Amendment to legal inspection requirements for hot cathode fluorescent lamps 
 
By the Bureau of Standards, Metrology and Inspection (BSMI), Ministry of Economic Affairs (MOEA) 
 
Introduction: 
The Bureau of Standards, Metrology and Inspection adopts the most recent version of standard, CNS 691
“Fluorescent lamps (for general lighting service), ” published on 15 August 2019, as the inspection 
standard for hot cathode fluorescent lamps. To phase out mercury-added products in line with the goal of 
Minamata Convention on Mercury, this revised version requires the content of mercury at not more than 4mg. 
The requirements for restriction of hazardous substances and the applicable conformity assessment 
procedures remain unchanged. 
 
Date of implementation:   
1 January 2021 
 
 Description of Goods  Inspection Standards C.C.C. Code (the 
first 6 digits are the 
same as HS 
Code)(Reference) 
Hot Cathode Fluorescent 
Lamp 1.CNS 691 (2019) 
2.Section 5 "Marking of presence" of CNS 15663 
(2013) 8539.31.00.00.7A 
Description of the two kinds of conformity assessment procedures  
1. Registration of Product Certification (RPC) Scheme ：Modules II + III 
Under the II+III combination of modules used in this scheme, domestic manufacturers or importers must 
have their products type-tested in advance (Module II) by the BSMI or BSMI-designated testing 
laboratories before applying for registration of their products. Manufacturers or importers will also be 
required to ensure by declaration (Module III, conformity-to-type declaration) that all products made at 
their manufacturing facilities or imported are in conformity with the prototypes submitted for type-test at 
Module II stage.  The conformity-to-type declaration shall be drawn up by the manufacturer or the 
authorized local representative, declaring that the mass-produced products comply with the prototype as 
in the type-test report. 
After being certified and registered by the BSMI, products will be allowed to use the Commodity 
Inspection Mark with the letter ‘R’ and the identification number given by the BSMI. Additionally, these 
products can clear customs directly without any further inspection if not being sampled by RPC border 
check procedures. The application fee and annual fee for RPC are both NT$5,000 (about US$170) for 
each certification, and the RPC certification is valid for 3 years. If there are any serial products, an extra 
NT$3,000 (about US$100) of application fee will be charged for every application in each certification. 
The fees for type testing vary by products and depend on the fee policies of the testing laboratories. 
Further information on this procedure is available on the BSMI website at 
https://www.bsmi.gov.tw/wSite/ct?xItem=4447&ctNode=9452&mp=2  
 
2. Type-Approved Batch Inspection (TABI) Scheme 
Under this procedure, manufacturers or importers shall have their products type-tested by the BSMI or the 
BSMI-designated testing laboratories, and file an application for Type Approval to the BSMI or its 
branches. 
After manufacturers or importers obtain a Type Approval certificate, they are required to file an 
application for batch inspection to the BSMI each time before their products are released from the 
production premises or arrive at the port of entry. The BSMI will then review the application and the 
related documents while additional samples may be required for further testing if it is deemed necessary.  
After the products have passed the inspection, they will be allowed to use the Commodity Inspection Mark with the letter ‘T’ and the identification number given by the BSMI. The application fee for a Type 
Approval is NT$3,500, and a Type Approval certificate is valid for 3 years. The fees for type testing vary 
by products and depend on the fee policies of the testing laboratories. 
Further information on this procedure is also available on the BSMI web site at 
https://www.bsmi.gov.tw/wSite/ct?xItem=4470&ctNode=9452&mp=2  
 
 
 
Related requirements: 
1. The revised inspection standards of the commodities listed above will come into force on the date of 
announcement and the current inspection standards will become invalid from 1 January 2021. 
2. Processing of applications: 
(1) Replacement: 
Before 1 January 2021, the certificate holders shall prepare type-test report in compliance with 
revised inspection standards of CNS 691 to apply for replacing the certificate(s) from the BSMI or 
its branches, the expiry date of the replaced certificate is the same as that of the original certificate. 
Otherwise, certificate(s) will be rescinded based on Paragraph 1, Article 16 of the “Regulations 
Governing Type Approval of Commodities” or Paragraph 9, Article 42 of the “Commodity Inspection 
Act”. 
(2) New application or extension: 
From the date of publication, applicants shall prepare type-test report in accordance with  the revised 
inspection standards , documents related to the location of the marking of presence, sample of the 
marking of presence (see Table 1 and Table 2), and the “Declaration of the Presence Condition of the 
Restricted Substances Marking” to apply for certificate(s). The validity period of a new certificate will 
be 3 years from the date of issuance while an extended one lasts 3 years since the next day of the 
previous expiration date. If applicants apply for certificate(s) in accordance with the original inspection 
standards, the expiry date of the certificate will be only valid till 31 December 2020. From 1 January 
2021, applicants shall file a new application or extension only  in accordance with the revised 
inspection standards. 
3. The applicable inspection schemes, applicable conformity assessment modules of Registration of Product 
Certification(RPC), the term of validity of certificates, inspection fees of the commodities remain 
unchanged. 
4. The certificate holders of the commodities shall follow the content stipulated in Section 5 “Marking of 
presence” of CNS 15663 and clearly mark “the presence condition of the restricted substances” on the 
body, packages, stickers, or the instruction books of the commodities. Those who utilize website as a 
means to announce “the presence condition of the restricted substances” of the commodities shall also 
clearly mark the website address on the body, packages, stickers, or the instruction books of the 
commodities. In that case, the requirements of Section 5.3 of CNS 15663 are not applicable to the 
positions of the markings. 
5. The Commodity Inspection Mark: 
(1) The Commodity Inspection Mark shall be printed by the certificate holders. The identification number 
of the Commodity Inspection Mark consists of “A Letter (R or T),” “Designated Code (5 digits)” and 
“the presence conditions of the restricted substance” (e.g., RoHS or RoHS(XX,XX)). 
(2) The identification number shall be placed below or right next to the graphic symbol and “the presence 
conditions of the restricted substance” shall be indicated in the second row.  
(3) The size of the Mark can be applied proportionally on a prominent location of the commodities. The 
Mark shall use materials that are not easily altered, and the content shall be in a clearly identifiable 
and indelible form affixed permanently to the commodity. (4) For RPC scheme, the examples of the Commodity Inspection Mark are listed below: 
 
 
 
 
 
 
 
(5) For TABI scheme, the examples of the Commodity Inspection Mark are listed below: 
 
 
 
 
 
 
(6) “RoHS” indicates “the content of restricted substance(s), other than exemptions stated in CNS 15663, 
does not exceed the reference percentage value of presence condition. 
“RoHS(XX,XX)” indicates the content of restricted substance(s) (element XX, element XX, …), other 
than exemptions stated in CNS 15663, exceeds the reference percentage value of presence condition. 
Restricted substances: Pb, Cd, Hg, Cr+6, PBB, and PBDE. 
Examples:  
 RoHS (Pb) indicates that the percentage content of Pb in certain parts of the commodity exceeds the 
reference percentage value specified in Annex A to CNS 15663. 
 RoHS (Cd, Cr+6, PBB) indicates that the percentage content of Cd, Cr+6, and PBB in certain parts of 
the commodity exceeds the respective reference percentage value specified in Annex A to CNS 
15663. 
6. The C.C.C. Code listed in the table is used for reference only. The commodity listed in the table shall still 
complete the inspection procedures before entering into the market even though their C.C.C. Code is 
identified differently by the Customs Administration, Ministry of Finance or Bureau of Foreign Trade, 
Ministry of Economic Affairs. 
7. The inspection standards of the products listed in the table shall be the version published in this 
announcement. If any updated version is available, the BSMI shall publish the implementation date of the 
updated version in further announcement. 
Table 1. Example of markings for the presence conditions of the restricted substances exceed the reference 
percentage value of presence conditions 
Equipment name: Hot Cathode Fluorescent Lamp, Type designation: XXX 
Unit Restricted substances and its chemical symbols 
Lead 
 
(Pb) Mercury 
 
(Hg) Cadmium  
 
(Cd) Hexavalent 
chromium 
(Cr+6) Polybrominated 
biphenyls 
(PBB) Polybrominated 
diphenyl ethers  
(PBDE) 
Cap Exceeding  
0.1 wt % ○ ○ ○ ○ ○ 
Tube ○ ○ ○ ○ ○ ○ 
Filler ○ − ○ ○ ○ ○ 
Electrode ○ ○ ○ ○ ○ ○ 
Note 1:  “Exceeding 0.1 wt %” and “exceeding 0.01 wt %” indicate that the percentage content of the 
restricted substance exceeds the reference percentage value of presence condition. 
Note 2:  “○” indicates that the percentage content of the restricted substance does not exceed the 
percentage of reference value of presence. 
Note 3:  The “−” indicates that the restricted substance corresponds to the exemption. 
 
Table 2. Example of markings for the content of restricted substances other than exemption do not exceed 
the reference percentage value of presence condition 
Equipment name: Hot Cathode Fluorescent Lamp, Type designation: YYY 
Unit Restricted substances and its chemical symbols 
Lead 
 
(Pb) Mercury 
 
(Hg) Cadmium 
 
(Cd) Hexavalent 
chromium 
(Cr+6) Polybrominated 
biphenyls 
(PBB) Polybrominated 
diphenyl ethers 
(PBDE) 
Cap ○ ○ ○ ○ ○ ○ 
Tube ○ ○ ○ ○ ○ ○ 
Filler ○ − ○ ○ ○ ○ 
Electrode ○ ○ ○ ○ ○ ○ 
Note 1:  “○” indicates that the percentage content of the restricted substance does not exceed the 
percentage of reference value of presence. 
Note 2:  The “−” indicates that the restricted substance corresponds to the exemption.