Is Conformity Assessment Information Mandatory on Products and Packaging? If Difficult Due to Design or Space Constraints, Is It Legally Permissible to Substitute by Listing Only in the User Manual? Released

We are answering your question regarding the display of conformity assessment information.

Conformity assessment information must, in principle, be mandatorily displayed on the product itself and its packaging. This is a basic obligation specified in relevant laws and regulations such as the Radio Waves Act and the Act on the Safety Control of Electrical Appliances and Consumer Products. This is to allow consumers to easily verify whether the product meets safety and quality standards, and for relevant authorities to facilitate post-management.

However, as you are concerned, exceptions are allowed when it is practically difficult to directly display conformity assessment information on the product or packaging due to product characteristics, design elements, or physical space limitations. In such cases, legal requirements can be met by clearly and legibly displaying the relevant information in the user manual or in a separately provided accompanying document.

Here, 'difficult cases' refers not merely to matters of convenience, but to situations with reasonable and objective constraints, such as the product being excessively small, the surface material being unsuitable for marking, or the product design's aesthetics being severely impaired. Examples include small electronic devices, jewelry-type wearable devices, etc. The important point is that even when these exceptional provisions are applied, the obligation to undergo conformity assessment itself remains unchanged, and the information must still be clearly displayed somewhere.

From the perspective of customs clearance and domestic market distribution, the correct display of conformity assessment information is extremely important. Even if the information is displayed in the user manual, the importer must be able to prove it if required by customs authorities. This can be done by presenting the relevant user manual along with the conformity assessment certificate and test report. You should be aware that if a product has not undergone conformity assessment, or if related information is displayed incorrectly and is discovered, it can lead to serious problems such as import clearance being withheld, return or destruction orders, imposition of fines, and even criminal penalties.

Therefore, when choosing to display conformity assessment information in the user manual, it is crucial to thoroughly check the following:

• You must objectively determine whether there are reasonable grounds that genuinely make it 'difficult to display on the product and packaging'.
• All conformity assessment-related information required by law, such as the KC mark, certification number, model name, manufacturer name, and importer name, must be clearly and legibly stated in the user manual without omission.
• Always keep relevant documents, such as the conformity assessment certificate and test report for the product, on hand and be prepared to submit them immediately if required.

The most ideal method is to display conformity assessment information directly on the product and packaging whenever possible, and displaying it solely through the user manual is a matter that should be approached carefully in exceptional circumstances. Please keep in mind that compliance with regulations is the surest way to prevent unnecessary customs delays or the occurrence of legal problems.