Europe and the US draw the line by nationality; Japan draws it by label
— Mutual recognition is not a loophole

When people talk about JC-STAR, someone sometimes says: "So it is a scheme to shut out Chinese products." The text does not say so. Europe and the US have begun to exclude inverters by nationality or place of production, but what Japan has put in place is a "label".

This article sets out the world's lines on one chart. Then it answers, from the text and the list, the question: "Could a company get in through Singapore?"

The world's lines on one chart

Figure 1 splits the cyber rules for solar and battery control devices into two groups. The upper group draws the line by labels and standards. The lower group draws it by nationality or place of production.

Terms used in this series

This series uses the terms below. All four articles share the same table.

Countries that draw the line by nationality

Three draw the line mainly by nationality or place of production.

• The EU: The policy is to stop projects that receive EU money from using inverters of "high-risk" companies, such as those in China. It has been reported since late April 2026, but there is no formal published document.
• Lithuania: It has banned by law remote operation from China and other countries over solar, wind and storage above 100 kW. The law also applies to existing plants.
• The US: It has stopped new certification of grid-connected inverters made abroad that have communication functions. In defence procurement, it excludes products from China and other countries. Texas also bans by state law companies tied to hostile countries from touching critical grid equipment.

Taiwan also bans imports of Chinese solar cells and modules. Dates and law numbers are in Table 2.

Countries that draw the line by label

Japan and Australia set no nationality condition. From April 2027, Japan asks for JC-STAR ★1 on control devices of solar and battery systems connected to the grid. Australia lets only inverters that meet its national standard and communication specification be used. The EU's product rules (the CE mark) also do not ask about nationality.

As of November 2026, Germany, the Netherlands and Korea have not started regulation that makes nationality a condition for inverters. In Germany and Korea, consideration has been reported.

Comparison by country

Table 2 lines up each country's rules by when they start, what they cover and how they draw the line. The right-hand column shows what we used to check each.

'Press reports' means that no primary source has been published, or that we could not read the primary source. For the EU funding policy, there is no formal published document.

Mutual recognition is not a loophole

People sometimes ask: "Japan has mutual recognition with Singapore, so can Chinese makers get in that way?" Table 3 lists the mutual recognition arrangements now in operation.

Whichever route is taken, the JC-STAR label is issued by IPA, not by an overseas authority. There are three reasons why it is not a loophole.

1. The requirement is "a label under IPA's scheme"

Devices shall be used that carry a conformity label of ★1 (Level 1) or higher (hereafter "JC-STAR ★1") under the security requirement conformity assessment and labelling scheme of the Information-technology Promotion Agency, Japan (IPA).Guideline on Technical Requirements for Grid Interconnection, draft revision, Chapter 2, Section 1, 5 (1) (October 2026) (our translation)

A CLS label is not itself a label of IPA's scheme. A product that conforms to CLS must still apply to IPA and receive a JC-STAR ★1 label before it meets the requirement. Mutual recognition lightens only the exemption of some checks, and the fee.

2. CLS is a scheme for household devices

Singapore's CLS is a scheme for consumer IoT devices. PCS and storage systems were never within its scope. In the CLS product list, Huawei's entries were only optical line terminals and Wi-Fi devices.

3. No product was obtained through mutual recognition

Each IPA product page has fields called "Mutual recognition with PSTI" and "Mutual recognition with CLS". We checked all 395 entries on the 12 November version. Every one reads "no application" in both fields. No product has yet obtained ★1 through mutual recognition.

Does nationality enter the label review?

Japan's requirement text has no nationality condition. Even so, the big Chinese names do not appear on the list.

According to Nikkei, an executive of a Chinese maker said: "Only Chinese companies' applications are being rejected. It is a de facto exclusion." Nikkei also reports that the application checklist has an item asking whether the company could be affected by foreign laws. METI does not disclose individual decisions.

The text does not ask about nationality. But what the review looks at cannot be confirmed from outside. The accurate statement is that we cannot say Japan pays no attention to nationality at all.

When ★2 arrives

Work has begun on a ★2-and-above standard suited to power equipment. At the Power Sub-Working Group of the Industrial Cybersecurity Study Group on 19 October 2026, it was reported that the policy is to prepare the study in consultation with IPA.

The national subsidy (Grid-Scale Storage System Deployment Support Programme) has already moved ahead. A device not covered by ★1 must obtain ★2 before supply starts, if a ★2 standard is later set and covers it.

Mutual recognition covers ★1 only. Neither CLS nor PSTI has anything that matches the ★2 requirements specific to power equipment. We expect that if the grid connection requirement rises to ★2, the part that mutual recognition lightens will become smaller still.

In closing

Japan and Australia set the conditions for grid connection by labels and standards that do not ask about nationality. If a seller pitches "we have CLS, so we are fine", the answer rests on the text above. What to look at is the registration number on IPA's list. That table is in 52-2 The list.

We should also say what we have not been able to confirm. These are the revised texts of the 10 grid operators and the result of the public comment on the draft revision. When the draft ★2 standard comes out, we will read the scope of mutual recognition again.

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