The Problem: Japan uses exclusively Type A (2-prong, ungrounded) outlets. Leo CTs ship with Type B (3-prong) — unusable in ~100% of Japanese homes. This blocks B2C/SMB market entry. B2B (commercial rooftops) can accommodate 3-pin outlets.

SIM: LEO-JP-22

Owner: Raymond Ruiz (Sr TPM, Global Expansions)  |  Escalation path: Trevor / Clint / Rajeev

Shock risk pathway: (1) fault to chassis, (2) customer touches device during fault, (3) sufficient energy to cause injury.

Pigtail ground availability: Most homes lack grounding terminals in living areas (only wet rooms). Pigtail would be unusable for majority of B2C customers.

~3% failure rate even with robust instructions (Sunil, human factors) — but since most homes lack the outlet, exposure is "substantial".

Mitigation: Earth Leakage Circuit Breakers (ELCB) common in post-1970s homes, but Amazon does not credit home infrastructure in safety design.

Lightning/surge: Outdoor CT charge transfers to IDU. External surge arrestor proposed (mandatory pro install). Evaluation NOT yet completed — needs internal expert sign-off.

Taiwan: Same Type A plug problem. $65M FET deal at stake. Country-level diligence with Richard V. ongoing.

Other APAC: Any country using ungrounded Type A outlets faces same issue. Solution for Japan applies regionally.

If Option 1 rejected → B2C segment may defer Japan launch until Class II redesign available (~mid-2027). This would push Japan B2C beyond current Jan 2027 CPL.

PSE (Product Safety Electrical Appliance & Material) is Japan's mandatory certification under the DENAN Act. Without PSE marking + METI registration, products cannot be imported/sold/distributed.

Critical gap: Inventory systems pool by ASIN with no CM differentiation. METI can audit at any time without notice — must provide import/sales/in-stock data by model AND manufacturer within days.

16 action items across 5 categories. 14 remain unresolved. 2 Critical, 4 High, 10 Medium priority.

Coco bundle component flagged at risk. Permanent cert resolution targeted Jul 31, 2026. Stop-gap in place for 100-unit NBN partner shipment.

Cable accessories fell through Compliance/Regulatory Assessment gate — only power adapters were explicitly scoped in original assessment.

2,139 NBN AU units require plasma-built devices (per Coco IPX6 alert). Plasma now approved on all 3 lines; 0F/60T ORT. Primer inventory (~82K units) on hold pending REL validation.

New failures found in inventory screening (11F/30T Wk4 Jun; 9F/27T Wk1) — different lots/lines/operators. Root cause analysis ongoing.

Target occupancy: End of August / beginning of September 2026

Operator: CTDI

Supports: Leo inventory Q4 + New Zealand exports

Flow: Direct CM → KAU (KBN as backstop). Inventory from ICN ICA2 (China) + KBN.

Returns: Kept separate from KAU initially until CTDI validated.

AU-specific 8-year-old biosecurity workaround blocks shipments. Expected resolution by end of 2026. Decision: monitor only (no proactive mechanism) since the requirement should be removed.

Ocean latest start: Jul 30, 2026. Air window: closed Jun 22. Trade GTC readiness is prerequisite. UAT completes Oct 23.

PO in system. Flow: CNT → KVN → NBN (outbound sales order; no AU import PO). First 100 units ship ~2 days after FFS. Must use plasma-built units only.

NBN needs support earlier than AU service launch (Mar 2027). KVN supports until KAU operational.