go.jp/shingikai/sankoshin/hoan_shohi/denryoku_anzen/hoan_seido/pdf/006_03_00.pdf
27
Official Explanation of Operation and Maintenance for Offshore Wind Power Generation Facilities, p. 73 and following.
Inspection and Diagnostic Guidelines for Port Facilities, July 2014 (partially modified in June 2008), Ports and Harbours
Bureau, MLIT.
26

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 29

District Transport Bureau28.
ClassNK has several experiences of classification survey for floating OSW project in Japan (in Kyushu andFukushima) and issued the guidelines for classification survey for floating OSW originally in 2012. Namely,
ClassNK defines offshore wind power generation facilities as offshore wind power generation vessels in Part
P of the Rules for the Survey and Construction of Steel Ships. The “Guidelines for Floating Offshore Wind
Turbines – Classification Survey –“ (December 2021) is the revised version based on the latest regulations
and standards such as Technical Standards for Floating Offshore Wind Power Generation( Safety Policy
Division, Maritime Bureau, MLIT, March 2020),

IEC TS 614003-2 (2019), and other parts of the Rules for

the Survey and Construction of Steel Ships.

Figure 9 Compliance with laws and regulations for offshore wind turbines
Source : ClassNK, “ClassNK Wind Turbine Certification and Related Services [Public website version], August 2021, p.33 29

Legally, it seems possible for an entity other than ClassNK to get registered by MLIT as a "Classification Society"defined in the Ship Safety Act. There are no provisions to limit the number of classification societies in this Act, eventhough customarily there is only one classification society in each country. A “Classification Society” in this act might beequivalent to a Recognized Organization, acting on behalf of the flag administration for inspections and surveys.
28

29

https://www.classnk.or.jp/hp/pdf/authentication/renewableenergy/en/RD2101_202108_Eng.pdf

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 30

Ship inspections based on the Ship Safety Act are shown in the figure below, while ClassNK's classification
inspections are divided into two main categories: registration inspections and periodic inspections.
Table 3 Ship inspections based on the Ship Safety Act
Type of inspection

Contents

Manufacturing inspection

Inspection that manufacturers undergo when manufacturing
vessels 30 meters or more in length

Periodic inspection

A detailed inspection to be carried out when the ship is put into
service for the first time or when the ship’s inspection certificate
expires.

Interim inspection

Simple inspection taken between periodic inspections. It is
subdivided into three types: Type 1 Interim Inspection, Type 2
Interim Inspection, and Type 3 Interim Inspection, and the typeof vessel determines which inspection the vessel is subject to.

Temporary inspection

Inspection to be performed when alterations, repairs, or new
equipment are made.

Temporary navigational inspection

Inspection to be made when a vessel is temporarily put into
service without a vessel inspection certificate

Preliminary inspection

Inspection of equipment, etc. listed in Paragraph 1, Article 2 of
the Ship Safety Law, when the ship to be installed is not
specified (If the equipment, etc. passes the inspection, theabove inspection is omitted).

Source : MLIT webpage, “Proper implementation of vessel inspections (Overview) 30

In the planning stage, the same inspections as those for ordinary vessels, such as structural inspections,water pressure tests, and watertightness tests, are conducted as registration inspections, and the tower isalso inspected during fabrication and assembly.

b) Pre-commercial operation phase
After the construction of the floating structure is completed, a stability test will be conducted. Since it isdifficult to conduct a stability test in the sea area where the floating structure will be installed, it is acceptable
to conduct a stability test before the wind turbine is installed and add the effect of the wind turbine to theresults of the test. In the installation site, a tension test of the mooring line of the floating facility, a checkof the control system of the wind turbine, and a check of the operational status of the equipment are
conducted. The tower will also be inspected when it is mounted on the floating facility.

30

https://www.mlit.go.jp/maritime/maritime_fr8_000018.html

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 31c) Operation and Maintenance phase
There are three types of periodic inspections: annual inspections, interim inspections every two to three years,
and periodic inspections every five years.
Annual inspections are in principle document checks. For interim and periodic inspections, an inspection planand inspection procedures are prepared in advance, and the inspections are conducted based on the plan andprocedures after obtaining approval from ClassNK. In the interim inspection, the visible area is inspected,
while in the periodic inspection, the inside of the floating structure and underwater structures are also
inspected.

4 International and European standards
4.1 Overview of thestandardisation

structureforinternational

andEuropean

European Standards can be adopted by one of three standards organisations: European Committee forStandardisation (CEN), European Committee for Electrotechnical Standardization (CENELEC), and European
Telecommunications Standards Institute (ETSI). European Standards must be transposed into a national
standard in all EU Member States. In case of conflicts, the EN supersedes any national standard. EN standards
can be adopted in direct reference to ISO (by CEN) and IEC (by CENELEC), then they have the prefix “EN ISO”
or “EN IEC”. They international standards may also be adopted with amendments. When an EN standard isadopted as national standard, the name is prefixed by the country-specific abbreviation, e.g. “DIN EN ISO”. In
the area of electrical and electronic standards, close to 80% of European standards are in fact IEC
International Standards (IEC, 2022). In Denmark for wind energy, for example, the option for national annexes(i.e. deviation from international and EN standards) has not been used so far.
4.1.1

Mirror committees in the international standardisation work

Countries participate in ISO/IEC work via national standards bodies (NSBs), as well as through input received
from liaison organisations. National positions on ISO/IEC work are developed by the NSBs on an ongoing basis.
For this, most NSBs establish national mirror committees (NMCs). The mirror committees function in a way
so that there is a national system of committees and working groups that are organised in the same way as
the ISO/IEC on the one hand, and the CEN/CENELEC on the other (in Europe).

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 32

Figure 10 The case of Danish Standard organization
Source: Danish Standard

In Denmark, for example, the Committee ‘S-588 Wind Energy Systems’ is organised in 13 sub-committees
that reflect all areas of the international relevant committees: U-01 Design and safety, U-02 Procedures formeasurements, U-03 Communication, U-04 Gear boxes, U-05 Testing and Certification of Wind Turbines –Rules and procedures, U-06 Electrical main components, U-07 Noise, U-08 Lightning protection, U-09 Rotor
blades, U-10 Availability, U-11 Electrical test and simulation models, U-12 Protective measures, U-13 IECRE
Renewable energy certification – Wind Energy Sector. The Danish S-588 has 30 members from a broad rangeof stakeholders, including equipment manufacturers, developers, consultants, several universities, the Danish
Transmission System Operator Energinet, and the Danish Energy Agency (who is responsible for drafting
regulation in the area). The sub-committees meet 2-4 times each year. Membership in S-588 costs between
2,250 EUR and 3,500 EUR per year, with a higher price for larger companies and commercial stakeholders,and a lower price for e.g. universities. Not-for-profit organisations can participate without fee. Members of
the Danish S-588 then participate in the relevant international committees, including the ‘IEC TC 88 Wind
Energy Generation Systems’, the ‘ISO TC60 Gear’, the ‘IEC TC 14 Power Transformers’, the ‘CENELEC TC 88
Wind Turbines’.
Denmark is also operating agent of the overall international IEC TC 88 and hosts its secretariat. The IEC TC
88 is structured in Working Groups (WG), Maintenance Teams (MT) and Project Teams (PT). Of interest here
may be:▪

WG 3 Design requirements for offshore wind turbines▪

WG 15 Assessment of site specific wind conditions for wind power stations▪

MT 1 Design requirements for wind turbinesSectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices▪

PT 61400-3-2 Design requirements for floating offshore wind turbines▪

PT 61400-6 Tower and foundation design▪

PT 61400-8 Design of wind turbine structural components▪

PT 61400-30 Safety of Wind Turbine Generator Systems (WTGs) – General principles for design▪

PT 61400-50-3 Use of nacelle mounted lidars for wind measurements▪

PT 61400-101 General requirements for wind turbine plants

4.1.2

. 33

Adoption of international standards

The ISO/IEC system adopts changes through a multi-layered consensus-based process. They follow a sixstage process for developing standards: (1) Proposal stage, in which industry associations or consumer groups
make a request; (2) Preparatory stage, in which a working group or Technical Committee(TC) prepares aworking draft of the new standard; (3) Committee stage (optional) for review and commenting by the parent
committee; (4) Enquiry stage, where the Draft International Standard (DIS) is distributed amongst members
for comments and ultimately voting (if no technical changes made); (5) Approval stage, in which the Final
Draft International Standard is prepared and voted on by all members; (6) Publication stage. These processes
are lengthy and can easily take 5-7 years.
In many areas of standards adoption, Europe subscribes to the principle of “Parallel Voting”, whereby thesame draft standard is simultaneously voted for adoption at international level (within ISO/IEC processes)
and at European level (within the Technical Committees of CEN/CENELEC/ETSI). This ensures a smooth andfaster process.
However, there have also been voiced doubts about the fact that there seems to be an expectation that
National Committees vote positively almost by default, and suggestions that they use the “Abstain” option
too little. Concerns have e.g., been raised in regards to EN IEC 60079-13 and the pre-existing EN 50381 forTransportable Ventilated Rooms. Here, an ad-hoc Working Group had been set up headed by Norway in 2018
to investigate issues, only after the IEC norm had already been adopted in the EN system. This is a relevant
issue for offshore operations, in particular regarding concerns about explosion safety requirements as these
could make the rooms uninhabitable for environmental reasons.

4.2 Overview of EU standards, certification, and technical regulation
4.2.1

EU Legislation

Regulation on European standardisation (EU) 1025/2012 defines a national standard as a standard that
manufacturers can use to comply with national product safety laws and policies. According to Regulation (EU)2019/515, when a product meets a local standard of an EU Member State, other Member States must accept
the product on their markets as well. This is unambiguous as national standards must not contradict EN
standards.

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 34

Although the compliance to standards is often voluntarily, this is not necessarily the case for products andservices that are publicly procured (as offshore wind energy typically is – through government support
schemes). This is, because EU Directives on public procurement stipulate that all public invitations to tenderand all public contracts in the European construction industry must accept the Eurocodes (Schuppener and
Ruppert, 2009). A regulatory framework enforcing the use of the Eurocodes in Public Procurement exists (orwill be implemented) in 41% of the countries analysed in a 2015 study, with another 17% of the countries
considering that the Eurocodes are well-placed in the Public Procurement without having a particular
Regulatory Framework.
If proposing an alternative design, one must demonstrate that is technically equivalent to an EN Eurocode
solution. The reference to Eurocodes as well as the flexibility in compliance can be e.g. seen here:“(42) The technical specifications drawn up by purchasers should allow public procurement tobe opened up to competition. To this end, it should be possible to submit tenders which reflect
the diversity of technical solutions. Accordingly, it should be possible to draw up the technicalspecifications in terms of functional performance and requirements and, where reference ismade to the European standard or, in the absence thereof, to the national standard […] To
demonstrate equivalence, tenderers should be permitted to use any form of evidence.
Contracting entities should be able to provide a reason for any decision that equivalence does
not exist in a given case.” [DIRECTIVE 2004/17/EC]
It is relevant to note that only in some countries parts of an offshore wind project are defined as construction
structures and hence have to comply with the Eurocodes. Other parts of the wind turbine fall under the
Machinery Directive.
The European Machinery Directive is relevant for wind turbines, including the tower, blades, gearbox, andeverything else in the tower and nacelle, which are considered to be machines under Directive 2006/42/EC.
Regulations apply to completed and partly completed machinery, interchangeable equipment, machine
related safety components, lifting accessories, chains, ropes and webbing, and removable mechanicaltransmission devices. The detailed guide to the Machinery Directive by the European Commission is helpful
to gain understanding of its application31.
A main point resulting from the Directive is that all wind turbines installed in the EU should be CE marked(machinery elements), which is in effect the assurance that the wind turbine complies with the essential
health and safety requirements of EU law. In all cases, the manufacturer must compile information
confirming how the machine complies with these requirements.
In addition, it is quite common for national technical regulations to refer to international and European
standards to help avoid that the law becomes too detailed or descriptive and to allow the law to stay current
as standards are regularly reviewed and updated (IEC, 2022).

31

https://ec.europa.eu/docsroom/documents/24722/attachments/1/translations/en/renditions/native

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices

4.2.2

. 35

Certification in the EU

A way to show compliance to standards and technical regulation is through certification. Certification is anindependently unbiased assurance of the safety of the product or service. Certification can be mandated bylegislation. But it is also often demanded by the market, for example by lenders or insurers. For financial andinsurance entities, certification reduces due diligence costs, and for owners it can in general reducetransaction cost and lower the technical risk exposure, ultimately lowering cost of capital and improving
project performance. Therefore, certification is often undertaken even if not mandated by regulation.
For government agencies and regulators, requiring certification according to certain industry standards canbe an efficient and cost-effective way of ensuring that public safety concerns have been addressed.
Certification can be distinguished in three areas relevant for offshore wind:-Type certification – includes a design bases evaluation, a design evaluation, a type testing, amanufacturing evaluation, and a final evaluation of a wind turbine according to specific standards
and technical requirements relating to safety, reliability, performance, testing, and interaction withelectrical power networks (IEC 61400, IECRE, GL2010, DNV GL 2015). Some optional phases such as
foundation design and manufacturing evaluation may apply.

-Component certification – includes the same procedures as type certification applied to major
components (blades, gearbox) according to the same specific standards and technical requirements
as type certification.

-

Project certification – consists in the verification of wind farm design and states whether it meetssite-specific conditions. It includes a soil investigation, a review of measuring campaigns, anevaluation of energy yield reports, an assessment of marine conditions a verification of load-casedefinitions. All the steps are further described below, in section 3.2.1.

Below is an overview of the general certification requirements for offshore wind in key European countries:
Table 4 General certification requirements for offshore wind in key European countries

Component certification
FranceType certification

Project certification

Certificates can facilitate The developer must use Tenderspecifiedproject

the integration into type turbines that respect certification requirements. In
and project certification.

European Union norms general:

Tender document requires (NF EN 61400) and that Project

Certification

the use of type certified have been previously according to IEC 61400-22.
turbines according to FN certified by a body who
EN 61400

received
accreditation

an
by

a

member State, in orderto provide guarantees

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices

regarding. 36

design,manufacturingandperformances.
Germany

Certificates can facilitate Prerequisite for approval Mandatory under BSH7005
the integration into type and project certification, forand project certificationwind

turbines

IEC 61400-22 or IECRE substation

incl.

and

support

OD-501 applicable (also structures
DIN EN 61400, DNVGLSE)
Denmark32

Certificates can facilitate Mandatory

under Mandatory under Executive

the integration into type Executive Order no. 73 Orderand project certification(2013),

referringno.

to referring

IECRE OD-501:2018

to73(2013),

IECRE

502:2018.

OD-

Project

certification must be applied
for by the project owner
UK

Certificates can facilitate Certificates

can Projectcertificationisthe integration into type facilitate the integration common practiceand project certification

into project certification

Belgium

Project

certificationismandatory and must be
carried out under national
and international norms.
Netherlands

Project

certificationismandatory as stipulated in
Water Decree of April 13th
2015.

All

international

norms can be used.
SwedenProject

certificationaccording to IEC 61400-22
and ISO standards.

Besides certification, offshore wind farms are subject to a long list of technical, environmental and safety
regulations. Below, we mention several major areas of this regulation with some European examples.
Wind turbines need to have a lighting system that can be required to be different between turbines locatedon the periphery on the farm or inside the farm, as is the case in France. Lighting may also vary between

32

https://cas.ens.dk/home/legislation-and-standardisation/

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 37night and day, and each element of the turbine (nacelle, tower, blade) has specific regulations. Furthermore,
every European country has set rules on colour markings: as an example, in Belgium blades, tower and nacellemust have red bands if tip height of turbines exceeds 150m.
The helihoist has to fulfil some requirements: the size of the platform of has to be either a square of 4m x
4m or a circle with a diameter of at least 5m in Denmark, for instance. Some other regulations regarding
weight tolerance, static discharge, railing, and friction characteristics also apply.
Technical regulations also include inspection, maintenance, and safety. Each country set rules on maintenanceintervals on every part of the turbine: blades, drivetrain, nacelle, tower, foundations, electrical system,
equipment under pressure, elevator, etc. Regular checks are done regarding people’s safety: harness, lifejacket,
safety kits, safety lighting, etc. Finally, an emergency service plan must be defined by the wind farm operator.
Transportation systems are also under a set of rules: operating conditions of helicopters (clouds, visibility,
wind…) as well as marine safety rules, including certification of crew members (they need to hold a certificate
of competency in Denmark and Germany, for instance).
Some regulations also apply on park layout. They include turbine spacing, considerations for neighbouringparks, vessel traffic and distances from exclusion zones (archeology sites, pipelines, etc.).
Data is always required to be shared with third parties. Each country has to set the party responsible forstoring environmental data.
Concerning environmental regulations, surveys are to be done before, during and after construction. They
make a focus on birds, sea mammals, soil conditions, fauna and flora growth on foundations, etc. Underwater
noises are to be controlled: some countries like Germany set a noise threshold and obligatory noise reduction
measures.
Finally, regulation on the decommissioning of wind farms is strict in all countries: foundations, cables andscour protections need to be removed in order to restore the seabed to former conditions.

In the following, we describe several areas of certification and regulation that are of particular interest forthe comparison between Europe and Japan.
4.2.3

Elements of project certification

In European countries, project certification is a long process that starts early before construction and that
may last during the entire life of a project. Project certification processes are typically not described in detailin regulation, but the documentation by certification bodies themselves gives a good picture of the typical
process and activities undertaken. Different certification bodies describe their own processes. We are here
referring to the representative DNV process. According to DNV-SE-0190, there are five mandatory phases
and some other that are optional, as shown on the following figure, extracted from the same document.

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 38

Figure 11 Typical European project certification phases
Source: DNV

Each phase is here further detailed:-

Concept: covers the concept development at the beginning of the wind power project.

-

Design basis: covers the site conditions and the basis for design. It includes: soil investigation, designbasis of project related assets (wind turbines, foundations, substations, power cables, etc.), review ofmeasuring campaigns, evaluation of energy yield reports, assessment of maritime conditions andverification of design load cases.

-

Basic design: covers the generic design documentation for a subsequent detailing andimplementation.

-

Design: covers the steps necessary to achieve final design approval. This includes the site-specificdesign approval of the integrated structural system of the project related assets, the verification ofload calculations.

-

Manufacturing: covers the surveillance during manufacturing of the project related assets.

-

Transport and installation: covers the surveillance during transport and installation of the project
related assets.

-

Commissioning, operation and maintenance manuals: involves all follow-up evaluation and onsite inspections during the implementation and start of operation of the power plant.

-

In-service: involves follow-up evaluation and periodic on-site inspections after start of operation.

-

Lifetime extension: covers continued operation of a wind power plant beyond its initial design lifetime.

-

Decommissioning: contains the planning and execution of a wind power plant decommissioning andremoval.

-Repowering: covers the renewal and reinstallation (typically partially or completely upgrading) of awind power plant at a former power plant site.

Typically, the quality system evaluation is limited to the verification that quality systems of the different
OEMS / operators are certified according to ISO 9001. On-site inspections on random sampling can be
conducted A wind farm “Project Design” certificate can be obtained to demonstrate assessment of the sitespecific design and site assessment, without the evaluation of transportation, construction, and testing.

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 39

Germany embarked on a special path as compared to other European countries in regard to projectcertification and permitting procedures. While other countries refer more directly to ICRE and leave muchroom to manoeuvre to the industry itself, Germany has developed its own unified ‘offshore wind standard’.
Germany’s specific offshore standard BSH 7005 collects and describes in detail all the standards andregulations that apply specifically for the offshore area.

The German BSH 7005 (2015)
Standard Design - Minimum requirements concerning the constructive design of offshore

structures
Germany has, as the only one of all European countries created its own unified ‘offshore wind standard’.
At the beginning of the 2000s, the German industry experienced barriers due to different typecertification requirements in Germany for loads and structural strength, and a complicated process tohave tower and foundation approved (ECN, 2000). Based upon request by the industry, a technical expert
group of ca. 20 experts was commissioned to develop the first German offshore standard. The groupcontained a variety of industry actors. BSH has moderated the process and was responsible for the final
decision-making. The first unified guidelines for site investigations were published in 2004/05, and thefirst offshore standard for constructive design was published in 2007. In its current version, the 117page document provides legal and planning security for the development, design, implementation,

operation, and decommissioning of offshore structures. The document lays out standard directives andjustifications for each point. It mentions and clarifies which standards are applicable where, and points
to regulations and procedures. There is a continuous review process & commenting of the draft byindustry associations and transmission system operators. In the preparation of its first update (2015),
already more than 75 technical experts were involved.

4.2.4

Site investigations

In Belgium, Denmark, the Netherlands, and the United Kingdom, detailed regulative requirements for site
investigations are intentionally not issued by the authorities (Fischer et al., 2020). Site investigation
requirements are widely based on part 8 of the ISO 19901 standard and further recommendations takenfrom supplementary guidance for offshore wind energy such as e.g., the DNV GL standards (DNVGL 2018)
and specific guidance on geophysical investigations like, for example, IHO 2008. It is commonly acceptedthat the sole use of this ISO standard, which originates from the petroleum industry, does not provide a
sufficient basis for site investigations for offshore wind farms. Hence, it is the practical project requirements
rather than regulative requirements that drive OWF site investigations. In the worst case, an inadequate site
investigation could cause issues in the project certification process at a later stage of the project (Fischer etal., 2020).

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 40

In Germany, a different approach is followed. Here, minimum requirements for geophysical and geotechnicalinvestigations are detailed in BSH 7004 ‘Standard Ground Investigations’, which specifies the priority use of
Eurocode 7, its national annexes and DIN standards33, and, in future the bundled requirements through part
4 of the DIN standard 18088 (DIN 2019). The ‘Standard Ground Investigations’ was defined by a working
group of experts and stakeholders (Fischer et al., 2020), in a similar process as for BSH 7005 described above.
There are no mandatory techniques for site investigation. Only in Germany, there is some restriction due tothe specification of minimum technical requirements on the towing speed, the frequency, and the resolutionof geophysical devices – however, the decision about the most appropriate device and the detailed executionof the site investigation remains with the owner (Fischer et al., 2020).
According to BSH 7004, the geological survey for turbine locations requires order 1b surveys for multi beamecho sounder and in accordance with the IHO standards for hydrographic surveys (IHO 2008). According topart D of BSH 7004, IHO special order surveys are required for the inner-array cable routes and the export
cable routes.
In practice, the approaches in the European countries are similar. E.g., for the currently developed Thor OWF
in Denmark, the scope for geotechnical investigations for a 440 km2 area comprises 15-20 borehole locations
with soil sampling, 60-80 CPT (cone penetration testing) locations and a number of laboratory tests.
According to the Danish authorities, the geophysical survey does not deviate from the technical requirements
laid out in the German BSH standard, except for organisational matters (Fischer et al., 2020). This is inparticular in reference to the “10% criterion” laid out in the BSH Standard, according to which the total numberof borehole locations and CPT locations of the preliminary site investigation shall correspond to 10% of theplanned number of wind turbine locations34.
According to IEC 61400-3-1, an assessment of earthquake conditions shall be performed if relevant,following IEC 61400-1:2018. However, some countries such as France require such an analysis for every
project, even if seismic risks are very low, according to the bill of specifications (n° 2011/S 126-208873) for
new offshore wind projects. More accurately, every company willing to develop an offshore wind farm must
provide a geological structure assessment, made by high resolution seismic reflection with a verticalresolution of 1m. This technique, among others, is described in the “Geotechnical and geophysicalinvestigations for offshore and nearshore developments” manual, issued by the Technical Committee TC1 of
the International Society for Soil Mechanics and Geotechnical Engineering (ISSMGE). This manual also
includes recommendations on how to plan offshore campaigns of geophysical and geotechnicalinvestigations.

Eurocode 7 “Geotechnical Design”,- DIN 1054:2005 “Ground – Verification of Safety of Earthworks and Foundations”- DIN 4020:2003 “Geotechnical Investigations for Civil Engineering Purposes”- DIN 4017 “Calculation of the Design Bearing Capacity of Soil beneath Shallow Foundations”,- DIN 4084 “Soil – Calculation of Embankment Failure and overall Stability of Retaining Structures”- DIN 4085 “Soil — Calculation of Earth Pressure”
34
generally assuming that one turbine will be installed per 0.5 km² of the wind farm area
33

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 41

The entities undertaking site investigations differ between countries. In Denmark, the responsible body forpreliminary site investigation is Energinet. In Germany, for wind farms that start operation before end of2025, the owner of the OWF is responsible for all parts of the preliminary and main site investigation
campaigns. For OWF commissioned after 2025, the BSH will take over the responsibility for the following
scope (all activities before the tender takes place): desk study, geophysical survey, preliminary geotechnicalinvestigation, geological report. The associated factual reports and raw data are forwarded to each relevant
applicant (Fischer et al., 2020). The works related to the geotechnical investigations are to be carried out by
an independent and suitably qualified third-party geotechnical expert. Regarding geophysical investigations,no such requirement exists.

4.2.5

Site-specific assessment of loads and load cases

According to DNV (DNV-SE-0073 and DNV-SE-0190) and Bureau Veritas (Marine & Offshore technology
report), an independent load analysis must be carried out in order to verify that specific loads are derived inconformity with the approved design basis. Such an independent analysis will be carried out based on a fulldynamic load modelling of the integrated systems consisting of wind turbines and support structures,
including soil modelling of offshore sites and using an aero-hydro-elastic computer program. The integrated
load analysis is preferably performed by a single computer program. It should consider the simultaneous
dynamic impacts of all relevant environmental forces such as wind, waves, current, etc. on the complete
system. The model on the complete system shall comprise rotor-nacelle assembly, support structure,foundation, and soil properties. This enables an analysis of the dynamic system response taking thecorrelation of all acting environmental impacts into account.
The following figure, extracted from DNV-SE-0190, gives an overview of the link between the various kindsof information required to perform the analysis.

Figure 12 Information required for the load analysis
Source: DNV

In general, the loads must fulfil the requirements of IEC 61400-3-1 and IEC 61400-3-2 for fixed offshore
wind turbines and floating offshore wind turbines respectively. These documents specify that the structural
analysis is based on ISO 2394.

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 42

Loads include the following:-

Gravitational and inertial loads: static and dynamic loads resulting from gravity, vibration, rotationand seismic activity-

Aerodynamic loads: static and dynamic loads derived from the airflow and its interaction withstationary and moving parts of wind turbines (tower, nacelle, rotor, floating substructure for floating
turbines)-

Actuation loads: they result from the operation and control of wind turbines-

Hydrodynamic loads: dynamic loads derived by the water flow and its interaction with the support
structure of wind turbines, including mooring system for floating wind farms-

Ice loads: static and dynamic loads induced by icing. ISO 19906 applied for floating wind turbines-

Other loads: wake loads, vessel-impact loads, earthquake loads…

According to IEC 61400-3-1, earthquake loads shall be considered according to IEC 61400-1:2018 (where adetailed assessment of earthquake loading is presented in Annex D), if relevant. A time-domain simulationis required for the load calculation of the support structures of offshore wind turbines. Appropriate modelling
methods shall be used for specific support structure types, e.g., an interaction model is needed for a monopile
support structure while a sway-rocking model can be used for a gravity base structure (more details provided
in ISO 3010:2017). In addition, hydrodynamic loads from waves resulting from sub-sea earthquakes(tsunamis) may need to be considered.

The following table gathers examples of design load cases related to power production from IEC 61400-31. More details concerning each of the load cases are given in the report. The integrated load analysis has tofocus on a selected sub-set of load cases for fatigue and extreme loads in the scope of project certification.
Table 5 Examples of design load cases related to power production from IEC 61400-3-1

Design load case(DLC)
DLC 1.1

DLC 1.5
DLC 1.6

Wind condition

Wave

Wind/wave

condition

directionality

Normal turbulence model

Normal sea

for all wind speeds

state

Extreme wind shear

Normal sea
state

Normal turbulence model

Severe sea

for all wind speeds

stateSame direction

Same direction
Same direction

Sea current

Water level

Normal current

Mean sea

model

level

Normal current

Mean sea

model

level

Normal current

Normal watermodel

level range

IEC standards for wind turbines focus on design conditions and load cases using a Load and Resistance Factor
Design (LRFD) approach, which accounts for design load uncertainties and consequences of failure throughSectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 43

a summation of partial safety factors (NREL 2014). Generally, IEC adheres to a 50-year return period for
extreme design conditions.
Besides, IEC 61400-3-2 reports some specific load cases for floating wind turbines. As an example, they
include other conditions such as redundancy check of the mooring system.
As an example, TÜV carries out load calculations thanks to finite-element computation. This includes linear
and non-linear analysis of stresses, deformations, and stability, the evaluation of local plastification under
extreme loads and fatigue analysis. Some failure scenarios are also investigated throughout this process.

4.2.6

Steel standards in Europe

Two relevant sets of steel standards are EN10027 and EN 10025. EN 10025 (Hot rolled products of structuralsteels) refers to a set of European standards which specify the technical delivery conditions for hot rolled
products of structural steels. The standards consist of the following parts:▪

EN 10025-1: Part 1: General technical delivery conditions▪

EN 10025-2: Part 2: Technical delivery conditions for non-alloy structural steels▪

EN 10025-3: Part 3: Technical delivery conditions for normalized/normalized rolled weldable finegrain structural steels▪

EN 10025-4: Part 4: Technical delivery conditions for thermomechanical rolled weldable fine grain
structural steels▪

EN 10025-5: Part 5: Technical delivery conditions for structural steels with improved atmosphericcorrosion resistance▪

EN 10025-6: Part 6: Technical delivery conditions for flat products of high yield strength structuralsteels in the quenched and tempered condition▪

Related to EN 1993 Eurocode 3: Design of steel structures

CE marking for all construction products that are covered by a harmonised European standard or conforming
to a European Technical Assessments is imposed by the EU Construction Products Regulation, which became
mandatory in 2013. For fabricated structural steelwork, CE marking became mandatory in the EU in July
2014 (EN 1090). CE Marking of structural steelwork is a declaration by the manufacturer. It states the steel
product meets certain public safety requirements. This represented a major development for engineers,
contractors, and steelwork specialists and demanded careful attention to the new obligations.
In Europe early in the development of offshore wind energy, it was thought that specific ‘offshore steel’
would need to be used. But now, there are no such restrictions on the type of steel used, albeit adequate
corrosion protection applies. The experience was made that restricting the type of steel that can be used will
delay the process and increase prices of offshore wind energy.

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 44

5 Comparison between Japanese and European standards andregulations
5.1 Differences between Japanese and European practices
In the following, we give an overview of the similarities and differences in Japanese and European practices.
As described in the respective chapters above, international standards ISO and IEC are applied in Europe aswell as in Japan, and those frequently used in Japan are published as JIS standards after translation work
into Japanese. Small adjustments in comparison to the international standards seen so far seem justified(e.g., lightning protection), according to industry representatives we talked to. Indeed, internationally, thetranslation into local language as well as small changes to account for local conditions is common in the
adoption of standards. However, we see a difference in the speed and adoption process of the international
standards, where in Europe an almost automatic procedure ensures rapid implementation, and a broad
participation of different stakeholders ensures support.

Table 6 Overview of similarities and difference identified in the technical regulation and use of standards in Japan and Europe:
EuropeAdoption ofstandards▪ >80% of IEC standards directly integrated into EN
standards▪ Public procurement based on EN Standards andEurocodes

Japan▪ National JIS standards based on IEC standards▪ Detailed offshore wind standard “Official
Explanation of Technical Standards for Offshore
Wind Power Facilities"▪ Most countries do not have specific offshore
wind standards▪ Germany: detailed ”offshore wind standard” (BSH
Nr. 7004 & 7005)
Development ofstandards andregulation

Project
certification &permitting▪ Development through direct participation in
ISO/IEC and IECRE▪ Germany: technical expert group for further▪ Participation in IEC and IECRE▪ Specific regulation for national context underdevelopment

development of ”offshore wind standard”▪ Dedicated expert committees of METI and MLIT

▪ Conformity assessment based on IEC 61400▪ Conformity assessment based on IEC 61400

series & IECRE OD 501 & 502

series▪ Full project certification typically undertaken▪ “Wind farm certification” for design phase typical▪ Typically, no government entity directly involved▪ Conformity assessment now jointly between thein undertaking conformity assessment▪ Today, no project-specific involvement of expert
committees

third-party certification body and registered bodyby MLIT, and also undertaken by METI

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices▪ Permitting based on certificates issued by. 45▪ Expert committee can be involved in specificaccredited third-party bodies

projects and issue requests and opinion▪ Broad field of conformity assessment bodies▪ Two conformity assessment bodies active

active, mutually recognised
Siteinvestigations▪ Detailed regulative requirements for site

▪ Complex and diversified seabed conditions

investigations intentionally not issued▪ ‘Official explanation’ details requirements▪ Exemption Germany: offshore standard▪ Surveys based on Standard Penetration Test

▪ No mandatory techniques Surveys typically based(SPT), desirably multiple soil borings

on Cone Penetration Test (CPT), one soil boring in
the vicinity
Loads▪ Integrated load analysis based on selected sub-▪ Combined analysis of load effects by time-

set of load cases for fatigue and extreme loads

domain methods and of annual averages▪ Load Resistance Factor Design (LRFD) approach▪ Different methods and calculations tried▪ Risk-based assessment for extreme design▪ More research needed to develop genericconditions based on IEC 61400-3-1

approach for earthquake and typhoon conditions
assessment

Materials▪ Based on Eurocodes in case of buildings and▪ Steel: JIS certification or METI approval

other civil engineering works▪ Based on EU Machinery Directive

requirement (price increasing effect)▪ Necessary to undergo separate performance▪ Steel: approx. 40 key EN steel standards

evaluation if specific design not listed (>100mm;▪ Steel in offshore wind: Increased flexibility=>M72)

through few requirements (cost decreasing▪ Specific guidelines and lists to be developed for

effect)5.1.1

materials, incl. concrete, synthetic fibre ropes

Project Certification ("Wind Farm Certification") and Permitting

In Japan, type certification of wind turbines based on the IEC61400 (JIS C61400) series is utilized. Currently,
as there are no wind turbine manufacturers in Japan (after Hitachi has ceased its production), there are no
new wind turbines to obtain type certification. For wind turbines used in Japan, international mutualcertification is utilized for products certified by certification bodies in various countries. As the loads related
to the earthquake are not considered in the type certification, they are assessed in the “Wind farm
certification” procedure as part of the site-specific assessment.
Project certification is also basically based on the IEC61400 series. Currently, third-party certification is
focused on the site conformity assessment (so-called, “Wind farm certification”), which is equivalent to theSite suitability evaluation stipulated in IECRE OD502, 6.3, since safety in the planning phase is the main
target of the assessment to obtain the permit by METI. The full project certification is rarely used in Japanand mainly two reasons pointer out are as follows; the periodical inspection during the operation andSectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 46

maintenance phase is regulated in detail by relevant laws and the risk assessment and control of theconstruction phase are considered to be covered by the Marine Warranty Survey and insurance contracts.
The procedures take into account the meteorological, geological, and seismic conditions peculiar to Japan. In
particular, the safety of type-certified wind turbines under seismic conditions is confirmed since the effectsof earthquakes are not taken into account at the time of type certification.
In Japan, "Wind farm certification" is at the aim of confirming conformity to technical regulations stipulated
by law, and third-party certification bodies review with reference to both IEC standards and regulations.
Therefore, if there is any difference between the IEC standards and the technical regulations, a project could
be certified only when the latter is cleared.
IEC61400-1 and IEC61400-3 indicate that, the evaluation for earthquakes is based on the seismic motions
provided by standards of each country. In this regard, the existence of Japanese technical standards that are
not found in Europe is not necessarily a deviation from the international standards.
The technical regulations themselves are clear but general and abstract. As a complement to these standards,
the IEC and other concepts and calculation methods conventionally used in Japan for buildings and support
structures are used (e.g., guidelines published by the Japan Society of Civil Engineers, JSCE). According tointerviews with relevant parties, the differences from international standards are mainly related to thedifferences in meteorological and geological conditions in Japan compared to Europe: earthquakes, seabed,wind (typhoons), and waves, and specifically with regard to calculation methods and requirement levels (moreconservative). Some calculation methods are already established in Japan, but when various calculation
methods (e.g., JSCE standards, DNV, IEC) are assumed, it may be possible to be required to use all of themand compliance with the most conservative results may be required. This conservatism may come from theimplicit pressure to experts being involved to the conformity assessment which might lead them not to takerisks as decision makers, or the fact that risk-based assessment principles are not so common in practice. In
addition, since there is little accumulation of experiences for OSW in Japan, the business operator applying
for certification is required to prove the validity of methods and calculation results for which there is little
track record of certification, and academic papers are currently being used for this purpose. Conversely, during
the course of a review, the applicant may be asked to use a new approach or method that incorporates thelatest findings, which is considered in some cases as a deviation from the published standards on the thirdparty certification guidelines or the Official Explanation.
In Europe, Germany is the only country with an approach comparable to the Japanese Official Explanation.
Germany has its own unified ‘offshore wind standard’ (BSH 7004 and BSH 7005). With this, Germany
embarked on a special path as compared to other countries, as they refer more directly to the ISO/IEC ICRE
standards and leave much room to manoeuvre to the industry itself. Germany’s specific offshore standard
collects and describes in detail all the standards and regulations that apply specifically for the offshore area.
The standard gives much direction and transparency, but it also delayed the offshore wind industry and took
several years to develop.

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 47

As is the case in Japan now, Germany started with an expert committee that examined projects separately,
a.o. due to perceived specificity of sites and load concerns. After a certain period, the committee thendeveloped the overall standard and is since not directly involved with specific projects anymore, only with
updating the offshore standard on a regular basis.
While Japan did recently reform its permitting process to avoid double-work in regards to conformity
assessment, we find it relevant to point out these important elements of governance practices: 1) In Europe,
there is typically no government entity that is directly involved in undertaking conformity assessment, andall work is undertaken by fully independent third-party certification bodies that are independently accredited
by a single national accreditation body; 2) activities should be as centralized as possible, so that the same
competencies do not have to be built up in several different regional offices. In Europe, there is typically only
one national authority office responsible for all offshore wind permitting, and at best, permitting processes
are merged so that there is only one point of entry for project developers towards authorities.

5.1.2

Site investigations

The seabed in Japan is more complex than that of European North Sea (where until now most of offshore
wind development took place), with a mixture of sand and rock, and soft ground is common in harbours andinner bays.

HonsyuHokkaido

Tsugaru Channel

Soft rock (KUROMATSU.)

Kunnui Formation

Rhyolite

Fault

Soft rock (YAKUMO)

Medium-hard rock

Andesite/
IgneousLayerboundary

Setana Formation

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices

United Folkestone
Kingdom Terminal

English Channel（La Manche）

France. 48

Coquelles
Terminal

Gray chalk
Upper chalk
Chalk Marl (Lower)
Middle chalkGreensandMiddle chalkGold clay

Tunnel Route
Fault

Figure 13 Examples of seabed condition (upper: Tsugaru Strait, lower: English channel)
Source: MLIT, Ports and Harbours Bureau, “Study Group on Base Ports and Harbors for Achieving Carbon Neutrality by 2050 (1stmeeting),” (LITMay 18, 2021)35 Translation added by REI

Since the seabed often changes with a slight difference in distance, it is evaluated by grouping when the
ground structure and soil properties are judged to be similar based on the results of the preliminary survey
and geophysical exploration.
In Japan, the survey is based on the Standard Penetration Test (SPT). When the Cone Penetration Test (CPT),
which is popular in Europe, is used, it is necessary to contrast the former and latter methods, compare andstudy the data, and prove maintainability (safety). The number of data required for calibration of SPT and
CPT may be larger than expected in IEC61400-3-1. That is, IEC61400-3-1 requires soil borings at one locationin the vicinity of the CPT site, whereas the Official Explanation states that “it is desirable to compare data at
multiple locations” due to the complex and diversified seabed conditions as mentioned above.
The IEC61400-50 series on LiDARs has not yet been issued36, and the implementation of related standards
in Europe are not broadly decided yet. In Japan, there is no description on the use of scanning LiDAR andfloating LiDAR in the Official Explanation and no applicable standards and criteria have been established.
Therefore, the wind conditions are individually verified at each construction site using a ground-based
meteorological observation mast, a vertical LiDAR, and multiple scanning LiDARs. Currently, New Energy andIndustrial Technology Development Organization, NEDO, is conducting research to accumulate relevant data.
A report on data accumulation and utilization as well as recommended standards based on the report are
expected to be published within a few years.

35
36

https://www.mlit.go.jp/common/001404624.pdf
They will be expectedly published between July 2022 and May 2023.

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices

5.1.3

. 49

Seismic Load evaluation

In IEC61400 series, the evaluation of seismic loads can be done by either response spectrum methods ortime-domain methods. In Japan, the Official Explanation states that seismic loads shall be evaluated by
combined analysis of the load effects evaluated by time-domain methods and those of the annual average
wave and wind. The European regulations typically do not regulate the investigation methods in great detailand general integrated load analyses based on selected sub-set of load cases for fatigue and extreme loads
are conducted.
5.1.4

Materials

As mentioned earlier, materials that can be used in the construction of wind power generation facilities are
required to conform to JIS standards in principle37 and the authority incorporates the list of materials in theregulations. Therefore, non JIS materials are basically not eligible. Those include, as an example, steel with athickness of more than 100mm and bolts with M72 or larger, which are commonly used in Europe. Also, evenJIS materials cannot be used if they are not in the list. In such cases, it is necessary to obtain approval by athird-party certification body as having safety equivalent to or better than JIS standards, or to undergo aperformance evaluation to confirm compliance with the technical regulations under the Electricity BusinessAct and the Port and Harbour Act. In that evaluation, the necessary data must be available, such as chemicalcomposition, mechanical properties, and quality control systems in the manufacturing process. With regard
to floating OSW, for concrete materials used for the foundations of floating offshore wind power generation
facilities and synthetic fibres used for mooring cables, it is necessary to consult the Maritime Bureau of MLIT
in addition to complying with domestic standards (concrete materials) and international standards (mooring
cables). MLIT is currently formulating guidelines for synthetic fibre ropes.
In Europe, those parts of wind parks that are subject to the Machinery Directive, must be CE-marked. We
have not been made aware that there have been any issues with special approval processes required forcertain materials to be used in offshore wind farms.
Hence, in contrast to Europe, in Japan the conformity assessment of site suitability cannot be done fully bya third-party and a government entity must make a separate investigation, which increases time anduncertainty. As the testing of this thick steel is specified as using the same methodology and thresholds (295
N/M2) as with thinner steel, it could be considered to change this practice through regulatory reform, so that
additional approval processes can be avoided in this respect.

Materials that have been approved for use under certain conditions may be used. The examples include materials
approved by the MLIT in accordance with Article 37, Paragraph 1, Item 2 of the Building Standard Act before 2014.
37

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 50

5.2 Best practices identified that may be relevant for Japan
1) EFFECTIVE GOVERNANCE
There is a value in transparency and consistency, when all standards and documents are fully available andall actors meet the same requirements and are well qualified against the backdrop of the same requirements
and activities and use common operational documents. The IECRE conformity assessment standards andprocedures generally provide this transparency, consistency, and basis for trust. A major benefit of this is thatit enables mutual recognition between certification bodies and test labs. This benefits not only wind farmowners, but also financial and insurance entities, as well as government and regulatory authorities. This may
mean that, in some cases, national practices have to be retracted and subside to the internationally agreed
ones. This has now been done many times in Europe.
In terms of standard development, it is most effective to work in the international context. That is, wecurrently still see need for development regarding earthquake and typhoons (load case definitions andspecifications), for which the best option would be to update IEC 61400-1 (general design) and specific cases
where necessary, e.g., in 61400-3-1. In parallel, some ‘amendments’ can be adopted in the national context
to the current version to ensure that new insights are taken into account in a timely manner.
Regarding national technical regulation, it is worthwhile putting effort in identifying essential requirements
for a certain application, with focus on functions and interfaces, and less on ‘products’, and use this as basis
for the development of technical regulation. Here, the already established technical expert group could play
an important role in the identification of issues and the development of offshore-specific insights forstandards and technical regulation. It may be of benefit for the technical expert group to facilitate the further
inclusion of international offshore wind experience, through experts and knowledge exchanges.
Concretely for Japan, this would mean to:▪

Engage in development of IEC standards and IECRE guidelines to ensure that these embrace all
Japanese conditions, incl. design load cases for earthquake, typhoon. And then, trust in them andenable direct adoption in Japan. This could also include collaboration with certification bodies thatissue their own guidelines as these can be implemented and amended faster.

▪

Limit the scope of core certification to essential requirements▪

The same standards, regulations, processes, and calculation methodologies should apply for all
projects▪

Provide national leadership to build consensus, take in critical information from wind experts andindustries to regulators and state agencies. Here, Japan can become a role model for the whole region.

▪

Refocus the role of technical expert group to focus on the topical content of the design basis, on
standard development and general questions e.g., on load cases and methodology, instead of being
involved in specific project-level decisions.

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 512) TRANSPARENT REQUIREMENTS WITH FREQUENT UPDATESMost European countries rely on the accountability of the sector. Wind farm developers, finance providers
and insurers all have in their interest to build safe and reliable wind farms, and have in the past proven to
subject themselves to rigorous conformity assessment even if not mandated by law. Public procurement foroffshore wind (through tenders) energy typically mandates project certification, although most countries do
not have detailed technical regulation that detail the specific requirements.
However, the path that seems most applicable to Japan, and on which the country has already embarked on,
is to follow a different approach and to develop a dedicated “offshore wind standard”, similar to the BSH
standard in Germany. Continuing along that path would mean to further develop the “unified explanation” forall standards and regulations applicable for offshore wind. In this endeavour, we see it as crucial that a main
goal in the further development is streamlining, ensuring fast adoption of new elements, and creating
predictability.
Concretely for Japan, this would mean to:▪

Continue to develop a comprehensive unified offshore standard that becomes the single reference
document for all offshore wind related regulation and that is equally applied across all projects. This
may delay the process and may not been acknowledged a necessary by all actors, but it seems to be
the way forward taking into account Japanese culture and traditions.

▪

Piece-wise updating of standards, quick publication of additions / clarifications. To avoid extensive
delays, the document can be built up and adopted step-wise.

▪

Exploit the options of a dedicated offshore wind standard. It could e.g., contain exemptions fromother national standards or from ‘positive lists’ for materials, if a deviation is deemed safe foroffshore wind applications.

▪

Establish a system that ensures fast adoption processes of new international standards and updates
to regulation from new national knowledge. This could e.g. include parallel voting to adopt new
ISO/IEC standards.

▪

Establish a system for early piloting in low-risk applications (e.g., LiDAR) and options to feed
experiences back into the national offshore standard development. This could e.g. be measurementof wind speed and turbulence intensity by floating LiDAR

3) LIMIT ‘SPECIAL’ REQUIREMENTS
International collaboration on international standards has proven to lead to efficiency gains in the industry
and to be less costly for all parties in the long run. Governments do not have to develop their own guidance‘in-house’, but can choose from suitable available standards. These can be ISO/IEC or others, e.g. also
guidelines from accredited certification bodies.
The need for separate approval processes for specific design elements is rendering the overall process rather

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 52

ineffective and can prolong the development phase and make the offshore wind energy more costly in thelong run. E.g., the lack of JIS standards for very thick steels means that a government entity must make aseparate investigation, which increases time and uncertainty. As the testing of this thick steel is specified asusing the same methodology and thresholds (295 N/M2) as with thinner steel, it seems that this process
could be streamlined.
Concretely for Japan, this would mean to:▪

Reconsider the practice of using ‘positive lists’ for materials that can be used for offshore wind▪

Allow for the use of thicker steel and bolts without specific and separate process for government
assessment, through inclusion in standard or unified explanations▪

Reconsider the requirement to use JIS certified steel for offshore wind, potentially allow trusted
certifications from other countries to enlarge market and increase flexibility.

4) FLEXIBILITY IN COMPLIANCE
An increased flexibility in requirements for compliance demonstration could be adopted with increased
experience in the sector. It could be worthwhile reconsidering several areas once experience has been gainedwith the aim to increase flexibility in compliance options, e.g., by using different methodologies in thedemonstration, or by substituting certain requirements in sub-parts if overall compliance can bedemonstrated. The following areas could be included in a monitoring for flexibility increase potential:▪

Risk-based assessment principles, to balance accountability and cost drivers▪

Case-by-case modifications to certification, for potential substitutions if overall compliance can bedemonstrated

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 53

Part II Accreditation system and certification procedures

6 Accreditation

procedures

andcertification

systemfor

conformity assessment bodies in Japan
6.1 Procedures for accreditation of conformity assessment bodies
In Japan, a third-party certification body is accredited by the Japan Accreditation Board (JAB) based on
ISO/IEC17065 (JIS Q 17065). JAB is a member of the International Laboratory Accreditation Cooperation(ILAC), an international organization of accreditation bodies for testing and inspection laboratories and has
agreed to the ILAC Arrangement.
JAB has established "Sectoral Guidelines on 'Criteria for Accreditation' - Wind Power Generation Systems:
Wind Farms, Projects" 38 as guidelines applicable to product certification bodies accredited under JIS Q
17065:2012 (ISO/IEC 17065IDT) for the certification of wind power generation systems. According to thisguideline, the evaluation method is based on JIS C 1400-22:2014, which is equivalent to IEC 61400-22 Ed.
1.0, and the method specified by the "Site Conformity Assessment Methodology for Wind Power Generation"of the Japan Electrical Manufacturers' Association, JEMA. In addition to JIS and international standards, laws
and ministerial ordinances, their interpretations, and the JSCE guidelines are listed as criteria for assessing
conformity.
Currently, Nippon Kaiji Kyokai (Class NK) and Bureau Veritas Japan K.K. are accredited as third-party
certification bodies.
The JAB guideline does not mandate the establishment of an expert panel in the certification process, but it
is recommended in practice. Both organizations have incorporated the review by the expert panel into theirprocedures.
The part of the JAB guideline referring to the resource requirement is as follows:

6. resource requirements
6.1 Personnel of the certification body
In addition to JIS Q 17065 clause 6.1, the following shall apply. Assessment personnel shall have theknowledge and experience to conduct the assessment specified in clause 7.4, and the skills to conduct

Japan Accreditation Board for Conformity Assessment, JAB PD366:2017https://www.jab.or.jp/files/items/common/File/PD3662017V2.pdf
38

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 54

the assessment. In the assessment, such knowledge and experience may be fulfilled by the assessment
team. The reviewer of the evaluation results should have knowledge of the evaluation items, pass/failcriteria, and evaluation methods in order to verify the appropriateness, sufficiency, and effectiveness of
the results of the evaluation activities. Certification decision makers should have knowledge ofcertification criteria, certification schemes, and conformity assessment systems in order to judge theappropriateness of review results and make certification decisions. The reviewer of the evaluation results
and the certification decision maker may serve concurrently.

6.2 Outline and activities of the accredited body in Japan
Among two conformity assessment bodies in Japan, ClassNK’s activities are worth being introduced due totheir track record in Japan compared to Bureau Veritas Japan which is recently accredited in November 2021.
ClassNK is one of the eleven classification societies of the International Association of Classification Societies(IACS), headquartered in Japan, with the same background as other classification societies such as DNV and
BV, which act as wind power certification bodies. It has the same background as other classification societiesthat act as wind power certification bodies, such as DNV and BV.
Its activities are diverse and include classification services, management system certification (ISO related),
and technical and training services.
In the area of renewable energy, they offer the following services39oType certification of wind turbinesoWind farm certificationoClassification of floating offshore wind turbinesoTechnical assessment of wind turbine support structures (including material certification)oWind turbine support structure manufacturing assessmentsoThird-party verification of wind turbine-related technologiesoPeriodic safety management auditoMarine Warranty Surveyo

GWO Training CertificationoPublication of guidelines

The guidelines for wind power published by ClassNK are as follows. Guidelines for bottom-fixed offshore wind
have not yet been opened in public other than OSW business operators and will be developed and publishedpending the accumulation of case studies.
o39

Certification Guideline for Wind Power Generation System (NKRE-GL-WT01, October2021) (publishedhttps://www.classnk.or.jp/hp/ja/authentication/renewableenergy/index.htm

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 55

May 2014, revised October 2021)
This guideline "prescribes rules and procedures for a certification system for wind turbines, consisting oftype certification and project certification of onshore and offshore wind power plant" and the standards citedare the IEC61400 series and other ISO and IEC standards.
oWind Farm Certification Onshore Wind Farms Edition (NKRE-GL-WFC01, Edition: July 2021) (published
July 2021)

This standard "specifies requirements for onshore wind farms subject to wind farm certification." "In theevent of any changes to the requirements for Construction plan review based on the Electricity Business Act,
such requirements shall take precedence over the provisions of this guideline”. Cited standards include
international standards, technical regulations (ministerial ordinances), their commentaries and JSCE
guidelines as included in accreditation standards by JAB.
o

Guidelines for Floating Offshore Wind turbine - Classification Survey - (NKRE-GL-FOWT01, Edition:
December 2021) (issued in December 2021)

This is a new edition of the "Guidelines for Floating Offshore Wind Turbine Generation Facilities" publishedin July 2012. Cited standards include not only IEC, but also technical regulations and other laws andregulations (e.g., ministerial ordinances of MLIT, those of METI, their interpretations, their commentaries, andOfficial Explanation).
ClassNK is committed to independence, impartiality, and third-party reliability. . Meanwhile, there is aconsulting company, ClassNK Consulting Services Inc. According to its website, the company provides
consulting services related to ship construction, operation, and management. According to other public
information as of July 2021, the representative director of Japan Wind Energy Consulting, Inc. 40 is
concurrently working as the leader of the Wind power group of ClassNK Consulting Services from June in2020. The services of Wind Energy Consulting include conducting wind condition campaign or other site
condition assessments, load analysis, preparing marine documentation for a Wind farm certification, andassisting in the response to the expert panel reviews.41

6.3 Conformity assessment practice
6.3.1

The modules of Wind farm certification

Wind farm certification consists of (1) Site conditions assessment, (2) Design basis evaluation, (3) Integrated
load analysis, (4) Wind turbine (RNA) design evaluation, and (5) Support structure design evaluation, all ofwhich are conducted in the case of offshore wind farms.

Carbon Trust and ClassNK, “Invitation for OSW Webinar, Offshore wind campaign and the technology of floating LiDAR,
held July 21, 2021” (event flyer), https://www.classnk.or.jp/hp/pdf/press/beshi20210706_001.pdf
41Japan Wind Energy Consulting Inc. website, https://www.jwinc.co.jp/services/40Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 56

Figure 14 Wind farm certification modules and flow
Source: ClassNK, “ClassNK Wind Turbine Certification and Related Services [Public website version],” August 2021, p.17

Currently, the RNA evaluation is conducted repeatedly by the secretariat and the Large Wind Turbine
Certification Subcommittee, which includes experts, until compliance with the technical standards, etc. isconfirmed. Regarding the support structure related matter, the business operators (e.g., developer, design
company, turbine manufacturer) directly explain the design to the panel members at the meetings of expert
panel (Support Structure Certification Subcommittee).

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 57

Figure 15 Flow of the review of ClassNK certification related to the RNA (upper) and the support structure (lower)
Source: “ClassNK Wind Turbine Certification and Related Services [Public website version],” August 2021, p.23,24

6.3.2

Issues related to the practice

Several issues have been raised in relation to the expert panel review in the procedures.
One example is that the interval of the panel meetings can be several months, which is pointed out as areason of the lengthy process to obtain a certification. These issues may be due to the limited experience
with offshore wind in Japan, the fact that the certification process itself is still in the process of development,
and the limited number of experts who are familiar with offshore wind due to the limited experience.
Since the third-party certification procedure is followed by METI review based on the Electricity Business Act,developers are currently required to undergo two reviews of the Construction plan and to respond to thepoints raised by the respective expert groups. If the members of the expert panel in the certification procedure
are different from those of METI Expert committee, the developer will be at risk of having to deal withdifferent requests from METI expert committee even after obtaining a third-party certification. This mightlead developers to select a certification body with similar membership in both panels to avoid the risk.
METI considered a reform by involving the members of their Expert committee in the third-party certification
procedure in order to streamline the whole process. Even though the aim of the reform was correct, theintervention of a government in such way may raise doubts about the independence of the third-party
certification body.
The latest reform planned by METI to establish a new conformity assessment body could streamline theprocess by omitting the review by the METI Expert Committee, but it seems uncertain how this new scheme

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 58

would affect the independent, third-party certification process now existing in Japan.
Meanwhile, there exists a concern raised from European stakeholders related to the monopoly and oligopolyof certification procedure and potential conflicts of interest. In the interviews, no one pointed out any conflictof-interest issues with respect to ClassNK itself.

7 Accreditation

procedures

andcertification

systemfor

conformity assessment bodies in the EU
7.1 System for conformity assessment in the EU
It is European practice (and required in the IEC conformity assessment system) that all conformity
assessments are undertaken by an accredited third party, i.e. that the assessment activity is performed by abody that is independent from the manufacturer or the buyer of equipment, and that is recognized by agovernment authority for this task.
To undertake conformity assessments under the IECRE system, a certification body must be accredited e.g.
to ISO/IEC 17065 (product certification). The process of accreditation is set out in the international standard
ISO/IEC 17011 Conformity assessment — Requirements for National Accreditation Bodies accrediting
Conformity Assessment Bodies. Requirements for accreditation in the EU are set in EU Regulation 765/2008
according to the main principles of:▪

Maximum one accreditation body per EU country (it is possible to use another country’s accreditationbody) and no competition between bodies▪

Accreditation as a public sector activity, not a for-profit activity▪

Accreditation as the preferred way of demonstrating technical capability to carry out certification▪

Stakeholders are represented

In terms of anchoring in European legislation, Article 42(5) of the Regulation 2016/679/EU of the European
Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to theprocessing of personal data and on the free movement of such data provides that certification shall be issued
by an accredited certification body or by a competent supervisory authority.

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices

7.1.1

. 59

Accreditation bodies and their organisation

Each country’s accreditation entities are in charge of accrediting companies for the certification of offshore
wind projects, offshore wind turbines and their components, etc. The following table shows the accreditationbody for each major country leading offshore wind development in Europe.
Table 7 Accreditation body for each major country leading offshore wind development in Europe

Netherland
Belgium

Denmark

FranceGermanysPortugal

Sweden

UK

BELAC

DANAK

COFRAC

DAkkS

RVA

IPAC

SWEDAC

UKAS

Accreditation
body

Accreditation bodies in Europe are independent entities. The Danish DANAK, for example, is organized as afoundation. It is mostly financed through client payments in connection with undertaken accreditation tasks.
DANAK’s work in international networks as a representative of the state is financed through the state budget.
The German DAkkS is an independent firm (GmbH), whose shareholders are the German state (33.33%), theGerman Industry Association (33.33%) and three federal states (11.11% each). The French COFRAC is anassociation with a large number of members, comprising diverse stakeholders.
The national accreditation bodies are organised in a European network called European Accreditation (EA).
EA, a not-for-profit association, has been instrumental in harmonising accreditation criteria across Europe.
EA developed the ‘Accreditation for Nofitication’ (AfN) package, published in 2016, which includes guidance
documents and good practices on assessment for accreditation. The current version is implemented as ofApril 2021 (EA-2/17 M:2020)42. The notification, as well as the accompanying project document43 contains
detailed explanations and lists of preferred standards for use in many application areas. In 2021, EA also
published an informative report “Accreditation – a tool to support regulators”44.
EA spans broader than only Europe. It has 36 Full Members and 13 Associate Members, also including
countries like Ukraine, Algeria, Israel, Azerbaijan, Eqypt and Jordan. The Multilateral Agreement (MLA)
between all EA accreditation body members established mutual automatic acceptance of accredited
certifications, inspections, calibration certificates and test reports. The reach of the MLA is further broadened
to international level by the International Laboratory Accreditation Cooperation (ILAC) and the International
Accreditation Forum (IAF). The robustness of the MLA is maintained through a strong peer evaluation process,in which bodies are regularly evaluated every four years. The peer evaluation system has been quite activein the past, e.g. in 2016, peer evaluation teams had reported a total of 135 findings where corrective action
was required by national accreditation bodies. In 2014, one Accreditation Body had actually been suspended

https://european-accreditation.org/wp-content/uploads/2018/10/ea-2-17-m.pdf
https://european-accreditation.org/wp-content/uploads/2020/04/AFN-PROJECT-2021.pdf
44
https://european-accreditation.org/wp-content/uploads/2018/10/accreditation-a-tool-to-support-regulators_1.pdf
4243Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 60

for a period (EC 2017). The MLA process is overseen by the European Commission, the EA Advisory Boardand the national authorities.
EA receives EU funding to assist in drawing up and updating of contributions to guidelines related toaccreditations, carrying out work related to peer evaluations, giving assistance to third countries, andparticipating in international organisations in the field of accreditation.

7.1.2

The procedure of accreditation in European countries

In order to become accredited and then carry out project certification, a body needs to pass the accreditation
procedure. In France, for example, the phases are the following: once the application has been submitted,
COFRAC, the accreditation body, proceeds with an operational admissibility review. The purpose is to check if
the applicant understood correctly all the requirements in order to be accredited and to determine how theassessment is to be carried out on-site with regard to the accreditation regulations and the body's
organization. Then, the on-site assessment is carried out for the applicant to demonstrate its competence
and the conformity of its operation to the accreditation requirements. Different techniques are deployed:
review of documents and records, interviews with staff, witnessing of activities presented for accreditation,
traceability audits of technical operations, etc. Once accreditation is issued by the assessment team, asurveillance programme is set up by COFRAC over the accreditation period, according to the terms laid out inthe accreditation regulations. Surveillance is carried out similarly to the initial assessment, but it is adapted
according to the results of the previous assessments and the changes made within the body, in terms ofresources and organization. There is possibility to extend the accreditation.
The process for accreditation in Denmark by DANAK and in the Netherlands by RVA is very similar to theprocess in France described above.
Typical accreditation cycles span 2 to 5 years, after which accreditation can be renewed after a complete
assessment for a new cycle. National Accreditation Bodies carry out regular surveillance assessments toensure that accredited bodies continue to live up to the high standards of technical expertise. They can impose
sanctions when certification bodies do not fulfil all obligations and requirements. Accreditation scopes canbe reduced, suspended or withdrawn.
Member States must inform the European Commission and the other Member States that a body, which
fulfils the relevant requirements, has been designated to carry out conformity assessment according to arelevant directive. This act is called ‘Notification’. In the European context, accredited certification bodies are
therefore also referred to as ‘Notified Bodies’. Lists of Notified Bodies can be searched on the NANDO (NewApproach Notified and Designated Organisations) website45.

45

https://ec.europa.eu/growth/tools-databases/nando/index.cfm

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices

7.1.3

. 61

Certification bodies in Europe

In most cases, third party certification bodies have testing and certification as their main focus of work andare commercial for-profit companies. Note that conformity assessment undertaken by a third party is
typically more expensive than a first party (in house) conformity assessment.
The certification bodies vary from a country to another in Europe as shown below*.
Table 8 Certification bodies in Europe

Certification body

Denmark France

Germany Netherlands Portugal

DNVx

Bureau Veritas

x

TÜV

x

x

UL

x

x

Lloydsx

SwedenUK

xx

WindGuard
certification
Hanseatic Power Cert

x

x

x

x

x

x

x
x

* For Belgium, no relevant information has been found.

Certification bodies engage in three main areas of conformity assessment46:(1) Calibration and Testing – Certified testing and test reports are provided for various calibration andperformance testing for wind energy equipment and project performance.
(2) Equipment – The equipment certification scheme provides procedures for conformity assessment to IEC
standards for WTGs and components, including prototypes.
(3) Projects – conformity assessment of a complete wind farm project or individual installation associatedwith the wind farm
7.1.4

Certification activity for offshore wind in Europe

IECRE provides data concerning certifications given by Bureau Veritas, UL, DNV and TÜV. In total, 156 valid
certifications to Europe firms are listed.

https://share.ansi.org/Shared%20Documents/Standards%20Activities/International%20Standardization/IEC/Communi
cations%20Committee/Conformity%20Assessment%20in%20the%20Wind%20Energy%20Industry.pdf
46Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 62

Table 9 Total number of valid certifications for each certification body

Total number of valid certifications for each certification body
80
70

60
50
40
30
20
10
0
Bureau Veritas

UL

DNV

TÜV

Despite its presence in most of the countries at stake, Bureau Veritas delivered only a few certifications
according to IECRE data. But since IECRE does not track local offshore wind project certifications, this picture
is skewed, as project certification is the area where Bureau Veritas seems to be more involved in. Besides,
being accredited in a country does not mean that the company ever gave any certification in this country.
Below, we show the types of certifications listed by IECRE within offshore wind in Europe. In the following
figure, the 3 main areas are CS (Design evaluation and conformity statement), CC (component certificate)
and TC (type certificate). The allocation among each of the 4 certification bodies is shown.
Table 10 Total number of valid certifications per certification type

Total number of valid certifications per certification type
90
80
70
60

UL

50

TÜV

40

DNV

30

Bureau Veritas

20
10

0
DC

PTC

QC

TC

CC

CS

Finally, companies seem to have preferences concerning the body in charge of certification of their products.

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 63

As examples and according to IECRE data:-

Vestas Wind Systems works only with DNV (34 certificates obtained)-

LM Wind Power works mainly with TÜV (15/21)-

Siemens Gamesa works mainly with TÜV (20/29)

In regard to project certification, we see some more diversity in collaboration, where e.g. Ørsted collaborated
with Bureau Veritas on Borkum Riffgrund 2 and Borssele 1&2, with UL on Borkum Riffgrund 3 and Gode Wind3, with TÜV on Borkum Riffgrund 1, and with DNV on Anholt and Horns Rev 2. Vattenfall collaborated withTÜV on Kriegers Flak and Hollandske Kuist 1-4, and with DNC on Horns Rev 3.

7.1.5

International recognition of conformity assessment bodies

The EU has in the past pursued cooperation agreements, which enable conformity assessment bodies in the
EU to test products for export to other world regions and vice versa. This alleviates the need to pay twice forthe same test and decreases time to market. These agreements are called Mutual Recognition Agreements(MRAs) and are bilateral between the EU and a third country. MRAs lay down the conditions under which theparties accept conformity assessment results performed by either party’s designated conformity assessment
bodies (CABs) to show compliance with each other’s requirements. MRAs include relevant lists of designatedlaboratories, inspection bodies and conformity assessment bodies in both the EU and the third country.
Currently, there are MRAs in place between the EU and Australia, Canada, Japan, New Zealand, the USA,
Israel and Switzerland (EC, 2022).
The agreement between the EU and Japan is from 200147 and operational for the following sectors:▪

Electrical Products▪

Telecommunications Terminal Equipment and Radio Equipment▪

Good Manufacturing Practice for Medical Products▪

Good Laboratory Practice for Chemicals

The agreement stipulates that each party shall accept results of conformity assessment procedures,confirmation of facilities conducted by the competent authorities, and data generated by confirmed facilities.
This is valid for listed approved conformity assessment bodies in the agreement. No designated conformity
assessment bodies are in the area of electrical products.

47

Official Journal L 284 , 29/10/2001 P. 0003 - 0032

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 64

7.2 Best practices identified that may be relevant for Japan
1) INDEPENDENCE
National Accreditation Bodies are independent, non-for-profit bodies that operate with government
recognition according to internationally recognised standards and are themselves regularly reviewed byinternational peers. Government representatives are welcome to observe evaluations, but have no formalrole in the process. The accreditation authority is typically separate from the regulation or permitting authority.
The internationally implemented process of peer evaluation with rigorous assessments and on-site
evaluations of quality systems, processes, and records of accreditation bodies to ensure the continuing
conformity with internationally accepted criteria (such as ISO/IEC 17011) is a strong instrument to ensureaccountability and quality of accreditation.
Concretely for Japan, this would mean to:▪

Ensure separation and independence of conformity assessment regulation and accreditation,
following international standards such as ISO/IEC 17011. Accreditation should be undertaken by anindependent body that is not directly involved in development of standards, technical regulation or
permitting of projects.

2) ‘THIRD-PARTY’ APPROACH
Only third parties undertake conformity assessments. No government body is directly involved in conformity
assessment in wind energy. This requires a number of capable accredited third-party bodies to choose with
sufficient experience in the area.
Concretely for Japan, this would mean to:▪

Assessments undertaken by independent accredited bodies only – avoiding ‘double’ certification
through authorities. Even if a government body has responsibility for specific assessment tasks, thiscan be executed by an accredited independent body.

▪

Enlarge the basis for accredited conformity assessment bodies, to ensure competition, introduce
more knowledge into the sector and ensure that there are sufficient capacities available for an
accelerated expansion of offshore wind.

3) INTERNATIONAL COOPERATIONThe European system includes a strong emphasis on mutual recognition, which extends to flexibility within aproject certification process: as certification bodies accept conformity statements by other IECRE accredited
certification bodies to different project certification modules, developers can, in principle, engage different

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 65certification bodies for different modules.
The strategic development of international cooperation and mutual recognition agreements between
accreditation bodies and their associations has proven very valuable. Certification bodies accredited in one
EU member state may also operate in others.
This may also a (however weak) mitigation against potentially dominating certification bodies within acountry.
Concretely for Japan, this would mean to:▪

Pursue multilateral and bilateral recognition and acceptance of standards and conformity
assessment4) TRANSPARENCY AND COMMUNICATION
Transparency in the accreditation can help develop the market. Many European countries are recognizing thepotential of accreditation as basis for trust and a well-functioning market. E.g., Ireland has in May 2022
published its first ‘Strategy for Accreditation’ 48 with the aim to inform and influence national policy, topromote awareness and engagement, to grow uptake and application of accreditation and to develop
governance, organisational design and structure of accreditation.
Concretely for Japan, this would mean to:▪

Actively engage in communication and information efforts around accreditation and conformity
assessment procedures, especially in case of updates and changes

48

https://www.inab.ie/news-resources/news/strategy-for-accreditation-may-2022.pdf

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 66

REFERENCES
BSH 7005 “Standard Design - Minimum requirements concerning the constructive design of offshore
structures within the Exclusive Economic Zone (EEZ)”, 1. Update 28 July 2015 – Corrected as of 1
December 2015, Federal Maritime and Hydrographic Agency (BSH)
https://www.bsh.de/DE/PUBLIKATIONEN/_Anlagen/Downloads/Offshore/Standards/StandardDesign_en.pdf?__blob=publicationFile&v=7
BSH 7004 “Standard Ground Investigations Minimum requirements for geotechnical surveys andinvestigations into offshore wind energy structures, offshore stations and power cables”, Second
update from 5. 2. 2014, Federal Maritime and Hydrographic Agency (BSH),
https://www.bsh.de/DE/PUBLIKATIONEN/_Anlagen/Downloads/Offshore/Standards/Standard-Groundinvestigation-for-offshore-wind-energy_en.pdf?__blob=publicationFile&v=6
Bureau Veritas – Guide on Offshore Wind Farm Project Certification BV-WFPC 100 (based on IEC 61400
Series)https://www.yumpu.com/en/document/read/10277406/guide-on-offshore-wind-farm-project-certificationmer-veillecom
Dimova, S., Fuchs, S., Pinto, A., Nikolova, B., Sousa, L. and Iannaccone, S. (2015), State of Implementation of
the Eurocodes in the European Union, available at:https://doi.org/10.2788/854939.
EC 2017 REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL AND THE
EUROPEAN ECONOMIC AND SOCIAL COMMITTEE COM(2017) 789 final. https://eur-lex.europa.eu/legalcontent/EN/ALL/?uri=COM:2017:789:FIN
EC 2022 https://ec.europa.eu/growth/single-market/goods/international-aspects-single-market/mutualrecognition-agreements_en
ECN (2000) Experience of Wind Turbine Manufacturers with Wind Turbine Certification. Frans van Hulle(ECN), Christian Nath (Germanischer Lloyd), Christer Eriksson (Det Norske Veritas), Pantelis Vionis(CRES). Report of Subtask A1 of project EWTC. European Research Project EWTC, contract JOR3-CT980265. Available at: http://resolver.tudelft.nl/uuid:f7ee1d2e-7e32-4a9e-95e2-6ca5a1bf7342.
Fischer, J., Jost, O., Richter, M. and Wiemann, J. (2020), Presentation and Comparison of Site Investigation
Methods for Offshore Wind Energy in the European North Seas Countries in the Context of the EU
North Seas Energy Cooperation. Final Report, Fichtner Water & Transportation GmbH, on behalf of theGerman Environment Agency (Umweltbundesamt, UBA), EVUPLAN Project No. (FKZ) 37EV 17 103 0,
Report No. FB000323/ENG, TEXTE 186/2020. ISSN 1862-4804.
IECRE – Wind energy certificateshttps://certificates.iecre.org/#/search

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 67IEC, 2022 https://www.iec.ch/understanding-standards
IHO International Hydrographic Organization (2008): IHO standards for hydrographic surveys. 5th edition,
special publication No. 44, Monaco, https://www.iho.int/iho_pubs/standard/S-44_5E.pdf
ISO, 2022 https://www.techtarget.com/searchdatacenter/definition/ISO
ISO, 2019 https://www.iso.org/files/live/sites/isoorg/files/store/en/PUB100358.pdf
NREL 2014 https://www.nrel.gov/docs/fy14osti/60573.pdf
Schuppener, B. and Ruppert, F.R. (2009), “Merging European and German standards-eurocode 7, DIN 1054
and DIN 4020”, Bautechnik, Vol. 86 No. SUPPL. 1, pp. 2–6.

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 68

APPENDIX A: Definitions

Key Pillars in a National Quality Infrastructure.
Source: https://www.inab.ie/news-resources/news/strategy-for-accreditation-may-2022.pdf

Accreditation: Independent evaluation of conformity assessment bodies (CABs) against recognised
standards to ensure their impartiality and competence to carry out specific activities, such as tests,
calibrations, inspections and certifications
Certificate: Document in which an accredited body gives written assurance that a product, process or service
conforms to specified requirements, i.e. prove that certification has been completed successfully.
Certification: Procedure by which a third party gives written assurance that a product, process or service
conforms to specified requirements. Also known as conformity assessment, i.e. according to IECRE OD501.
Component certification: Issued for e.g. rotor blades, generators, gearboxes, electrical components, brakes,
couplings, nacelle frames, towers, main bearings or systems such as pitch systems, yaw systems, fire
protection systems, condition monitoring systems or parts such as bolts and tower internals. For floating
support structures, component certification will typically be relevant for e.g. mooring components.
Conformity Assessment: Procedure by which a third party gives written assurance that a product, process

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 69

or service conforms to specified requirements, based upon a given certification scheme for which thecertification body is accredited. In this report, we will focus on third-party conformity assessment only, inwhich certification is performed by a person or organisation that is independent of the seller or the buyer.
Conformity Assessment Body (CAB): Entities that perform testing, calibration, verification, certification or
inspection services
Multilateral Agreement (MLA): A signed agreement between the EA Members whereby the signatories
recognise and accept the equivalence of the accreditation systems operated by the signing members, andalso the reliability of the conformity assessment results provided by CABs accredited by the signingmembers.
Regulatory framework: Generally, the published and official laws, standards, guidelines…
Standards: Provide instructions, guidelines, rules or definitions that are then used to design, manufacture,
install, test & certify, maintain and repair electrical and electronic devices and systems. Not in principle
compulsory, but usually the easiest or in practice the only way to meet the more detailed, law-based
requirements.
Technical regulations: Regulations are rules or directives that are made and maintained by a national orregional authority. Generally, compliance with regulations is generally compulsory, such as with laws.
Internationally, it is quite common for technical regulations to refer to international standards because
standards help avoid that the law becomes too detailed or descriptive. This approach allows laws to stay
current because standards are regularly reviewed and updated.49
Type certification: Wind turbine types shall be certified according to defined standards by an accredited
certification body. Within the wind industry, type certification means certification of the wind turbine rotornacelle assembly and its components. The type certification is in general a certification of a type of turbine
considering generic wind conditions (wind turbine class). A generic tower type is part of the type certificate.
However, especially for offshore wind, a tower is always designed site specific, thus part of the projectcertification. Also other site-specific components such as foundations and assets such as offshore
substation and power cables are not type certified.
Project certification: To evaluate whether a wind farm, including type-certified wind turbines, their support
structures and auxiliary installations is designed according to applicable standards, construction codesand other relevant site-specific requirements. The applicant is usually the developer. Project certification
may be required by law, by authorities, financial institutions, or by insurers.
Validity of a project certificate: The project certificate is issued for a certain tested design and thus valid
only for this specific design and installation. The project certification is restricted and depends on regularsurveillance of the O&M activities.

49

https://www.iec.ch/understanding-standards

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 70

APPENDIX B: Extract of the Technical Standards for Floating Offshore Wind Power
Generation Facilities related to the issued discussed in the report"Safety Guidelines of Technical Standards for Floating Offshore Wind Power Generation Facilities" (Maritime
Bureau, MLIT, hereinafter, “Safety Guidelines”) , the explanative document of the Technical Standards, arealso referred to when relevant.

1. Safety regulations
Chapter 1 External Conditions
4-1. Earthquakes(1) The effects of earthquakes shall be appropriately considered. The largest earthquake that has everoccurred in the vicinity of the installation site shall be taken into account.
(2) The effects of tsunamis shall be considered appropriately. For tsunamis, the largest tsunami that has everoccurred in the vicinity of the installation area shall be considered. However, if the water depth is deep enough,tsunami effects may be considered as tidal fluctuations and ocean currents.
(3) When considering earthquakes and tsunamis, environmental loads such as wind and waves may be
assumed to be those under normal conditions.
(4) Liquefaction of the seabed in the event of an earthquake shall be considered.

Chapter 2 Rules for Structure
Section 1 Materials 1. Materials to be used
(1) Materials specified in the Ship Structure Rules (1998 Ministry of Transport Ordinance No. 16) shall be
used for the main structural parts of floating offshore wind power generation facilities and for drainage
facilities, etc.
(2) If materials other than those specified in (1) above are to be used, an inquiry should be made to the
Director, Inspection and Survey Division, Maritime Bureau, MLIT, together with the necessary data.

Chapter 3: Position Retention System
3. mooring analysis

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices
Status. 71

Safety factor
Chain and wire rope

Synthetic fibre ropeNon-damaging
Dynamic analysis

1.67

2.50

Quasi-dynamic analysis

2.00

3.00

Single cable breakage (equilibrium state after breakage)
Dynamic analysis

1.25

1.88

Quasi-dynamic analysis

1.43

2.15

Transient state at single cable breakage
Dynamic analysis

1.05

1.58

Quasi-dynamic analysis

1.18

1.77

Table 3-1 Safety factor of mooring line

Chapter 4 Regulations Concerning Facilities
2. Equipment related to engines
To be conformed to the Ministerial Ordinance for Ship Engine (Ministry of Transport Ordinance No. 28 of1984)

3. Facilities related to electricity
To be conformed to the Ministerial Ordinance for Ship Equipment (1934, Ministry of Posts andTelecommunications Ordinance No. 6), Part 6

5. Elevating facilities (if any)
To be conformed to the Ministerial Ordinance for Ship Equipment (1934 Ministry of Posts andTelecommunications Ordinance No. 6), Part 7, Chapter 1.

6. Landing facilities for rotary wing aircraft (if any)
To be conformed to the Guide to Ship Inspection 3-1 Annex [9]Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices. 72

2. Materials
2.1 Concrete materials
Chapter 2
1. materials to be used
(1) Materials specified in the Ministerial Ordinance for Ship Structure (1998 Ministry of Transport Ordinance
No. 16) shall be used for the main structural parts and drainage facilities of floating offshore wind power
generation facilities.
(2) If materials other than those specified in (1) above are to be used, an inquiry should be made to the
Director, Inspection and Survey Division, Maritime Bureau, MLIT, together with the necessary data.
"Safety Guidelines"
When used as a structural strength material of a floating facility, tower, etc., it is necessary to confirm thatit has sufficient safety by conducting an appropriate strength evaluation.
For details, refer to References 2-1) and 2-2) and other domestic guidelines related to concrete structures.
Reference 2-1: JSCE Standard Specifications for Concrete [Design Edition], 2012
Reference 2-2: JSCE Standard Specifications for Steel and Rigid Structures, General Provisions, Structural
Planning and Design, 2007

2.2 Synthetic fiber cables
Chapter 3, 5 Mooring Equipment(2) Chains, wires, etc.
(a) Chains, wires or synthetic fibre ropes, intermediate sinkers, intermediate buoys, anchors that serve as
mooring points on the seabed, sinkers, piles, etc. used for mooring systems shall be those approved as
appropriate by the competent marine authority.
“Safety Guidelines"(2) Chains. Wires, etc.
Chains, wires or synthetic fibre ropes, intermediate sinkers, intermediate buoys, anchors serving as mooring
points on the seabed, sinkers, piles, etc. used for mooring systems shall comply with international standards
and shall be approved by the competent marine authority.

Sectoral Study: Standards, technical regulation and conformity assessment in the Japanese andEuropean offshore wind power market: current implementation and best practices––©European Union, 2022
Reuse is authorised provided the source is acknowledged. The reuse policy ofEuropean Commission documents is regulated by Decision 2011/833/EU (OJ L 330,
14.12.2011, p.39). The content and opinions expressed are those of the authorsand do not necessarily represent the views of the European Commission or any
other body of the European Union and the Commission cannot be held responsible
for any use which may be made of the information contained therein.
Luxembourg: Publications Office of the European Union, 2022

Print

ISBN 978-92-76-56956-5 doi: 10.2781/460020 NG-09-22-524-EN-C

PDF

ISBN 978-92-76-56957-2 doi: 10.2781/628998 NG-09-22-524-EN-N. 73