Guidance

Regulations: consumer connectable product security

Guidance for manufacturers, importers and distributors on the Product Security and Telecommunications Infrastructure Act 2022 and Regulations 2023.

From:
Office for Product Safety and Standards and Department for Science, Innovation and Technology
Published
8 January 2024
Last updated
23 April 2024 — See all updates

Key announcements

The UK’s consumer connectable product security regime will come into effect on 29 April 2024. Businesses involved in the supply chains of these products will need to be compliant with the new legislation from that date.

Read full details of the legislative framework.

Overview

The use and ownership of consumer products that can connect to the internet or a network is growing rapidly. UK consumers should be able to trust that these products are designed and built with security in mind.

The Product Security and Telecommunications Infrastructure Act 2022 (PSTI) and the Product Security and Telecommunications Infrastructure (Security Requirements for Relevant Connectable Products) Regulations 2023 will mandate that manufacturers of consumer connectable products who sell to UK consumers comply with baseline security requirements. These are based on the top three principles in the Code of Practice for Consumer Internet of Things (IoT) Security, and align with key provisions of the leading global standard for cyber security for consumer IoT, ETSI EN 303 645 (ETSI website).

When the regulations come into effect, consumers who purchase new connectable products will benefit from world-leading security protections from the threat of cyber-crime.

What is covered

The regulations apply to relevant consumer products that can connect to the internet or a network.

The regulations do not cover:

  • products made available for supply in Northern Ireland to which relevant legislation applies (legislation listed in Annex 2 of the Windsor Framework, and contains a free movement article)
  • charge points for electric vehicles
  • medical devices
  • smart meter products
  • desktop computers, laptop computers and tablet computers which do not have the capability to connect to cellular networks (unless according to the manufacturer’s intended purpose they are designed exclusively for children under 14 years)

Extent of the obligations

The regulations will come into force on the 29 April 2024.

The regulations apply to:

  • any person who manufactures a product or has a product designed or manufactured and markets that product under that person’s name or trademark
  • any person who markets a product manufactured by another person under that person’s name or trademark
  • any person who imports the product from a country outside the UK to the UK and is not a manufacturer of the product
  • any person who distributes (makes the product available) in the UK and is not the manufacturer or importer of the product

How to comply

Manufacturers, importers, and distributors (i.e. retailers) have a duty to comply with the obligations in the Act and the security requirements stated in the Regulations 2023, including duties concerning the statement of compliance. The security requirements relate to:

  • banning universal default and easily guessable passwords
  • publishing information on how to report security issues
  • publishing information on minimum security update periods

There are additional duties for manufacturers, importers and distributors which include, but are not limited to, investigating potential compliance failures, duties to maintain records and duties to take action in relation to compliance failures.

There is also a duty on authorised representatives to take action in relation to a manufacturer’s compliance failure.

These duties are laid out in Chapter two of the PSTI Act 2022.

Role of the Office for Product Safety and Standards (OPSS)

OPSS is the enforcement authority responsible, from 29 April, for ensuring compliance with the legislation on behalf of the Department for Science, Innovation and Technology.

Our approach to carrying out our regulatory activities will be risk-based, as explained in our Service Standards. Our approach to addressing non-compliance by those we regulate will be pragmatic and proportionate, and will take account of the maturity of the legislation, as set out in our Enforcement Policy, which should be read alongside guidance on the specific enforcement actions available to us under the legislation, and associated rights to make representations or appeal.

Read our Service Standards.

Read our Enforcement Policy.

Read our guidance on enforcement actions and associated rights.

Where to find more information

Legislation

ETSI Standards and Implementation Guide

Supporting guides and resources

Additional guidance

Statement of Compliance

The Product Security and Telecommunications Infrastructure Act 2022 states that a Statement of Compliance (SoC) must ‘accompany’ the product and defines the SoC as a ‘document’.

The Act does not define the terms ‘document’ or ‘accompany’ and therefore each business in scope of the regime must determine how it will comply with the requirements in relation to its own individual products.

The Act does not specify that the document must be physical; therefore it could be digital. However, the manufacturer, importer and distributor must ultimately ensure that the SoC accompanies the product and meets the necessary legal requirements in the PSTI Act 2022 and PSTI Regulations 2023.

Automotive vehicles

The government intends that categories of product may be exempted from the PSTI regime through further regulation. This may be because they already are or will in the future be covered by sector specific legislation that contains cyber security requirements equal to or greater than those mandated in the PSTI regime, or where regulation would be considered inappropriate.

As such, DSIT is beginning the legislative process for the certain categories of products, to be exempt from the PSTI regime. The draft statutory instrument containing the proposed new exemptions will reference the categories of products regulated by Regulation (EU) 2018/858, Regulation (EU) No 168/2013 or Regulation (EU) No 167/2013.

This Statutory Instrument will be laid in Parliament as soon as parliamentary timetables allow and will be subject to approval by Parliament. As the PSTI regime goes live on 29 April 2024, there will be a short period of time before the instrument comes into force where these products fall under the PSTI regime. Government cannot provide stakeholders with a timeframe for how long this period will be.

In its role as the regulator, OPSS will approach the early stages of implementation in a pragmatic and proportionate manner, in line with its published enforcement policy. OPSS will take into consideration the statutory instrument containing the exemption when considering products set out in the instrument. Should OPSS receive intelligence concerning the sectors identified in the statutory instrument, there may be the need to engage with the relevant business to address the issue, on a case-by-case basis, to ensure that consumers are protected from harm.

Contact us

If you have a specific enquiry about compliance or wish to contact us regarding suspected non-compliance, please email OPSS.enquiries@businessandtrade.gov.uk.

Alternatively, you can contact our helpdesk on 0121 345 1201.

Or in writing to:

Office for Product Safety and Standards
4th Floor Cannon House
18 The Priory Queensway
Birmingham
B4 6BS
United Kingdom

Published 8 January 2024
Last updated 23 April 2024 + show all updates

  1. Additional guidance provided on the Statement of Compliance and automotive vehicles.

  2. First published.

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