Regulations: consumer connectable product security
Guidance for manufacturers, importers and distributors on the Product Security and Telecommunications Infrastructure Act 2022 and Regulations 2023.
Key announcements
The UK’s consumer connectable product security regime came into effect on 29 April 2024. Businesses involved in the supply chains of these products need to be compliant with the new legislation from that date.
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 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).
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 came into effect 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 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 guidance on enforcement actions and associated rights.
Where to find more information
Legislation
- Product Security and Telecommunications Infrastructure Act 2022
- The Product Security and Telecommunications Infrastructure (Security Requirements for Relevant Connectable Products) Regulations 2023
- Explanatory Memorandum – PSTI Act 2022
- Explanatory Memorandum – PSTI (SRRCP) Regulations 2023
ETSI Standards and Implementation Guide
- ETSI EN 303 645 – Cyber Security for Consumer Internet of Things: Baseline Requirements
- ETSI Technical Specification 103 701 – Cyber Security for Consumer Internet of Things: Conformance Assessment of Baseline Requirements (ETSI website)
- ETSI Implementation Guide 103 621 – Guide to Cyber Security for Consumer Internet of Things (ETSI website)
Supporting guides and resources
- Code of Practice for Consumer IoT (Internet of Things) Security
- loTSF Consumer IoT Security Quick Guides and Webinars (IOT website)
- Code of Practice for Consumer IoT Security – international versions
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 went 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 [email protected].
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
Updates to this page
Published 8 January 2024Last updated 23 April 2024 + show all updates
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Additional guidance provided on the Statement of Compliance and automotive vehicles.
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First published.