Mandatory Labeling of Conformity Assessment Information: Guidelines on Exceptions for Space and Design Constraints Released

We provide the following guidance regarding the mandatory display of conformity assessment information (such as the KC Mark) for imported goods.

General Requirements for Conformity Assessment Labeling

In principle, conformity assessment information must be displayed on both the product itself and its packaging. This is a fundamental legal obligation stipulated under relevant regulations, including the Radio Waves Act and the Electrical Appliances and Consumer Products Safety Control Act. These requirements are designed to allow consumers to easily verify safety and quality compliance while enabling regulatory authorities to conduct efficient post-market surveillance.

Exceptions for Physical and Design Constraints

However, exceptions are permitted if it is realistically difficult to mark the information directly on the product or packaging due to specific product characteristics, design elements, or physical space limitations. In such instances, the legal requirement can be satisfied by providing the information clearly and legibly in the user manual or separate accompanying documentation.

Defining 'Practical Difficulty' and Compliance Risks

'Practical difficulty' refers to objective and reasonable constraints rather than mere convenience. This includes situations where the product is extremely small (e.g., miniature electronics, wearable jewelry), the surface material is unsuitable for marking, or where marking would significantly compromise the product's aesthetic integrity. Even when applying this exception, the legal obligation to undergo conformity assessment remains unchanged, and the information must still be explicitly provided in the documentation.

From the perspective of customs clearance and domestic distribution, accurate labeling is critical. Even if the information is provided via a user manual, importers must be prepared to prove compliance to customs authorities by presenting the Conformity Assessment Certificate, test reports, and the manual itself. Failure to comply—either by omitting the assessment or by improper labeling—can lead to clearance delays, shipment returns, disposal orders, administrative fines, or criminal penalties.

Compliance Checklist for Manual-Based Labeling

If you choose to display conformity assessment information in the user manual, please ensure the following:

• Objectively determine if there is a justifiable reason why marking on the product or packaging is impractical.
• Include all mandatory information required by law, such as the KC mark, certification number, model name, manufacturer name, and importer name, in a clear and legible format.
• Always maintain the conformity assessment certificate and test reports to be submitted immediately upon request by authorities.

The most reliable method is to mark the information directly on the product and packaging whenever possible. Relying solely on the user manual is an exceptional measure that should be approached with caution to prevent unnecessary legal or logistical complications.