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Title: Directions Governing the Inspection Procedure for Paints Ch
Date: 2021.01.29
Legislative: 1.Adopted and promulgated by Ministerial Order No. 10020007420, BSMI, MOEA, on 28 July 2011.
2.All 9 Articles amended and promulgated by Ministerial Order No. 10120003690, BSMI, MOEA, on 20 April 2012.
3.Articles 3, 4, 6 and Table FRP-02 of Appendix 5 amended and promulgated by Ministerial Order No. 10420000680, BSMI, MOEA, on 24 April 2015.
4.All 9 Articles amended and promulgated by Ministerial Order No. 10720000660, BSMI, MOEA, on 19 March 2018.
5.Article 6 amended and promulgated by Ministerial Order No. 11020000180, BSMI, MOEA, on 29 January 2021, and enforced on 1 February 2021.
Content: 1.These Directions are hereby stipulated for implementing the inspection of paints.

2.Inspection Scheme: Type-Approved Batch Inspection or Registration of Product Certification 
(Module II-Type Test + Module IV-Full Quality Management System, Module V-Production Quality 
Management or Module VII-Factory Inspection).

3.Terms used by these Directions are defined as follows:
(1)Paints subject to mandatory inspection include fire-retardant paints for buildings (hereinafter 
referred to as fire-retardant paints), ready mixed paints (synthetic resin type), enamel, emulsion 
paint and solvent-base masonry paints.
(2)Classification: the classification specified in the applicable national standards (CNS).
(3)Same type:
a.Fire-retardant paints: paints of the same classification (specified in CNS 11728), same 
fire-retardant property (Grade II or Grade III incombustibility), coating process, same production 
premise and same country of production.
b.Paints other than fire-retardant paints: paints of the same production premise and same country of 
production.
(4)Main type:
a.Fire-retardant paints: among products of the same type, selection of any products as the main type.
b.Paints other than fire-retardant paints: among products of the same type, selection of any products 
with different national standards and usages (“interior, interior and exterior,” “exterior,” “steel 
structure” and “large-scale steel structure” specified in Table 2 of CNS 601 “Ready mixed paints 
(synthetic resin type),” as well as “interior, interior and exterior” and “exterior” specified in Table 2 
of CNS 606 “Enamel”) as the main type. Emulsion paint is one single type.
(5)Series of type:
a.Fire-retardant paints: among products of the same type, those other than the main type shall be 
regarded as series of type.
b.Paints other than fire-retardant paints: among products of the same type, those other than the main 
type with different national standards and usages (“interior, interior and exterior,” “exterior,” “steel 
structure” and “large-scale steel structure” specified in Table 2 of CNS 601 “Ready mixed paints 
(synthetic resin type),” as well as “interior, interior and exterior” and “exterior” specified in Table 2 
of CNS 606 “Enamel”) as series of type. Emulsion paint is of single type.

4.Inspection standards and inspection items:
(1)Fire-retardant paints: inspection of fire-retardant property, the amount of Volatile Organic 
Compounds (VOCs), content of hazardous heavy metals and marking in accordance with CNS 
11728.
(2)Paints other than fire-retardant paints: inspection of the amount of VOCs, emission of 
formaldehyde, content of hazardous heavy metals and marking in accordance with the applicable 
national standards.
(3)Labelling of “maximum limit of VOCs” and "emission level of formaldehyde" in traditional 
Chinese may be the values specified in national standards or those declared by the business operator 
in compliance with national standards. If the labelled values comply with the limit specified in the 
national standards but do not match the declared values, it shall be regarded as not complying with 
the inspection standards and processed accordingly.
(4)Inspection of labelling of the name of the product, name and address of the obligatory inspection 
applicant in accordance with Article 11 of the Commodity Inspection Act.

5.Relevant requirements for type test:
(1)Application procedures for type-test reports:
a.The applicant shall make applications to the Bureau of Standards, Metrology and Inspection 
(BSMI), Ministry of Economic Affairs, its branches (hereinafter referred to as the inspection 
authority) or BSMI designated testing laboratories by submitting the type classification table of 
paints (Tables FRP-01 and FRP-02), three copies of the following technical documents and samples 
for different main types and series of types of the products.
(a)List of specifications.
(b)Summary of the production process.
(c)Samples of labels in traditional Chinese.
(d)Samples: two containers, each being at least one liter in volume.
b.The unit accepting the applications shall check that the samples match the types or specifications 
stated in the Type Classification Table.
(2)Inspection items: products of each main type and series of type shall be inspected in accordance 
with the preceding Clause.
(3)The type test report may be replaced by a test report under the CNS Mark Certification System of 
which the issuance date shall be within one year of the application for type approval or Registration 
of Product Certification (RPC), under the condition that the name and type of the product are the 
same.
(4)Type-test fees: The fees shall be collected in accordance with the fee schedule of the testing unit 
accepting the applications.

6.Relevant requirements for type approved batch inspection:
(1)Application procedures for type approval: 
a.The applicant shall first obtain a type-test report in accordance with the preceding Clause, and 
apply to the inspection authority for type approval certificates by submitting the application form, 
type-test report and technical documents.
b.Processing time for review type-approval applications: 14 working days after the inspection 
authority accepts the application (not including the time for delivery of documents or samples). 
Where additional samples are drawn for testing, such period shall be extended to another 7 working 
days after the receipt of samples.
c.The terms of validity for a type-approval certificate shall be three years. The certificate holder 
may apply for an extension of the validity period.
(2)Relevant requirements for batch inspection
a.The obligatory inspection applicant shall make the application for inspection to the inspection 
authority having jurisdiction over the port of entry or location of production of the products by 
submitting an application form and a copy of the type-approval certificate before the products are 
imported or released from the factory. The obligatory inspection applicant shall indicate the 
production date or batch number of the product on the application form.
b.Each application for inspection shall contain only products of the same type, which shall be 
treated as one batch. All applications shall be sampled by the inspection authority based on a rate of 
20% to draw samples for inspection. If the sampled batch includes different series of type, the 
inspection authority shall pick each series of type for inspection. Batches not sampled will be 
subject to the procedure of release after document examination to simplify the inspection process, or 
batch-by-batch verification when it is deemed necessary.
c.For products of the same type, if the number of filed batches reaches 20 with no non-compliant 
records, the sampling rate may be reduced to 5% for fire-retardant paints and 10% for paints other 
than fire-retardant paints.
d.Numbers of samples to be taken for inspection: two containers, and each container being at least 
one litre in volume.
e.Sampled items are inspected in accordance with Clause 4.
f.Inspection agency: the BSMI, its Keelung Branch, Taichung Branch and Kaohsiung Branch.
g.The time required for batch-by-batch inspection is 12 working days after the inspection agency 
receives the samples.
h.The test of VOC content of paints shall be done in accordance with CNS 15039-1 “Paints and 
varnishes - Determination of volatile organic compound (VOC) content-Part 1: Difference method.” 
If results do not comply with the requirements and the VOC level is lower than 15%, a final test 
shall be performed at the Kaohsiung Branch of the BSMI in accordance with CNS 15039-2 “Paints 
and varnishes-Determination of volatile organic compound (VOC) content-Part 2: 
Gas-chromatographic method” to confirm whether the products pass the inspection.
i.Sampled products that have failed the inspection shall be subject to the following measures:
(a)The sampling rated of 20% will resume after products of the same type are sampled for 
inspection and comply with the requirements for a consecutive of three batches.
(b)If part or all of the products fail the inspection, the applicant may apply for separating the 
products into different batches. For non-compliant products, the obligatory inspection applicant 
follow the Regulations Governing Disposition of Commodities Failing Inspection to return or 
destroy the products or make a new application for inspection after completing corrective actions 
under surveillance. Products passing the inspection shall be released after they become separated 
batches.
(c)The application of separating batches shall be limited to one time only.
j.The inspection authority shall conduct sampling and inspect the main inspection items upon 
receiving reports or when there is doubt regarding the consistence of the products under application 
for inspection.

7.Relevant requirements for Registration of Product Certification (RPC):
(1)An inspection body (agency) shall examine whether a factory is equipped with the basic testing 
and inspection equipments, such as cone calorimeters and Kar Fischer, when it is conducting factory 
inspection. If the factory is not fully equipped, it shall be deemed as a major nonconformity.
(2)The application for an RPC certificate shall be submitted along with the following documents:
a.Type-test report (application to be made in accordance with Clause 5).
b.A copy of the certificate of quality management system registration or the factory inspection 
report issued by BSMI or certification bodies recognized by the BSMI.
c.The declaration of conformity-to-type.
d.Relevant technical documents.
(3)Time of review: 14 working days after the inspection authority accepts the RPC application (not 
including the time for delivery of additional documents or samples). Where additional samples are 
drawn, the time shall be extended to another 7 days after the receipt of the samples.
(4)The term of validity for an RPC certificate shall be three years. The certificate holder may apply 
for an extension, which is limited to one time only.
(5)The identification number of Commodity Inspection Mark consists of a letter “R” and a 
designated code, which may be printed by the obligatory inspection applicants in accordance with 
relevant regulations.

8.The basic testing and inspection equipment about cone calorimeters mentioned in the preceding 
Clause may be replaced by the following methods:
(1)Development of a comparison module:
a.The production premises shall have regular testing and inspection equipments, such as the 
flame-retardant equipment mentioned in CNS 6532, equipment mentioned in ISO 1182, ASTM-E84, 
UL 723, ISO 1716, EN 13823, ISO 11925-2, ISO 9705, or other equivalent equipment.
b.The control value to be implemented by individual production premise shall be based on the 
results of the comparison between the tests performed by using the regular testing inspection 
equipments and those by CNS 14705-1 testing equipment.
(2)Production control: carrying out tests with the regular testing equipment and using the control 
value developed by the comparison model to control the quality of products.
(3)Tests subcontracted to outside bodies on a regular basis:
a.Certified products are sent to the inspection authority, BSMI designated test laboratories or testing 
laboratories accredited by Taiwan Accreditation Foundation on a regular basis to carry out tests in 
accordance with CNS 14705-1 regarding fire-retardant performance.
b.The test results are used to compare with those performed by the production premises and used as 
the reference for modifying the control value where it is deemed necessary.
c.Frequency of subcontract:
(a)One of each type of RPC registered products manufactured each quarter in the first to third 
quarters shall be subcontracted to outside laboratories to carry out tests in accordance with 
CNS14705-1 every year. In the fourth quarter, each of the RPC registered product manufactured in 
that quarter shall be subcontracted to outside laboratories for tests against the same standard.
(b)Samples of each type of RPC registered products manufactured in the fourth quarter shall be 
submitted to the RPC certification body accepting the application for record and inspection before 
the end of the year.

9.Products which are certified by RPC by following the aforementioned Clause shall be processed 
in accordance with the followings every year:
(1)The test reports issued by outside laboratories shall be regularly sent and samples of each type of 
RPC registered products manufactured in the fourth quarter shall be sent before the end of the year 
to the RPC certification body accepting the application for record and inspection. If this is not done, 
the inspection authority shall conduct border checks or inspection of products before they are 
released from the production premises in accordance with Article 7 of the Regulations Governing 
Registration of Product Certification. Tests of samples that are sent to the inspection body shall be 
completed within one month. If noncompliance is found, the RPC certificate shall be rescinded in 
accordance with Subparagraph 1, Paragraph 1, Article 42 of the Commodity Inspection Act. 
(2)The test reports issued by outside laboratories may be replaced by the test report under the CNS 
Mark Certification System. One CNS Mark test report can be only used to replace the test report 
issued by an outside laboratory for one main type or one series of type.
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