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How to comply with the Product Security and Telecommunications Infrastructure Act 2022 if you manufacture, import, or distribute consumer connectable products in the UK. Covers the three mandatory security requirements, supply chain duties, products in scope, and OPSS enforcement powers.
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The Product Security and Telecommunications Infrastructure Act 2022 (PSTI Act) sets mandatory cyber security requirements for consumer connectable products sold in the UK. The product security regime has been in force since 29 April 2024.
If your business manufactures, imports, or distributes internet-connected or network-connected consumer products, you have legal duties under this Act. Non-compliance can result in penalties of up to £10 million or 4% of qualifying worldwide revenue.
The Act places duties on three categories of business in the supply chain. Your obligations depend on your role.
If you fulfil more than one role (for example, you import products and also sell them directly to consumers), you must meet the duties for each role.
The PSTI Act imposes three baseline security requirements that all relevant connectable products must meet before being made available to UK consumers.
Each role in the supply chain has specific obligations. Failing to meet your duties is a criminal offence.
As a manufacturer, you carry the broadest obligations: - Ensure your product meets all three security requirements before it is made available in the UK - Produce a statement of compliance for each product, confirming it meets the requirements - Keep the statement of compliance for at least 10 years and provide a copy to the relevant enforcement authority on request - Include the statement of compliance (or a link to it) with the product - Investigate any compliance failure you become aware of and take corrective action, including notifying distributors and importers - Maintain records that allow the product to be traced through the supply chain
Before making a product available on the UK market, you must: - Verify that the manufacturer has produced a valid statement of compliance - Check that the product meets all three security requirements - Not make the product available if you know or believe it does not comply - Keep a copy of the statement of compliance for at least 10 years - Provide the statement to the enforcement authority on request - Take corrective action (including withdrawing the product) if you become aware of non-compliance after making it available
As a distributor, you must: - Not make a product available to consumers if you know or have reason to believe it does not comply - Take reasonable steps to verify compliance before making products available - Take corrective action if you become aware of non-compliance, including stopping supply and notifying the manufacturer or importer - Cooperate with the enforcement authority and provide information on request
The Act covers consumer connectable products – products that connect to the internet or to a network and are made available to consumers in the UK. This includes:
The following product categories are excluded because they are regulated under separate frameworks:
If you are unsure whether your product falls within scope, check OPSS guidance or seek legal advice before making the product available.
The Office for Product Safety and Standards (OPSS) enforces the PSTI Act product security regime. OPSS has wide-ranging powers to investigate non-compliance and take enforcement action.
Maximum penalty: £10 million or 4% of qualifying worldwide revenue (whichever is greater).
Daily default penalty: £20,000 per day for a continuing breach after a compliance notice has been issued.
OPSS can also issue stop notices (prohibiting supply), recall notices (requiring product recall from consumers), and compliance notices (requiring specific corrective action).
OPSS takes a proportionate approach to enforcement. In most cases, OPSS will engage with businesses before taking formal action. However, the regulator can and does act swiftly where there is a serious or ongoing risk to consumers.
If OPSS identifies a potential breach, the typical enforcement pathway is:
If you manufacture, import, or distribute consumer connectable products:
The requirements have been in force since 29 April 2024. If you have not yet taken action, you should review your compliance position as a matter of urgency.