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Across 8 modules • Updated May 9, 2026
Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
ETSI EN 303 645 consumer IoT products: what is in scope?

What counts as a consumer IoT product under ETSI EN 303 645?

ETSI EN 303 645 defines a consumer IoT device as a network-connected or network-connectable device that has relationships to associated services and is typically used by consumers in the home or as an electronic wearable. The standard also defines an IoT product as the consumer IoT device plus its associated services.

The scope is broad but not unlimited. ETSI lists examples such as connected children's toys and baby monitors, smoke detectors, door locks, window sensors, IoT gateways, base stations, hubs, wearable health trackers, home automation and alarm systems, connected appliances, and smart home assistants. Devices primarily intended for manufacturing, healthcare, or other industrial applications are outside the document's scope.

  • Start the scope note with the exact device or product family, its network connectivity, and the consumer use case.
  • Include associated services that are required for the product's intended functionality, such as manufacturer-provided cloud access, telemetry, or a companion mobile app.
  • Do not stretch the scope to industrial, healthcare, or manufacturing devices unless the product is also a consumer IoT device under the ETSI definition.
Citations
ETSI TS 103 701 V2.1.1, scope

Assessment source confirming that the methodology covers consumer IoT devices, their associated services, and corresponding relevant processes.

ETSI EN 303 645 consumer IoT products: what is in scope?

How should teams document product scope for assessment?

For assessment work, ETSI TS 103 701 uses the Device Under Test, or DUT, as the specific consumer IoT device assessed against ETSI EN 303 645. TS 103 701 says test scenarios address DUT functionality, its relation to associated services, and development or management processes.

The supplier organization provides ICS and IXIT information to the test laboratory. The ICS declares capabilities implemented in or supported by the DUT, while the IXIT contains or references the additional information about the DUT and assessment environment that enables appropriate test activities. The test laboratory uses those documents to derive a test plan.

  • Identify the DUT, software version, interfaces, associated services, and relevant supplier-side processes before claiming assessment readiness.
  • Use the EN 303 645 implementation conformance statement pro forma to record support, non-support, or not-applicable rationale for each provision.
  • Use the TS 103 701 IXIT structure to point assessors to the evidence needed for conceptual and functional tests.
Citations
ETSI EN 303 645 consumer IoT products: what is in scope?

What scope mistakes create weak ETSI EN 303 645 claims?

A weak scope claim treats ETSI EN 303 645 as a generic product-security label. The standard is product-specific and provision-specific: applicability can depend on the device, whether it is constrained, whether the functionality exists, and which associated services are part of the product.

Constrained devices need explicit handling. ETSI describes constrained devices as devices with physical limitations in processing, communication, storage, or user interaction, and gives examples such as window sensors and low-powered devices that rely on a base station or hub. If a recommendation is considered not applicable or not fulfilled, provision 4-1 requires a recorded justification.

  • Avoid saying a whole product is compliant without naming the assessed device, associated services, provisions, software version, and evidence boundary.
  • Do not exclude a cloud service or companion app when it is an associated service required for the product's intended functionality.
  • Record constrained-device and not-applicable decisions as product-specific justifications instead of using generic wording.
Citations
ETSI EN 303 645 default passwords: what must consumer IoT teams do?

What does ETSI EN 303 645 require for default passwords?

Provision 5.1-1 applies where passwords are used. In any state other than factory default, each consumer IoT device password must be unique per device or defined by the user. That means a shipped value such as a universal admin password cannot be the operational password after setup.

The standard gives several acceptable patterns: unique pre-installed passwords, requiring the user to choose a password during initialization, or avoiding passwords by using another authentication method. The answer should be scoped to each authentication mechanism, not just to the product as a whole.

  • List every password-based authentication mechanism for users and machine-to-machine authentication.
  • For each mechanism, state whether the password is user-defined, unique per device, factory-default only, or not used.
  • Do not present a product as aligned with provision 5.1 if a universal password remains usable after initialization or reset into an operational state.
Citations
ETSI EN 303 645 default passwords: what must consumer IoT teams do?

How should pre-installed unique passwords be handled?

Provision 5.1-2 applies when pre-installed unique per-device passwords are used. The generation mechanism must reduce the risk of automated attacks against a class or type of device, so the evidence has to cover the generation method, not only a sample label or onboarding screenshot.

ETSI gives examples of weak patterns to avoid: incremental counters, common strings, and passwords obviously related to public information such as MAC addresses or Wi-Fi SSIDs. TS 103 701 turns that into conceptual checks on regularities, common patterns, relationship to public information, and appropriate complexity.

  • Document the password generation mechanism in IXIT 1-AuthMech, including the authentication mechanism that uses it.
  • Show that generated passwords are not based on predictable counters, public identifiers, common strings, or obvious device information.
  • Keep functional evidence that sampled device passwords match the documented generation mechanism.
Citations
ETSI EN 303 645 default passwords: what must consumer IoT teams do?

What else belongs in a provision 5.1 password evidence pack?

Default-password work is only one part of clause 5.1. If users can authenticate against the device, the device must provide a simple mechanism for the user or administrator to change the authentication value. If the device is not constrained, it must also have a mechanism that makes brute-force attacks on authentication mechanisms via network interfaces impracticable.

For an assessment, TS 103 701 expects the supplier organization to complete ICS and IXIT information so the test laboratory can derive a test plan. Incomplete IXIT information can lead to an inconclusive test result because the test case cannot be properly executed.

  • Include user-facing instructions for changing passwords or other authentication values, and verify the old value stops working after change.
  • Document brute-force prevention for network-addressable authentication, such as delays, limited attempts, suspension, lockout, suitable entropy, or two-factor authentication.
  • Tie each claim to the assessed device version, user manual, interfaces, onboarding flow, reset behavior, and IXIT entries used by the test plan.
Citations
ETSI EN 303 645 personal data deletion FAQ for consumer IoT

What does ETSI EN 303 645 require for personal data deletion?

Clause 5.11 of ETSI EN 303 645 is the main deletion section. Provision 5.11-1 says the user shall have functionality so user data can be erased from the device in a simple manner. The standard defines that user data broadly for this context: individual data stored on the IoT device, including personal data, user configuration, and cryptographic material such as user passwords or keys.

Provision 5.11-2 is narrower and service-focused. It says the consumer should have functionality on the device so personal data can be removed from associated services in a simple manner. The examples given by ETSI include transfer of ownership, the consumer wanting to delete personal data, removing a service from the device, and disposal of the device.

  • Treat device erasure and associated-service removal as two related but distinct deletion paths.
  • Do not assume a factory reset is enough for every privacy scenario; ETSI gives a shared-use example where resetting the whole device would not be appropriate for deleting one user's personal data.
  • Keep GDPR statements narrow: EN 303 645 says the functionality is expected to comply with applicable data protection law, including GDPR, but the standard itself presents technical baseline provisions rather than a full legal assessment.
Citations
ETSI EN 303 645 V2.1.1, clause 5.11

Primary ETSI source for consumer IoT user-data erasure, personal-data removal from associated services, deletion instructions, confirmation, and the caution that factory reset is not always the right mechanism.

ETSI EN 303 645 V2.1.1, clause 6

Privacy context for consumer IoT, including clear information about personal data processing, valid consent where consent is the basis, withdrawal capability, and telemetry minimization.

ETSI EN 303 645 personal data deletion FAQ for consumer IoT

What should the user experience include?

The standard uses simple, user-facing language. Deletion should require minimal steps and minimal complexity, and users should receive clear instructions on how to delete their personal data.

ETSI also expects clear confirmation that personal data has been deleted from services, devices, and applications. For a product team, this means the deletion flow should not stop at a hidden backend job or a vague success message; the user should be told what was deleted and where the deletion applied.

  • Show the deletion entry point in the relevant device, app, or service interface instead of burying it in support-only processes.
  • Explain whether the action erases device-stored user data, removes personal data from associated services, deletes an app or account profile, or does more than one of these.
  • Confirm the result in user-visible language, including any practical consequence such as logout, loss of remote services, or return to factory-default state.
Citations
ETSI TS 103 701 V2.1.1, sample IXIT 25-DelFunc

The sample IXIT illustrates deletion-function evidence fields such as description, target type, initiation and interaction, and confirmation for device reset and online-profile removal examples.

ETSI EN 303 645 personal data deletion FAQ for consumer IoT

What evidence should teams keep for assessment?

ETSI TS 103 701 maps the deletion provisions to concrete IXIT entries. For 5.11-1, the required deletion-function evidence includes an ID, description, target type, and initiation and interaction. For 5.11-2, teams also need personal-data evidence that describes the personal data and processing activities, linked to the deletion functionality.

For 5.11-3 and 5.11-4, the evidence extends to user information: documentation of deletion, personal-data and deletion-function entries, and confirmation evidence. The useful evidence packet therefore joins three views: the personal data inventory, the deletion function, and the user-facing documentation or confirmation.

  • Maintain a personal-data inventory that records what personal data is processed, the purpose, authorized parties, lifecycle, and processing activities where those fields apply.
  • Maintain a deletion-function record for each deletion route, including the target type and the exact user interaction that initiates it.
  • Retain screenshots, user documentation, or other visible evidence showing the deletion instructions and the confirmation shown after deletion.
Citations
ETSI EN 303 645 support period: what must consumer IoT teams publish?

What does ETSI EN 303 645 mean by support period?

The support period is not a general warranty promise. ETSI EN 303 645 defines it specifically around security updates: the minimum length of time, expressed as a period or by an end date, for which the manufacturer will provide security updates.

For visitor-facing content, the useful answer should say what security-update support period applies to the product and where a user can find it before or around purchase. Avoid vague statements such as "supported for a reasonable period" if the product evidence does not define a duration or end date.

  • State the support period as a concrete period or end date for the consumer IoT product.
  • Keep the claim limited to security-update support unless separate sources support broader product-support or warranty language.
  • Tie the support-period statement to the product or model designation users need in order to check update support.
Citations
ETSI EN 303 645 support period: what must consumer IoT teams publish?

What must be published for users?

Provision 5.3-13 requires the manufacturer to publish the defined support period in an accessible, clear, and transparent way. The surrounding ETSI text explains why: when purchasing a product, the consumer expects the period of software-update support to be clear.

TS 103 701 makes this assessable through IXIT 2-UserInfo. The assessment checks whether a user with limited technical knowledge can understand and access the publication, whether access is unrestricted, and whether the published support period matches the support-period information documented for updateable software components.

  • Publish the support period where users can reach it without registration or other access restrictions.
  • Document the publication path in IXIT 2-UserInfo as "Publication of Support Period", including the information needed to access it.
  • Check that the public page, product information, app help path, or manual points to the same support period recorded in the assessment evidence.
Citations
ETSI EN 303 645 support period: what must consumer IoT teams publish?

How should constrained or non-updateable devices be handled?

If a constrained device cannot have its software updated, do not treat the support-period answer as complete by saying updates are not available. ETSI EN 303 645 provision 5.3-14 says the manufacturer should publish the rationale for the absence of software updates, the period and method of hardware replacement support, and a defined support period in an accessible, clear, and transparent way.

TS 103 701 separates this evidence from the normal support-period publication. It checks the published rationale for absence of updates and the published hardware replacement support information, including period and method. It also maps replacement-support evidence to IXIT 9-ReplSup for constrained-device isolation and hardware replacement.

  • For updateable products, publish the defined security-update support period and keep it aligned with update evidence.
  • For constrained non-updateable products, also publish why software updates are absent and how hardware replacement support works.
  • Keep replacement-support and isolation evidence separate from general marketing claims so assessors can trace the constrained-device route.
Citations
ETSI EN 303 645 telemetry: what should consumer IoT teams evidence?

What does ETSI EN 303 645 say about telemetry?

EN 303 645 defines telemetry as data from a device that can help the manufacturer identify issues or information related to device usage. Provision 5.10-1 is conditional: if telemetry data is collected from consumer IoT devices and services, such as usage and measurement data, it should be examined for security anomalies.

The standard gives practical examples of the kind of security signal it expects teams to look for: deviations from normal device behaviour, such as an abnormal increase in failed login attempts, or telemetry across multiple devices showing that updates are failing because software update authenticity checks are invalid.

  • Start by listing the telemetry actually collected by the device and associated services, not by writing a generic monitoring statement.
  • For each telemetry category, document whether it is used for security anomaly examination or only for another purpose such as performance or stability analysis.
  • Keep the claim conditional: EN 303 645 does not require every product to collect telemetry, but collected telemetry should be examined for security anomalies.
Citations
ETSI EN 303 645 telemetry: what should consumer IoT teams evidence?

What evidence should support a telemetry claim?

TS 103 701 turns the telemetry provision into IXIT 24-TelData evidence. The completed IXIT lists telemetry collected by the device and associated services, with an identifier, description, purpose, security examination, and references to any personal data processed in the telemetry data.

For provision 5.10-1, the test laboratory checks whether at least one security examination is provided in IXIT 24-TelData for examining security anomalies. It also assesses whether each associated telemetry description is suited to the described security examination.

  • Use a TelData entry for each meaningful telemetry category, such as crash logs, update failure signals, failed-login indicators, usage measurements, or stream metadata.
  • For telemetry used in security monitoring, describe how anomalies are examined and whether the examination is performed by the device or by an associated service.
  • If a telemetry category is not used for security examination, say so plainly instead of implying that every telemetry feed is security telemetry.
Citations
ETSI EN 303 645 telemetry: what should consumer IoT teams evidence?

How should telemetry personal data and consumer information be handled?

EN 303 645 clause 6 is the relevant place to narrow privacy-facing telemetry statements. It says the document addresses personal-data protection from a strictly technical perspective, so teams should avoid broad legal-compliance claims unless they have separate legal grounding.

For collected telemetry, provision 6-4 says personal-data processing should be kept to the minimum necessary for the intended functionality. Provision 6-5 says consumers must be told what telemetry data is collected, how it is used, by whom, and for what purposes.

  • Map any personal data in telemetry to IXIT 21-PersData and keep only the data needed for the stated telemetry purpose.
  • Make the consumer-facing telemetry notice accessible and consistent with the IXIT 2-UserInfo documentation of telemetry data.
  • When publishing product claims, say that the ETSI evidence supports technical data-protection provisions; do not claim GDPR compliance from EN 303 645 alone.
Citations
ETSI EN 303 645 test evidence: what should consumer IoT teams keep?

What counts as test evidence for ETSI EN 303 645?

Start with the distinction between the two ETSI documents. EN 303 645 is the baseline requirements standard for consumer IoT devices and associated services. Its Annex B ICS pro forma lets the user of the standard record whether each provision is supported, not supported, or not applicable, and the detail column explains the implemented measure or rationale.

TS 103 701 is the assessment methodology. It defines the Device Under Test, Supplier Organization, Test Laboratory, ICS, IXIT, test plans, conceptual tests, functional tests, external evidence, and verdict handling. A useful evidence pack therefore should not say only "tested to EN 303 645"; it should show the assessed DUT, the ICS claim, the IXIT detail, the test group or external evidence used, and the verdict basis.

  • Keep the EN 303 645 provision mapping separate from TS 103 701 assessment records.
  • For each supported provision, retain the ICS support claim and the IXIT information needed to prepare and perform assessment activities.
  • Tie each test result to the specific DUT, software version, associated services, user documentation, and development or management process in scope.
Citations
ETSI EN 303 645 test evidence: what should consumer IoT teams keep?

How should ICS and IXIT evidence be prepared?

Under TS 103 701, the supplier organization completes identification of the DUT, the ICS, and the necessary IXIT information. The ICS states which EN 303 645 provisions are objects of the assessment. The IXIT contains additional information about the DUT and assessment environment so the test laboratory can choose suitable test methods, equipment, conditions, and instructions.

This means evidence should be specific enough for a test plan. For a provision claimed as "Yes", the IXIT should contain or reference the implemented security measures needed for the corresponding test group. If the IXIT is incomplete or insufficient, TS 103 701 allows an inconclusive verdict because the test case cannot be properly executed.

  • Record "Yes", "N", or "N/A" support values in the ICS with the required detail or justification.
  • Complete only the IXIT entries needed for provisions claimed as "Yes", but make those entries exhaustive, correct, and distinctly referenced.
  • Where the IXIT references existing documentation, provide that documentation to the test laboratory instead of relying on an unsupported assertion.
Citations
ETSI EN 303 645 test evidence: what should consumer IoT teams keep?

Can existing certificates or third-party reports replace testing?

Sometimes, but only within the TS 103 701 external-evidence rules. Existing security certifications or third-party evaluations of parts of the DUT may be used partially as evidence to reduce assessment effort. The supplier organization has to announce the evidence in the addressed ICS detail field and provide the certification, certification details, test reports, or other information needed for verification.

The test laboratory still has to decide whether the evidence is adequate for the corresponding test group. TS 103 701 says the laboratory examines whether the scope matches the test group objective, whether the evidence's test activities meet each test purpose in the test group, and whether the test depth or evaluation assurance level is appropriate to the level addressed by the test group.

  • Do not reuse a certificate or report unless its scope covers the same DUT part, feature, software, service, or process needed by the test group.
  • Keep the external evidence reference in the ICS detail field together with the supporting report or certification details.
  • Treat external evidence as a TS 103 701 assessment input, not as a blanket EN 303 645 conformance claim for the whole product.
Citations
ETSI EN 303 645 vulnerability disclosure requirements for consumer IoT

What must the public vulnerability disclosure policy include?

The public policy is not just a security mailbox. EN 303 645 provision 5.2-1 says the manufacturer shall make a vulnerability disclosure policy publicly available and that the policy includes contact information for reporting issues plus a timetable for initial acknowledgement and status updates until reported issues are resolved.

For visitors, buyers, researchers, and assessors, the policy should make the reporting path visible without requiring private documentation. TS 103 701 turns that into both a conceptual and functional assessment: the test laboratory checks the publication route described in IXIT 2-UserInfo and verifies that the policy is publicly accessible.

  • Publish a clear external location for the vulnerability disclosure policy, such as a security page or support path that remains reachable without authentication.
  • Include contact information that lets security researchers and other reporters submit potential vulnerabilities.
  • State timelines for initial acknowledgement and for status updates until resolution, avoiding vague process text that gives reporters no expectation.
  • Keep product documentation, app help, or support pages aligned with the public policy location if those channels direct users to report security issues.
Citations
ETSI EN 303 645 V2.1.1, clause 5.2

Primary ETSI requirement for publishing a vulnerability disclosure policy with reporting contact information and acknowledgement/status-update timelines.

ETSI EN 303 645 vulnerability disclosure requirements for consumer IoT

How should reported vulnerabilities be handled after disclosure?

EN 303 645 provision 5.2-2 says disclosed vulnerabilities should be acted on in a timely manner. The standard explains that timing is incident-specific: software fixes are conventionally completed within 90 days, including patch availability and notification, while hardware fixes can take considerably longer.

That means the evidence should describe the decision path for different vulnerability types rather than using a single generic promise. TS 103 701 expects the test laboratory to assess the action and time frame for each disclosed vulnerability type in IXIT 3-VulnTypes, considering the public disclosure policy, severity, criticality, firmware, hardware or software type, process steps, responsibilities, and third-party involvement.

  • Define how reports are triaged, investigated, confirmed, fixed, mitigated, or escalated for the product and its associated services.
  • Separate timelines where firmware, cloud service, mobile app, hardware, operating system, or third-party library vulnerabilities follow different paths.
  • Document who owns each step, including security incident teams, software teams, supplier contacts, and external vendors where relevant.
  • Avoid claiming a fixed universal remediation deadline unless the evidence supports that timeline for the vulnerability type and deployment route.
Citations
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