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 Proposal for Legal Inspection Requirements for Double-capped LED Lamps 
 
By the Bureau of Standards, Metrology and Inspection (BSMI), Ministry of Economic Affairs (MOEA) 
 
Introduction: 
 The use of double-capped LED lamps is becoming prevalent in domestic households. To enhance 
consumer protection and promote efficiency of energy use, the Bureau of Standards, Metrology and 
Inspection(BSMI) proposes to regulate double-capped LED lamps in aspects of safety (CNS 15438, CNS 
15829, CNS 15983 or CNS 62931), performance (CNS 16027), EMC (CNS 14115) and use of hazardous 
substances (Section 5 of CNS 15663). The conformity assessment procedure will be Registration of Product 
Certification Scheme (Module II+III) or Type-approved Batch Inspection Scheme. 
  
Proposed date of implementation:  1 January 2022 
 
Scope of covered products: 
Description of Goods  Inspection Standards C.C.C. Code (the first 
6 digits are the same as 
HS Code)(Reference)  Conformity 
Assessment 
Procedures 
Double-capped LED lamps 
(inspection scope: those for 
general purpose, including 
CRI above 95) 1. CNS 15438(2019) or 
CNS 15829(2015) or 
CNS 15983(2019) or 
CNS 62931(2019) 
2. CNS 16027(2019) 
3. CNS 14115(2016) 
4. CNS 15663 (2013) Section 5 
“Marking of Presence” 8539.50.00.00.3B RPC Scheme 
(Modules II+III)  
or 
TABI Scheme  
 
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-recognized 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. 
 
2. Type-approved Batch Inspection (TABI) Scheme 
Under this procedure, manufacturers or importers shall have their products type-tested by the BSMI or 
the designated testing laboratories recognized by the BSMI, 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 2 
 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 the two schemes can also be found on the BSMI web site: 
http://www.bsmi.gov.tw/wSite/ct?xItem=8673&ctNode=811&mp=2  
 
Locations to apply for Registration of Product Certification: 
The BSMI or its branches. 
 
Time required for Registration of Product Certification: 
14 working days. (This period does not include the time for corrective actions by the applicant due to 
deficiencies in the documents or samples. Extra 7 working days may be required if additional tests are 
required.) 
 
Related requirements: 
1. Upon the date of announcement of this measure, applications can be made to the BSMI for RPC 
certification. When the BSMI completes the review procedure and approves the application, a certificate 
will be issued and valid for 3 years. 
2. For the requirement of Section 5 “Marking of presence” of CNS 15663, the certificate holders of the 
commodities shall 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 clearly mark the website 
address on the body, packages, stickers, or the instruction books of the commodities, instead. 
3. 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 “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 to the right of 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, 
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 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. 
The restricted substances: indicates Pb, Cd, Hg, Cr+6, PBB, and PBDE. 
Examples:  
 RoHS (Pb): indicates that the Pb percentage content in certain parts of the commodity exceeds the 
reference percentage value of presence condition. 
 RoHS (Cd, Cr+6, PBB): indicates that the Cd, Cr+6, and PBB percentage content in certain parts of the 
commodity exceed the reference percentage value of presence condition respectively. 
4. The C.C.C. Codes listed in the table are used for reference only. The commodities shall still comply with 
the requirements before entering into the market, even though their C.C.C. Codes are identified differently 
by the Customs Administration, Ministry of Finance or Bureau of Foreign Trade, Ministry of Economic 
Affairs. 
5. The inspection standards of the commodities 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. 
6. Commodities with combined features or multifunctional products shall comply with the respective 
inspection standards and the conformity assessment procedures of RPC scheme. 
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 Table 1. Example of markings for the presence conditions of the restricted substances 
exceeds the reference percentage value of presence conditions  
Equipment name: Double-capped LED lamps, Model ：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 % ○ ○ ○ ○ ○ 
Lamp 
housing ○ ○ ○ ○ ○ ○ 
LED Die ○ ○ Exceeding  
0.01 wt % ○ ○ ○ 
Driver ○ ○ ○ ○ ○ ○ 
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. 
Note 2:  “○” indicates that the percentage content of the restricted substance does not exceed the 
reference percentage value. 
 
Table 2. Example of markings for the content of the restricted substances other than 
exemption do not exceed the reference percentage value of presence condition 
Equipment name: Double-capped LED lamps, Model ：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 ○ ○ ○ ○ ○ ○ 
Lamp 
housing ○ ○ ○ ○ ○ ○ 
LED Die ○ ○ － ○ ○ ○ 
Driver ○ ○ ○ ○ ○ ○ 
Note 1:  “○” indicates that the percentage content of the restricted substance does not exceed the 
reference percentage value. 
Note 2:  The “−” indicates that the restricted substance is exempted. 
 (*) The “name and model” can be omitted if the position of the “markings for the presence 
conditions” clearly identifies the corresponding commodity. Multiple types could be 
shown together if the “markings for the presence conditions” are applicable.