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Artifact GuideUKRelevant Connectable Products

UK PSTI Product Security Relevant Connectable Products

A product is relevant when it is internet-connectable or network-connectable and not excepted, then the UK consumer-use and supply facts determine whether the Part 1 duties engage.

Apply connectivity, exceptions, UK consumer-product status and supply-chain role as separate tests.

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Author
Sorena AI
Published
May 9, 2026
Updated
Jul 24, 2026
4 sections8 primary sources
Overview

A is internet-connectable or network-connectable and is not excepted. The separate UK consumer-use, first-supply, and duty-holder facts then determine whether the Part 1 duties engage.

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4 of 4 questions
Question 1

How do you apply the product test?

Start with the physical product. It is a only if it is internet-connectable or network-connectable under section 5 and is not an under section 6 and Schedule 3 of the Regulations.

An can send and receive data over the internet using a protocol in the Internet Protocol suite. A can send and receive data by electrical or electromagnetic transmission, is not itself internet-connectable, and meets one of section 5's two direct-connectability conditions. Those conditions cover an IP-suite connection to an internet-connectable product or specified non-IP connections involving an internet-connectable product and, in one branch, two or more simultaneous product connections. A wired connection can still be direct for this test.

Section 5 also treats some wireless computer-input products as meeting the second condition when they are designed to work with a linking product that connects by a non-IP protocol to an . A wire or cable used only to connect products is disregarded when counting the two simultaneous product connections, but a wire does not stop a connection from being direct.

  • Document every radio, wired interface, protocol, gateway, hub, and direct product-to-product connection.
  • Apply the definitions to the shipped product, not only the feature that marketing calls 'smart'.
  • Then test whether it is an under the current Schedule 3, including the territorial and product-specific conditions.
Question 2

When do the UK consumer supply duties engage?

Relevant product status is only the first step. The manufacturer, importer, and distributor duties use the separate concept in section 54 and actor-specific intention, awareness, or 'ought to be aware' conditions in Chapter 2.

A can qualify when it is first made available to consumers in the United Kingdom. It can also qualify when first made available to non-consumers if products identical to it are or have been made available to UK consumers. Record the actual UK route, intended users, sales material, customer restrictions, and whether identical consumer products exist.

Do not decide the first-supply question from an invoice alone. Section 54 has specific rules for unwanted-product returns, returns made under the PSTI regime, products reconditioned by or for a manufacturer, and certain intermediary supplies. Section 55 also treats gifts, prizes, installation into a building, and some hire or lending arrangements as supply, while excluding transport-only services and scrap sales.

  • Do not treat a business-to-business sale as automatically outside scope.
  • Assess bundles and product families component by component, then record how the complete offering is supplied.
  • Identify each manufacturer, importer, distributor, and authorised representative separately; branding can make a reseller a manufacturer.
Question 3

What should a defensible scope record show?

Keep the product model and configuration, connectivity diagram, intended purpose, instructions and promotional material, consumer-availability evidence, identical-product analysis, Schedule 3 review, UK supply chain, branding, and dated conclusion. State which facts would change the answer.

Reassess after changes to radios, gateways, associated products, branding, intended users, UK distribution, or the exception list. A prior decision for a related model is evidence, not a substitute for the current product test.

Question 4

Questions and answers

What is the PSTI relevant-connectable-product test?

Apply two conditions to the physical product: it must be an or under section 5 of the PSTI Act, and it must not be an under section 6 and the current Schedule 3. Then apply the separate and actor-specific duty triggers.

Is a business-to-business connectable product automatically outside PSTI?

No. Section 54 can treat a product first made available to UK non-consumers as a when identical products meet the consumer route. Record the first qualifying supply, the customer type, and whether identical consumer products exist.

When should a PSTI scope decision be reassessed?

Reassess after changes to connectivity, protocols, gateways, bundled products, intended purpose, branding, UK sales channels, customer restrictions, reconditioning, or Schedule 3. Keep the prior decision and the new facts rather than applying one model's conclusion to a changed product.

Recommended next step

Record the product-scope decision

Document connectivity, exceptions, UK consumer availability, supply history, and each legal entity before assigning duties.

Assessment workflow
Open Assessment Autopilot for UK PSTI Product Security

Build a classification questionnaire for one model and route to market.

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Research workflow
Review UK PSTI Product Security source evidence

Use Research Copilot to answer follow-up questions with cited source material.

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Talk to Sorena
Talk through implementation

Review scope, evidence, owners, and the next compliance actions with Sorena.

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Primary sources

References and citations

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