BSMI Proposes Amendments to Inspection Requirements for Information Technology and Audiovisual Products; Connected Products Should Address Cybersecurity and Certification Requirements

The Bureau of Standards, Metrology and Inspection (BSMI), Ministry of Economic Affairs, has proposed amendments to the Inspection Requirements for Information Technology Equipment Subject to Mandatory Inspection and the Inspection Requirements for Audiovisual Products Subject to Mandatory Inspection. The proposed amendments focus on information technology equipment, audiovisual products, and consumer electronics with network connectivity, including digital cameras, digital video cameras, routers, bridges, switches, network hubs, gateways, smart speakers, smart home assistants, video recorders and players, displays, and televisions.

As consumer electronics increasingly incorporate Wi-Fi, Bluetooth, Ethernet, cloud connectivity, app control, remote updates, and smart-home integration, product inspection no longer focuses solely on traditional electrical safety and electromagnetic compatibility. Cybersecurity for connected products, data transmission security, firmware update management, and user risk management are also becoming important aspects of product certification.

Network Connectivity Is an Important Determining Factor in the Proposed Amendments

The proposed amendments specifically distinguish whether a product has network connectivity. BSMI documents define network connectivity as connecting to a network through Internet Protocol (TCP/IP). In other words, if a product can connect to the internet through a wired network, wireless network, or another method, it may fall within the inspection requirements for connected products.

For businesses, whether a product has network connectivity will directly affect the applicable standards, inspection methods, test items, and certificate documentation. For example, if digital video cameras, smart speakers, smart home assistants, connected displays, or connected televisions have network connectivity, cybersecurity-related standards may also need to be reviewed in addition to traditional safety and EMC testing.

Proposed Amendments for Information Technology Equipment Cover Cameras and Network Equipment

For information technology equipment, the proposed amendments cover digital cameras, digital video cameras, and network equipment such as routers, bridges, switches, network hubs, and gateways. The categories of routers, bridges, switches, network hubs, and gateways also include products such as smart speakers and smart home assistants.

These products are commonly used in homes, offices, commercial premises, surveillance systems, and smart-living applications. If a product provides data transmission, remote connectivity, image capture, audio reception, cloud synchronization, or smart-control functions, businesses should consider electrical safety, EMC, RoHS marking, and cybersecurity testing requirements concurrently during product development and market launch planning.

Proposed Amendments for Audiovisual Products Cover Connected Displays and Connected Televisions

For audiovisual products, the proposed amendments cover products such as video recorders, video players, displays, and televisions and introduce cybersecurity-related testing requirements for products with network connectivity, including connected displays and connected televisions.

For products such as smart televisions, connected displays, or audiovisual equipment with streaming functions, compliance may involve cybersecurity standards, warning labels, user data protection, and subsequent software update management because of network connectivity, in addition to basic safety, electromagnetic compatibility, energy efficiency, and restricted-substance marking requirements.

Cybersecurity Standards Incorporated into the Product Certification Process

Under the proposed amendments, products with network connectivity may be subject to cybersecurity-related standards such as CNS 16190, CNS 18031-1, and CNS 18031-2. Depending on the product type, certain digital video camera products may also be subject to CNS 16120 and the CNS 16132 series of standards.

This means that when conducting type testing, type approval, or Registration of Product Certification for relevant connected products in the future, businesses cannot prepare only traditional electrical safety and EMC test information. They should also review in advance whether the product involves network connectivity, user accounts, password settings, data transmission, firmware updates, remote control, cybersecurity warnings, and default security settings.

Existing Certificates and Declarations of Conformity Should Be Reviewed in Advance

For businesses that have already obtained type approval, Registration of Product Certification, or a Declaration of Conformity, the proposed amendments also address the application of standards before and after the amendments, certificate validity periods, certificate replacement, the validity of Declarations of Conformity, and documentation required for reapplication.

If businesses previously obtained certificates under the former inspection requirements, they should still review whether their products fall within the scope affected by the proposed amendments and confirm whether supplementary type-test reports, cybersecurity test information, quality management system documents, factory inspection information, or certificate replacement applications are required. Failure to complete the necessary procedures within the prescribed period may affect subsequent importation, release from the factory, display, or sale.

Product Certification Recommendations

Action Technology recommends that manufacturers, importers, brand owners, agents, and e-commerce retailers selling information technology equipment, audiovisual products, or consumer electronics with network connectivity review in advance how the proposed amendments may affect product certification and market launch schedules.

• Confirm Whether the Product Has Network Connectivity: If a product can connect through Wi-Fi, a wired network, an app, the cloud, or TCP/IP, businesses should first confirm whether the inspection requirements for connected products apply.
• Review Product Categories and Models: Digital cameras, digital video cameras, network equipment, smart speakers, smart home assistants, displays, televisions, and video recording and playback equipment should be individually assessed according to their functions and specifications to determine the applicable standards.
• Plan Safety, EMC, and Cybersecurity Testing Concurrently: If a product is subject to electrical safety, electromagnetic compatibility, restricted-substance marking, and cybersecurity requirements, testing schedules should be coordinated to avoid repeated testing or delayed market launch.
• Review RoHS and Warning Labels: Relevant products must continue to disclose information on the presence of restricted substances in accordance with Section 5 of CNS 15663 and should be reviewed to determine whether additional warning-label requirements for information, communication, and consumer electronics products apply.
• Determine Whether Existing Certificates Require Replacement: For products that have obtained type approval, Registration of Product Certification, or a Declaration of Conformity, businesses should confirm the implementation schedule for the amended standards and whether supplementary test reports or certificate replacement applications are required.
• Allow Time for Cybersecurity Testing and Documentation: Cybersecurity testing may involve product functions, firmware versions, account and password settings, remote connectivity, data transmission, and update mechanisms. These requirements should be incorporated into certification planning during the product development stage.

Certification of Connected Products Should Begin at the Design Stage

Network connectivity is becoming increasingly common in consumer electronics, and product certification is gradually expanding from hardware safety testing alone to software, firmware, data transmission, and cybersecurity management. If businesses discover deficiencies in cybersecurity standards, labeling, or certificate documentation only during the later stages of product development, they may need to redesign the product, modify firmware, conduct supplementary testing, or postpone the market launch.

For digital video cameras, network equipment, smart-home devices, displays, televisions, and other connected consumer electronics, businesses are therefore advised to confirm the applicable standards, test items, certification methods, and documentation requirements during the initial design stage to reduce compliance risks after mass production.

Action Technology Co., Ltd. will continue to monitor BSMI inspection requirements for information technology equipment, audiovisual products, and connected products, assisting businesses with EMC testing, SAFETY compliance testing, BSMI certification assessment, RoHS marking review, preparation of type-test documentation, and pre-market compliance planning to help products enter the market more smoothly.

Source: Bureau of Standards, Metrology and Inspection, Ministry of Economic Affairs｜Proposed Amendments to the Inspection Requirements for Information Technology Equipment Subject to Mandatory Inspection and the Inspection Requirements for Audiovisual Products Subject to Mandatory Inspection