1 
 Proposal for a mendment to l egal inspection  requirements  for hot cathode 
fluorescent lamp s 
 
By the Bureau of Standards, Metrology and Inspection  (BSMI), Ministry of Economic Affairs  MOEA  
 
Introduction:  
The Bureau of Standards, Metrology and Inspection i s proposing to adopt 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.  
 
Proposed  date of implementation:  1 January  2021 
 
 Description of Goods  Inspection Standards  C.C.C. Code (the 
first 6 d igits are the 
same as HS 
Code)(R eference)  
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：Module s II + III  
Under th e 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 declaratio n (Module III , conformity -to-type declaration ) that all products made at 
their manufacturing facilities or imported are in conformity with the prototypes submitted f or type -test at 
Module II stage . The conformity -to-type declaration shall be drawn up by the manufacturer or the 
author ized 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‟ a nd the identification number given by the BSMI. Additionally , these 
products can  clear  customs directly without any further inspection if not be ing sampled by RPC border 
check procedure s. 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$10 0) of application fee will be charged  for every application in each certification.  
The fees for type testing var y 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 laboratorie s 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 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 val id for 3 years. The fees for type testing vary 
by products and depend on the fee policies of the testing laboratories.  2 
 *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  
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 bec ome 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 standard s of CNS 691 to apply for re placing 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 . 
Otherw ise, 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 a pplication  or extension : 
From the date of publication, applicant s shall  prepare Type -Test report in accordance with  the 
revised inspection standard s, 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 applicant s apply for certificate (s) in accordance with the original inspection 
standard s, the expiry date of the certificate  will be only valid till  31 December  2020. From 1 January  
2021, applicant s shall  file a new application or extension only  in accordance with the revised 
inspection standard s. 
3. The applicable Inspection Schemes , applicable c onformity assessment modules of Registration of Product 
Certification(RPC) , the t erm 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 clearl y mark  “the presence condition  of the restricted substance s” on the 
body, package s, stickers , or the instruction books of the commodities . Those who utilize  website as a 
means to announce  “the presence condition  of the restricted substance s” of the commodi ties shall  also 
clearly  mark  the website address on the body, package s, stickers,  or the instruction books of the 
commodities . In that case, t he 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 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) 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 applie d proportionally  on a prominent location  of the commodit ies. 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:  
 
 
 
 
 
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 (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 co ndition.  
Restricted substances: Pb, Cd, Hg, Cr+6, PBB, and PBDE.  
Example s:  
 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 commodi ty listed in the table shall  still 
complete th e 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 Economi c 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 . 
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 Table 1. Example of marking s for the presence conditions of the restricted substance s exceed the reference 
percentage value of presence conditions  
Equipment name: Hot Cathode Fluorescent Lamp, Type designation: XXX  
Unit Restricted substances and its che mical 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 exceed s the reference percentage value of presence condition.  
Note 2:   “○” indicates that the percentage content of the restricted substance does not ex ceed 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 restricted substance s 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 subs tance does not exceed the 
percentage of reference value of presence.  
Note 2:   The “−” indicates that the restricted substance corresponds to the exemption.