Artifact GuideUKRelevant Connectable Products Scope

UK PSTI Product Security Relevant Connectable Products Scope

Understand which connected product categories can enter UK PSTI scope, how the statutory tests work, and why examples never replace the current exception schedule.

Binding duties come from Part 1 of the 2022 Act and the current 2023 Regulations. OPSS guidance explains administration and enforcement; ETSI materials are standards evidence, not a substitute for applying the UK rules.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 24, 2026
Sections
4

Structured answer sets in this page tree.

Primary sources
7

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 24, 2026
Overview

UK PSTI uses a capability test, not a closed list of smart-device names. A can include a connected camera, speaker, television, router, toy, wearable, appliance, alarm, lock, hub, or smartphone, but the regime applies only if the model satisfies the Act's definitions, is not excepted, and meets the separate and actor conditions. The regime has applied since 29 April 2024.

Section 1

Internet-connectable and network-connectable categories

Internet-connectable products can send and receive data over the internet using an Internet Protocol suite protocol. Network-connectable products are not internet-connectable but can send and receive data and meet one of section 5's direct-connectability tests. Bluetooth, Zigbee, or another radio label alone does not answer the test.

Associated apps, cloud services, and software can fall within particular Schedule 1 requirements when they are used for the manufacturer's intended purpose. That does not make every service a separate ; start with the physical product definition and then apply each security requirement's software scope.

  • Consumer IoT examples include smart cameras, TVs, speakers, toys, baby monitors, locks, smoke alarms, hubs, appliances, fitness trackers, and phones.
  • Products with only one-way communication may not meet the sending-and-receiving element.
  • Non-IP products require the specific simultaneous and direct-connectability conditions in section 5.
  • Classify each model and intended purpose; do not decide from a marketing category alone.
Section 2

Current excepted product categories

Schedule 3 currently excepts specified products supplied in Northern Ireland under listed Windsor Framework legislation, smart charge points, qualifying medical devices, smart meter products, certain desktop, laptop and tablet computers without cellular connectivity, and specified vehicles in Great Britain. The vehicle exceptions took effect on 25 February 2025.

The conditions matter. The non-cellular computer exception does not cover a computer designed exclusively for children under 14. A product used in healthcare is not necessarily a medical device, and a vehicle component is not necessarily within a vehicle exception.

  • Match the product to the legal definition cited by the exception.
  • Confirm geography where an exception is limited to supply in Northern Ireland.
  • Record cellular capability and the manufacturer's intended purpose for computers and tablets.
  • Use the consolidated Schedule 3 plus the 2025 amendment when checking vehicles.
Section 3

Consumer, business, refurbished, and bundled products

The regime is aimed at product lines made available to UK consumers, but section 54 can also capture a unit first supplied to a non-consumer when identical products meet the consumer condition. A 'business sale' label is therefore not decisive.

Section 54 turns on whether a relevant person supplied the unit to any earlier customer, not merely whether someone used it. Its return, reconditioning, and installation-contract rules can change that result, so second-hand, returned, refurbished, and installed products need a fact-specific analysis. Bundles also require care: supplying a connected product for no separate charge, or incorporating it in a building under a construction contract, can still be supply under section 55.

  • Check identical consumer variants before treating a B2B order as outside scope.
  • Record earlier supplies, returns, reconditioning, refurbishment, and installation facts before applying section 54.
  • List each connected item in a bundle and the entity supplying it.
  • Do not assume a free accessory or installed product falls outside the definition of supply.
Section 4

Role consequences after category classification

Manufacturers, importers, and distributors have different but overlapping obligations. Own-brand and white-label sellers can be manufacturers. The current Schedule 1 password, reporting, and support-period requirements apply to manufacturers. Importers and distributors have direct statement duties and must not supply in the circumstances set out in the Act when they know or believe there is a manufacturer's compliance failure.

Complete category classification first, then apply the section 54 and actor-awareness tests. Record the result per legal entity, product line, and route to market.

  • Identify the brand owner, original manufacturer, UK importer, distributors, and any authorised representative.
  • Assign the three security requirements and technical evidence to each actor that must comply.
  • Verify the statement or current deemed-compliance route before supply.
  • Reopen the classification after a new model, radio, intended purpose, sales channel, or amendment.
Primary sources

References and citations

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