Proposal for Amendments to the Legal Inspection Requirements for Freezers  
 
By the Bureau of Standards, Metrology and Inspection (BSMI), Ministry of Economic Affairs (MOEA)  
 
Introduction:  
 
   At present,  only upright freezer s of which the  storage volume does not exceed 400L  are in the scope of mandatory 
inspection of BSMI . However, the storage volume  of commercial upright freezer s has increased . Upright freezers with 
storage volume not exceeding 700L become popular in the market. In addition to that, horizon tal freezer s are also 
getting popular among consumers recently . As a result of risk assessment , BSMI  proposes  to add upright  and horizontal  
freezers with storage volume not exceeding 700L into the scope of legal inspection . 
 
Date of implementation: 1 Januar y 2025 
 
Scope of covered products : 
 
 
Item  
Description of Goods  Inspection Standards  C.C.C. Code (the 
first 6 digits are the 
same as HS Code)  
(For reference)  Conformity 
Assessment 
Procedures  
1 
Freezers (inspection scope:  
rated voltage not exceeding 250V  
and rated storage volume not  
exceeding 700L)  1. CNS 60335 -1 (2014)  
2. CNS 60335 -2-24 (2016)  
3. CNS 13783 -1 (2013)  
4. CNS 2062 (2000) :  
Section  5.2 ”Cooling  Performance ”; 
Section 5.3 “Cooling  Rate”;  
Section 5.10 “Energy efficiency ”; and 
Section 7  ”Marking ” 
5. CNS 15663 (2013) :  
Section 5 “Marking  of presence ” 
6. Product s with secondary lithium 
cells/batteries are required  to conform  
to item 2 of the related requirement s. 8418.40.90.00.3  
8418.30.90.00.5  RPC Scheme 
(Modules II+IV, 
II+V, or II+VII) 
or 
TABI Schem e 
 
The two kinds of conformity assessment schemes for the commodities are as follows:  
1. Registration of Product Certification (RPC) Scheme (Module II + III)  
Under this procedure, domestic manufacturers or importers must have their products type -tested by BSMI 
designated testing laboratories in advance ( Module  II) before applying for registration of their products. 
Manufacturers or importers will also be required to ensure by 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, 
and the declaration procedure is called Module III (conformity -to-type declaration). The conformity -to-type 
declaration shall be drawn up by the manufacturer or the authorize d local representative, declaring that the 
mass -produced products comply with the prototype as described in the type -test report.  
Products will be allowed to use the Commodity Inspection Mark with the letter ‘R’ and the identification 
number given by the B SMI, after they are certified and registered with the BSMI. These products can then clear 
customs directly without any further inspection if not be ing sampled by RPC border check procedure. The 
application fee and annual fee for RPC are both NT$5,000  (abou t US$170) for each certification, and the RPC 
certificates are valid for three years. If there are any serial products, an extra NT$3,000  (about US$102) is charged  
for each application in each certificat e. 
The fees for type -testing vary by products  and dep end on the fee schedule of the testing laboratories.  
 
2. Type -approved Batch Inspection (TABI) Scheme  
Under this scheme, manufacturers or importers shall have their products type -tested by the BSMI or BSMI  
designated testing laboratories, and then file an application for t ype-approval with the BSMI or its branches.  
After manufacturers or importers have obtained a type -approval certificate, they are still required to file an 
application for batch inspection with the BSMI each time before their products arriv e at the port of entry. The BSMI will then perform inspection with simplified procedures. Additional samples may be required for further testing if it 
is deemed necessary. The application fee for a t ype-approval is NT$3,500, and a t ype-approval certificate  is 
generally valid for three years.  
The fees for type -testing vary by products and depend on the fee schedule of the testing laboratories.  
*Further information about the two schemes is also available on the BSMI web site at 
https://www.bsmi.gov.tw/wSite/lp?ctNode=9768&CtUnit=4132&BaseDSD=7&mp=2  
 
Locations to apply for Type Testing:  
The BSMI  designated  testing laboratories.  
 
Locations to apply for Registration of Product  Certification:  
The BSMI or its branch offices.  
 
Time required for Registration of Product Certification:  
Fourteen working days. (This period does not include the time for corrective actions by the applicant due to 
deficiencies in the documents or samples;  another seven working days may be required if additional tests are required .) 
 
Conformity assessment procedure: No change . 
 
Related requirements:  
1. In addition to  section 25.7 of CNS 60335 -1, power cords should also conform to  CNS 15767 -1 “Plugs and 
socket-outlets for household and similar purposes - Part 1: General requirements ” or relevant national standards for 
power cord sets. For products of which  the inspection standard is based on CNS 60335 -1, they do not apply to Class 
0 electrical structures.  
2. For the product with the secondary lithium  cells/batteries , its cells (include the cells in the batteries)  shall conform to 
CNS 15364 : 2013 , and its  batteries shall conform to Sections 7.3.8.1 “vibration” and 7.3.8.2 “mechanical shock”  of 
CNS 62133 -2: 2018  or meet the requirements of relevant national standards or international standards  of newer 
version . The certificates issued by  certification bodies or test reports issued by testing laboratories accredited by 
Taiwan Accreditation Foundation  shall be prov ided. 
3. Section 5.10 of CNS 2062 is replaced by  “the measured value of the energy efficiency of the freezer sh all be more 
than 95% of the declared value. ” 
4. This proposed measure does not apply to products with any of the following features:  
(1)The rated  input voltage is DC 5V and the product has a USB port and does not have  an AC to DC adaptor  and is 
not p owered  by secondary cells/batteries ; 
(2)The product is p owered by automotive power  only and has  automotive cigarette lighter plug  and is not p owered  
by secondary cells/batteries ; 
(3)The product is p owered by three -phase  system s only;  
(4)The product is p owered by  primary batteries  only; or 
(5)The product is a t oy which  is subject to legal inspection.  
5. For p roducts  newly added to the legal inspection sc ope, they (both imported and domestically manufactured) will be 
subject to inspection beginning on 1 January 20 25. The inspection methods, conformity assessment procedures  of 
RPC , and inspection fee s for listed products remain unchanged.  
6. The revised inspection standards  (related requirements  1-3) will come into force from the date of announcement and 
the old version of inspection standards will be invalid beginning on 1 January 2025.  
7. Applications for TABI or  RPC  will be processed in accordance with th e followings upon the date of adoption:  
  (1) For products  that have been certified : Applicant s of the certificate sh all provide the type -test report and technical 
documents that conform to  the revised inspection standards and apply to the BSMI on or prior  to December 31, 
2024. The validity period  of the certificate after renewal will remain unchanged; if the certificate is not renewed 
within the time limit, it will be abolished in accordance with Subparagraph 9 , Article 42 of the the Commodity 
Inspection Act . 
  (2) For e xtension of validity period of certificates : Applica tions for extending the validity period of TABI or RPC 
certificates based on the old version of inspection sta ndards will be accepted under the circumstances stated in 
the “Regulations Governing Type Approval of Commodities ” or “Regulations Governing Registration of 
Product Certification ”, the validity period of the extended certifica te will end on December 31, 20 24. For 
applica tions submitted on or after  1 January 2025 , a type -test report and technical docume nts based on the new 
versions of the inspection standards shall be submitted.  
  (3) For p roducts  newly added to the legal inspection scope : Applicant s shall  apply for certificate (s) based on  the new 
version of inspection standards by preparing the required  type-test reports, technical documents as well as documents indicating  the location of the “Marking of Presence, ” sample s of the “Marking of Presence ” (see 
Tables 1 and 2) , and the “Declaration of the Presence Condition of the Restricted Substances Markin g.” The 
validity period of the certificate is 3 years.  For certificates issued on or prior to 31 December 2024, the 
beginning date of the 3 -year validity will be 1 January 2025.  
8. For applications mentioned in the previous item, if the RPC  was abolished i n accordance  with Subparagraph 9 , 
Article 42 of the the Commodity Inspection Act , the original  type-test reports  of safety and electromagnetic 
compatibility  (EMC ) of the product  may be used for re -applying for RPC . 
9. The certificate  holders of the products shall  clearly label “the presence condition of the restricted substances” on the 
body, package s, stickers , or user manuals  of the products in accordance with the limit  stipula ted in  Section 5 
“Marking of presence”  of CNS 15663 . Those who use website as a means to announce “the presence condition of 
the restricted substance s” shall  also clearly  label the website address on the body, package s, stickers  or user manuals  
of the products. In that case, t he requirements of Section 5.3 of CNS 15663 regarding the position of labeling are not 
applicable.  
10. The Commodity  Inspection Mark:  
   (1) The Commodity Inspection Mark sh all be printed by the certificate holder s. 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) T he 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 . Where the size of connectors for 
wiring or cord sets is too small to label information about RoHS or RoHS (XX) below or to the right of the 
Commodity  Inspection Mark , it can be labeled near the Commodity  Inspection Mark . 
   (3) T he size  of the Mark can be applied  proportionally  on a prominent location  of the products.  The Mark shall use 
materials that are not easily altered, and the conten t shall be in a clearly identifiable and indelible form affixed 
permanently to the product . 
   (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 rest ricted 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 p ercentage 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 th e respective reference percentage value specified in Annex A to CNS  15663.  
14. T he C.C.C. Code listed in the table is used for reference only. The products listed in the table shall  still complete 
the inspection procedures before entering into the market e ven though their C.C.C. Code is  determined differently 
by the Customs Administration, Ministry of Finance, or Bureau of Foreign Trade,  Ministry of Economic Affairs . 
15. The inspection standards of the products listed in the table shall be the version publi shed in this  announcement. If 
any updated version is available, the BSMI shall publish the implementation date of  the updated version in further 
announcement . 
16. The import regulation code  for the listed products is C02 . 
17. Commodities with combined feat ures or multifunctional products  shall comply with the respective inspection 
standards and the applicable modules under the RPC  scheme . 
 
 
Table 1. Example of marking s for the presence conditions of the restricted substance s exceed s the reference 
percentag e value of presence conditions  
Equipment name: Freezers , 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)  
Plug Plastic 
Frame  Exceeding  
0.1 wt %  ○ ○ ○ ○ ○ 
Wire Material  ○ ○ ○ ○ ○ ○ 
Solder  (ire 
and Copper 
Sheet)  ─ Exceeding  
0.1 wt %  ○ ○ ○ ○ 
Socket 
Housing  ○ ○ ○ ○ ○ ○ 
Copper 
Sheet  ○ ○ Exceeding  
0.01 wt %  ○ ○ Exceeding  
0.1 wt %  
Note 1:   “Exceedin g 0.1 wt %” and “exceeding 0.01 wt %” indicate that the percentage content of the 
restricted substance exceed s the reference percentage value of presence condition.  
Note 2:   “○” indicates that the percentage content of the restricted substance does not exc eed the 
percentage of reference value of presence.  
Note 3:   The “−” indicates that the restricted substance corresponds to the exemption.  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 Table 2. Example of marking s for the content of the restricted substance s other than exemption do not  exceed the 
reference percentage value of presence condition  
Equipment name: Freezers , Model：YYY 
Unit Restricted substances and its chemical symbols  
Lead  
 
(Pb) Mercury  
 
(Hg) Cadmium  
 
(Cd) Hexavalent 
chromium  
(Cr+6) Polybrominated 
biphenyls  
(PBB)  Polybro minated 
diphenyl ethers  
(PBDE)  
Plug Plastic 
Frame  ○ ○ ○ ○ ○ ○ 
Wire Material  ○ ○ ○ ○ ○ ○ 
Solder( Wire 
and Copper 
Sheet)  − ○ ○ ○ ○ ○ 
Socket 
Housing  ○ ○ ○ ○ ○ ○ 
Copper 
Sheet  ○ ○ ○ ○ ○ ○ 
Note 1:   “○” indicates that the percentage content of the restricte d substance does not exceed the 
percentage of reference value of presence.  
Note 2:   The “−” indicates that the restricted substance corresponds to the exemption.  
Note    *The 1st “name and model” row can be omitted if the position of “the markings for the  presence conditions” 
shows clearly to specify the corresponding commodity.  
*Multiple models could be shown together in the same field if “the markings for the presence conditions” can 
be applied to contemporarily.