VEHICLES AND PARTSPRELIMINARY REMARKS
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The aim of these Factsheet is to explain to EU exporters of Vehicles & Parts, the Japanesemarket access opportunities offered by the EU-Japan Agreement for an Economic
Partnership (EPA) as well as, in a brief overview, the relevant Rules of Origin.
As regards product specification, only the Harmonised System (HS) code system at six-digit
level, or the Japanese nomenclature at nine-digit level have been used. For detailed descriptionof the Japanese nomenclature, reference is made to the Japanese Schedule in the Agreement.
In the Japanese Schedule, a fiscal year (FY) means the period between 1 April of
one year and 31 March of the next year. As the Agreement has entered into force on 1
February 2019, the first year was the period between 1 February 2019 and 31 March 2019.
All quantities are expressed in metric tonnes (t), unless stated otherwise.
The complete text of the EPA, and annexes, incorporating the Schedule of Japan, can be found on
the following website of the European Commission: https://trade.ec.europa.eu/doclib/press/index.
cfm?id=1684. Japan’s tariff Schedule is in Annex 2-A-4; “Notes for the Schedule of Japan” canbe found in Annex 2-A-3. These Notes explain inter alia the various types of concessions.

This document has been prepared with the sole purpose of simplifying the understanding of some parts of the EU-Japan EPA and bears no legal standing.
© Copyright EU-Japan Centre 2019

Under thesupervision of

EU-Japan Centre
for Industrial Cooperationwww.eu-japan.eu/epa-helpdesk

Page 1VEHICLES AND PARTS
1. PRODUCT COVERAGE
Products classified under the following Chapters have been considered in this Factsheet:

HS
CHAPTERDESCRIPTIONREMARKS

ex-CH38

Hydraulic brake fluids – Anti-freezing preparations

ex-CH40

Transmission belts – Tyres – Inner tubes – Articles of vulcanised rubber

ex-CH70

Safety glass

ex-CH73

Nuts of iron or steel – Springs

ex-CH76

Solid profiles of aluminium alloys

ex-CH83

Locks used for motor vehicles – Hinges – Base metal mountings, fittings for motor vehicles

ex-CH84

Piston engines and parts thereof

ex-CH85

Electrical machinery and equipment & parts thereof

ex-CH87

Vehicles other than railway or tramway rolling stock and parts and accessories thereof

ex-CH90

Instrument panel meters, parts and accessories thereof

ex-CH91

Instrument panel clocks

ex-CH94

Seats for motor vehicles and parts thereofThis document has been prepared with the sole purpose of simplifying the understanding of some parts of the EU-Japan EPA and bears no legal standing.

Under thesupervision of

EU-Japan Centre
for Industrial Cooperationwww.eu-japan.eu/epa-helpdesk

Page 2

2. MARKET ACCESS• Apart from leather parts of seats used in vehicles(940190.021)[1], all EU exports of vehicles and parts thereof
have been liberalised and enter duty free in Japan.
• A majority of these tariff lines have been liberalised
at MFN level (and hence outside EPA context), others
were liberalised at the entry into force of the EPA, as aconcession in this Agreement.
• The Schedule of the EPA only lists products which were
not liberalised at the entry into force of the EPA. Products[1]
The tariff of this product (3.8%) will be graduallyphased out over a period of 10 years; it will be free as from
1/4/2028.

which had already duty-free access in Japan before the
EPA entered into force or which have been liberalised at
the entry into force of the Agreement are therefore notlisted in the EPA Schedule.
• The complete list of all products, together with the baserates and applied tariffs under the EPA, including those withduty free access, can be found on the website of the Japanese
Customs: http://www.customs.go.jp/english/tariff/2019_4/
data/e_50.htm.
Caution: updates are published regularly with thepreferential tariffs of the relevant fiscal year.

This document has been prepared with the sole purpose of simplifying the understanding of some parts of the EU-Japan EPA and bears no legal standing.

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3. SPECIAL EPA PROVISIONS APPLICABLE TO
VEHICLES & PARTS (ANNEX 2-C)
• -The Agreement reached in this annex applies to all products of vehicles, their parts and equipment regulatedby the 1958 Agreement[2] and the 1998 Agreement[3], with the exception of vehicles, their parts and equipment
thereof, used exclusively for agriculture and forestry.
• -Under this Agreement both Parties share the following objectives:- The promotion of high levels of safety, environmental protection and energy efficiency.
- Trade facilitation between the two Parties and access to respective markets through regulatory
cooperation, and elimination and prevention of adverse effects of non-tariff measures.
- Enhancing the international harmonisation of requirements in the context of WP.29[4], and the mutual
recognition type approvals granted in accordance with UN Regulations without requiring any further
testing, certification or marketing.
- Achieving convergence of regulatory requirements of the Parties through the application of UN
Regulations and GTRs[5].
• -Each Party shall accept on its market products which are covered by a type approval certificate, under the 1958
Agreement for the UN Regulations, as specified in Appendix 2-C-1 of the EPA, as compliant with its domestic technical regulations and conformity assessment procedures, without any further testing, documentation, certification ormarketing.
This means that the EU and Japan align themselves to the same international standards. As a result, EU
and Japanese cars would be subject to the same requirements; and in particular, owing to the introduction of theinternational whole vehicle type approved, EU cars would no longer have to be tested and certified again whenexported to Japan.
EU exports of cars to Japan will be significantly simplified. The agreement in this context allows that a limited number of hydrogen-fuelled cars that are approved in the EU can be exported to Japan without further modifications.
However, there are still several specific restrictions in terms of the material specifications. The matter of material
qualification is currently being discussed in phase 2 of GTR13.
The Agreement additionally foresees a strong cooperation between the Parties and obligations to guaranteethat the conditions contained in this Agreement can be maintained over time. In this context relevant consultation
procedures have been defined.
[2]“1958 Agreement” means the Agreement concerning the Adoption of Harmonized Technical United Nations
Regulations for Wheeled Vehicles, Equipment and Parts which can be Fitted and/or be Used on Wheeled Vehicles and theConditions for Reciprocal Recognition of Approvals Granted on the Basis of these United Nations Regulations.
[3]“1998 Agreement” means the Agreement concerning the establishing of global technical regulations for wheeledvehicles, equipment and parts which can be fitted and/or be used on wheeled vehicles.
[4]
WP.29 means the World Forum for Harmonisation of Vehicle Regulation, acting within the framework of the UN and
the Economic Commission for Europe.
[5]
GTR means a global technical regulation established and placed on the Global Registry in accordance with the 1998
Agreement.
This document has been prepared with the sole purpose of simplifying the understanding of some parts of the EU-Japan EPA and bears no legal standing.

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Page 4• -The Agreement furthermore includes an accelerated dispute settlement procedure on domestic regulatory
procedures.
• -A safeguard clause reserves each Party the right, during 10 years following the entry into force of the EPA, tosuspend equivalent concessions[6] or further equivalent concessions , in the event the other Party does not apply a
UN Regulation specified in Appendix 2-C-1, or introduces or amends any other regulatory measure that harms thebenefits of the application of an UN Regulation.

[6]
The level of the suspension of concessions or other obligations shall be no more than the level of the amount of thebilateral trade between the Parties of products covered by the relevant UN Regulation.
This document has been prepared with the sole purpose of simplifying the understanding of some parts of the EU-Japan EPA and bears no legal standing.

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Page 5

4. RULES OF ORIGIN
4.1.

GENERAL• To benefit from EPA preferential tariff rates, the productneeds to be originating in Japan or the EU. In order tobe considered ‘originating’, the product needs to comply
with the provisions “Rules of Origin” of Chapter 3 Section
A and the Product Specific Rules – PSR - (Annexes 3-A, 3-B,
Appendix 3-B-1) of the Agreement.[7]- Annex 3-A contains Introductory Notes toAnnex 3-B (the Product Specific Rules of Origin).
- It includes a number of definitions, including the
below listed:∙ “Chapter” means the first two-digits inthe tariff classification number under the
Harmonized System;∙ “Heading” means the first four-digits inthe tariff classification number under the
Harmonized System;∙ “Subheading” means the first six-digits
in the tariff classification number under the
Harmonized System;∙ “Wholly obtained”: EU/JPN origin is required.

• A product shall be considered as ‘originating’ in theother Party if:- Wholly obtained or produced products asprovided for in Art. 3.3 of the Agreement;- Products produced exclusively from materials
originating in the Party (EU or Japan);- Products produced using non-originating
materials, provided they satisfy all applicablerequirements of Annex 3-B (PSR).

∙ “CC (Change of Chapter)” means thannon-(EU/JPN) originating materials (imported
from non-contracting parties) may be usedin the production of the goods concerned,
if these materials are classified underanother tariff chapter of the goods in the HSclassification system (at 2-digit level).

- The Chapter 3 Section A includes provisions
allowing more flexibility to comply with these
Product Specific rules (tolerance, bilateral full
cumulation, absorption rule etc.).

∙ “CTH (Change of Tariff Heading)” means thatnon-(EU/JPN) originating materials (imported
from non-contracting parties) may be used in
the production of the goods concerned, if thesematerials are classified under another tariffheading of the goods in the HS classification
system (at 4-digit level).

- Chapter 3 Section B (“Origin procedures”) of the
EPA sets out the procedures to claim preferential
treatment. The EPA is based on the selfcertification system, therefore the EU or Japanese
exporters self-certify that the product is originatingby making a statement on origin in line with
Chapter 3, Section A including its Annex 3-D (“Textof the statement on origin” – can be found on
http://trade.ec.europa.eu/doclib/docs/2018/august/tradoc_157231.pdf#page=149). Moreover, the EPA
gives for the first time a possibility for the importers
to claim preferential tariff treatment on the basis of‘importer’s knowledge’, which contributes to tradefacilitation for the related companies.
[7]
More information can be found on the following websites:
Japan’s Customs: http://www.customs.go.jp/english/c-answer_e/
imtsukan/1524_e.htm
European Commission (DG TRADE): http://madb.europa.eu/madb/
viewPageIFPubli.htm?doc=ppo&hscode=0402&countryid=JP∙ “CTSH (Change of Tariff Sub-Heading)”means that non-(EU) originating materials(imported from non-contracting parties) may be
used in the production of the goods concerned, if
these materials are classified under another tariff
sub-heading of the goods in the HS classification
system (at 6-digit level).
It furthermore provides the provisions for the tolerance
rules applicable to certain products. The tolerance rules
permit manufacturers to use non-originating materials
up to a specific limit.

This document has been prepared with the sole purpose of simplifying the understanding of some parts of the EU-Japan EPA and bears no legal standing.

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Page 6

• Product Specific Rules of Origin (PSR) are laid downin Annex 3-B of the Agreement. This annex sets out(per 4 or 6-digit tariff heading) the requirements to beoriginating. Further to the three conditions specified
under the above 2nd indent, these requirements canbe:- a change in tariff classification,- a production process,- a maximum value of non-originating
materials, or a minimum regional value content,or- any other requirement specified in Annex
3-A and in Annex 3-B (PSR).

• As in most of similar Agreements the EU has concluded
with third countries, the EPA provides for a clause of“Bilateral Cumulation”. This clause specifies that if
a product qualifying as originating in one Party, it isconsidered as qualifying in the other Party if that productis used as a material in the production of anotherproduct in the other Party (Art. 3.5 of the Agreement),
or in other words bilateral cumulation allows inputs/
materials originating in Japan to be considered asoriginating in the EU when further processed orincorporated in the EU and exported to Japan (andvice and versa). Only materials deemed originating canbenefit from this basic type of bilateral cumulation.

This document has been prepared with the sole purpose of simplifying the understanding of some parts of the EU-Japan EPA and bears no legal standing.

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Page 7

4.2. SPECIFIC RULES AS REGARDSCERTAIN VEHICLE PRODUCTS AND
PARTS• The respect of the RoO provisions as specified in the
EPA are a condition to benefit from the preferences
contained in that Agreement.
• As a result, the PSR only concern Japanese imports
of EU products which have a preferential treatment
under the EPA, and do therefore not concern for
instance EU products for which Japan has alreadygranted duty free access at MFN level before
the entering into force of the EPA. This is the casefor a large majority of the products covered in thisFactsheet.
• The EPA Appendix 3-B-1[8], containing provisions onrules of origin related to certain vehicles and parts thereof,
does therefore not concern EU exports of these products
to Japan as duty free access at MFN level has already been
granted by Japan.
• Below an overview of the few products on which Japanapplies an EPA preference and on which, as a result, EPA
PSR are applicable.

production of these goods if these materials areclassified under another tariff sub-heading, or• a chemical reaction, purification, productionof standard materials, isomer separation orbiotechnological processing is undergone, or• MaxNOM 50% (EXW) – meaning that the valueof the non-originating materials cannot behigher than 50% of the ex-works price of the
product paid or payable to the manufacturer
in who’s undertaking the last working orprocessing is carried out, or• RVC 55% (FOB) – meaning that the minimum
regional value content of the product is 55% of
the free on-board price of the product paid or
payable to the seller regardless of the mode of
shipment.
- Heading 7318.16 - Nuts of iron or steel• PSR: CTH, meaning that non-(EU/Japan)
originating materials, i.e. imported from
non-contracting Parties, can be used in the
production of these goods if these materials areclassified under another tariff heading.
- Heading 7604.29 – Solid profiles of aluminium alloys• CTH and• MaxNOM 50% (EXW) or- Heading 3819.00 - Hydraulic brake fluids• CTH and RVC 55% (FOB)• CTSH, meaning that non-(EU/Japan)
originating materials, i.e. imported from
non-contracting Parties, can be used in the- Heading 8302.10 – Hinges of all kinds, of base metal• CTH, or[8]This Annex contains provisions as regards:- Interim thresholds of product specific rules of origin forvehicles and parts thereof (Headings concerned: 87.03,
84.07, 84.08, 87.06, 87.07 and 87.08);- Application of the product specific rules of origin forcertain motor vehicles through production processes
related to certain parts (subheadings concerned: 8703.21
and 8703.90), and- Status of ‘originating’ of materials of headings 84.07,
85.44 and 87.08 originating in third countries and used in
the production in a Party of a product of heading 87.03.

• MaxNOM 50% (EXW) or• RVC 55% (FOB)- Heading 9401.90 – Parts of seats• CC, meaning that non-(EU/Japan) originating
materials, i.e. imported from non-contracting
Parties, can be used in the production of thesegoods if these materials are classified underanother tariff chapter.

This document has been prepared with the sole purpose of simplifying the understanding of some parts of the EU-Japan EPA and bears no legal standing.

www.eu-japan.eu/epa-helpdesk

Page 8DISCLAIMER
The Report has been prepared with the sole purpose of clarifying and simplifying theunderstanding of some parts of the EU-Japan EPA related to vehicles & parts, and bear therefore
no legal standing.
While utmost care was taken in the preparation of the report, the author, the EU-Japan Centre,
and the European Commission cannot be held responsible for any error or omission.
This report does not constitute legal advice in terms of business development cases. As a result,only the legal text and annexes of the EU-Japan EPA, as well as relevant legislation in the EU andJapan prevail.
The Report reflects the view of the author who cannot be held responsible for any use which
may be made of the information contained herein.

This document has been prepared with the sole purpose of simplifying the understanding of some parts of the EU-Japan EPA and bears no legal standing.

Under thesupervision of

EU-Japan Centre
for Industrial Cooperationwww.eu-japan.eu/epa-helpdesk

Page 9