FAQs for electricians

If your products are not specifically named in the “excepted products” list, you should read “What products are in-scope?” above and the relevant provisions of the Act such as sections 54 (Meaning of “UK consumer connectable product”) and 55 (Meaning of “supply”). 

A product that can only connect to another single device is in scope if

(i) that product itself is capable of connecting directly to the internet ("internet-connectable product") 

or 

(ii) that product itself is not capable of connecting to the internet but is capable of both sending and receiving data by means of electrical or electromagnetic means and is also capable of connecting directly to an internet-connectable product by use of the Internet Protocol suite ("IP suite"). 

For example, a washing machine that can send and receive data only to and from a single device (such as a smart phone)

Is in scope

• if the data transmission will be done by electrical or electromagnetic means (such as by Bluetooth) and the washing machine itself can also connect directly via internet by using for example Wi-Fi to the smart phone or any other single internet-connectable device

Or

•  if it can connect directly to the internet. 

Is out of scope

if the washing machine cannot itself connect directly to the internet or any internet-connectable device via the internet.  

Non-compliant PSTI stock of in-scope products cannot be made available from 29th April 2024. This includes products held in stock by an importer, distributor or retailer for onward supplies to another business or a consumer. Any business that supplies an in-scope product after this date in the UK, whether that be to a business or consumer customer, must comply with PSTI. For example, if anyone is holding stock of an in-scope product without a statement of compliance on 29th April 2024, this cannot be compliantly sold or otherwise supplied from this date.

You can make an in-scope product available in more than one way for example by:

• sale;
• giving it away for free or in exchange for something other than money;
• hiring or lending (but not when renewing the relevant contract) it if you are a manufacturer of the product; or
• supplying it under a hire-purchase agreement.

If you install the product into a building as part of your installation service or construction of the building, you are treated as making such product available by performing the installation or construction work.

You are not considered as making a product available by for example just transporting it or returning it to your customer after keeping it temporarily (e.g. for repair).

See above. All in-scope products made available in the UK, regardless of source or method of sales from 29 April 2024, will be subject to the new requirements under PSTI. 

In-scope products without copies of the statement of compliance cannot be made available from 29 April 2024. The copies of the statement if not shipped together with such products will therefore need to be provided by the manufacturer separately so that the distributor (or others within the supply chain) can arrange for a copy to be provided together with each product. The best chance for all parties to be compliant is to introduce the statement of compliance as soon as possible, to allow enough 'buffer' time to sell stock without disruption beyond 29 April 2024.

A statement of compliance must be a document that accompanies the in-scope product. PSTI however does not define the term “accompany”. A physical copy of the statement provided with the product should suffice however it does not necessarily need to be in a separate document. It could be included in the packaging or the instructions for use that accompany the product.

The statement could be in a digital form. However, if you make available an in-scope product that does not come with a physical copy of the statement, you need to be able to show that the digital statement for that product ‘accompanies’ the product.

 Use of a summary statement is currently not permitted. All information required under PSTI (https://www.legislation.gov.uk/uksi/2023/1007/schedule/4/made) must be included in the statement. 

A statement of compliance must accompany the product (see the Q&A above). There is no guidance on whether providing a QR code leading to a digital statement with an in-scope product satisfies this requirement.

Yes, a manufacturer can subsequently extend the minimum length of time for which security updates will be provided, creating a new defined support period, by publishing the new defined support period “as soon as is practicable.”

https://www.legislation.gov.uk/uksi/2023/1007/schedule/1/paragraph/3/made 

No, there is no stipulation in PSTI for the duration of the support period or the minimum number of security updates that must be provided

No, there is no definition of "batch" in PSTI. We encourage manufacturers to use an established and documented serial coding or batching system.

Yes, this period must be "the minimum length of time, expressed as a period of time with an end date, for which security updates will be provide” however the legislation is silent on the start date.

The minimum or ‘defined’ support period must be expressed as a period of time “with an end date”. This information must be in English, accessible, clear, transparent and made available in a way that is understandable by a reader without prior technical knowledge.

Therefore, such period can be expressed by reference to a specific end date. If the end of the period is expressed by reference to a month and/or year, use of the words such as “until the end of” together with the month/year might be helpful in clarifying the end date and meeting these requirements. 

The PSTI does not require any product to have the capability or feature of receiving security updates. The requirements relating to the minimum support period under PSTI do not apply if the relevant hardware or software is not capable of receiving security updates.

A statement of compliance would be required for in-scope products if (in essence) the manufacturer intends those products to be supplied in the UK. 

The PSTI does not specifically require a product to have a password, rather, it sets out the requirements that apply to a password where it is used by an in-scope product and if the hardware or software of that product has the features set out in the Regulations.

There is no specific number of times that you must provide a status update or frequency at which you have to give such update before the reported issue is resolved.

Whilst there is no guidance that has been issued by the government on this, an update every two weeks could be an option given that the government’s Call for Views published in July 2020 stated that a non-indicative or implicative example could be fortnightly status updates until resolution of the issue.  

OPSS guidance on the enforcement of PSTI can be found here. 

DSIT guidance on the PSTI regime can be found here.

Our speakers share their best practice cases and look to the future on upcoming developments in the sector. If you want to see safety and resilience develop in your business and get feedback about your ideas from fellow professionals, this is the right place to do it.

Government departments, manufacturers, retailers, importers, lawyers, fire and rescue services, and test houses.

Yes, but your guest would also need to register – we have two for one offers to take advantage of.

We regret that we are unable to issue refunds. If you cannot attend, please tell us as soon as possible - your ticket may also be given to a colleague.

Use our contact form to get in touch. 

For sponsorship opportunities please contact ellen.vester@electricalsafetyfirst.org.uk or use our contact form.