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Title: Directions Governing the Inspection of Paints Ch
Date: 2018.03.19
Legislative: 1.Adopted and promulgated by the Bureau of Standards, Metrology and Inspection, Ministry of Economic Affairs on 28  July, 2011.
2.Amended and promulgated by the Bureau of Standards, Metrology and Inspection, Ministry of Economic Affairs on 20  April, 2012.
3.Amended Articles 3, 4, 6 and appendix 5 FRP-02 promulgated by the Bureau of Standards, Metrology and Inspection, Ministry of Economic Affairs on 24  April, 2015.
4.Amended and promulgated by the Bureau of Standards, Metrology and Inspection, Ministry of Economic Affairs on 19 March, 2018.
Content:

1.This Directions is stipulated for the purpose of paints commodity inspections.

2.The inspection of paints commodities adopts a type-approved batch inspection or registration of
product certification【Type-Test Module (Module II) and Full Quality Management System Module
(Module IV) or Production Quality Management Module (Module V) or Factory Inspection Module
(Module VII)】.

3.The terms used by these Directions are defined as follows:
(1)Products of paints commodities include fire-retardant paints for buildings (hereinafter referred
to as fire-retardant paints), ready mixed paint (synthetic resin type), enamel, emulsion paint and
solvent-base masonry paint for buildings.
(2)Type: in accordance with the type specified in the applicable National Standards (CNS).
(3)Same type:
a.Fire-retardant paint: refers to products produced by the same type (in accordance with the type
specified in CNS 11728), same fire-retardant property (Grade II or grade III incombusbility), same
coating process, same factory, and same country.
b.Ready mixed paint (synthetic resin type), enamel, emulsion paint and solvent-base masonry paint
for buildings: refers to products produced by the same factory, and same country.
(4)Main type:
a.Fire-retardant paint: refers to products selected as the main type among products from the same
type.
b.Ready mixed paint (synthetic resin type), enamel, emulsion paint and solvent-base masonry paint
for buildings: refers to products selected as the main type among different applicable National
Standards(CNS) and uses (in accordance with the " interior, interior and exterior ", " exterior ",
" steel structures " and " large-scale steel structure " specified in CNS 601 table 2, and
" interior, interior and exterior " and " exterior " specified in CNS 606 table 2) from the same
type, emulsion paint is a single type.
(5)Series of type:
a.Fire-retardant paint: refers to other products of the same type.
b.Ready mixed paint (synthetic resin type), enamel, emulsion paint and solvent-base masonry paint
for buildings: refers to other products selected as the main type among different applicable
National Standards(CNS) and uses(in accordance with the  " interior, interior and exterior ",
" exterior ", " steel structures " and " large-scale steel structure " specified in CNS 601 table 2,
and " interior, interior and exterior " and " exterior " specified in CNS 606 table 2) from the
same type, emulsion paint is a single type.

4.Inspection standard and inspection items:
(1)Fire-retardant paint: Commodity's fire-retardant property, amounts of Volatile Organic
Compounds(VOCs), hazardous heavy metals content, and marking shall be rectified in accordance
with CNS 11728.
(2)Ready mixed paint (synthetic resin type), enamel, emulsion paint and solvent-base masonry paint
for buildings: Commodity's amounts of Volatile Organic Compounds (VOCs), emission of formaldehyde(the
emission does not exist in National Standards(CNS) exempt from inspection), hazardous heavy metals
content, and marking shall be rectified in accordance with applicable National Standards(CNS).
(3)Chinese labels for "Maximum volatile organic compound(VOC) content limit value " and " emission
of formaldehyde " may be the value set by National Standards(CNS) or the content limit value of VOC
and emission of formaldehyde self-proclaimed by businesses in compliance with National Standards(CNS).
If the labelling value meeting the inspection requirements with National Standards(CNS) are found not
to comply with self-proclaimed, they shall be handled in accordance with labels are not in conformity
with the inspection standards.
(4)Commodity's name, obligatory inspection of the applicant's name and address shall be rectified in
accordance with Article 11 of the Commodity Inspection Act.

5.The relevant regulations for type test:
(1)Application procedures for type-test report:
a.The type-test applicant shall submit the type classification table of paints (Table FRP-01,
Table FRP-02), three copies of the following technical documents and samples according to different
main types and the series of type to the Bureau of Standards, Metrology and Inspection, Ministry of
Economic Affairs (hereinafter referred to as BSMI), its branches (hereinafter referred to as
inspection authority) or designated testing laboratories recognized by the BSMI.
(a)Specification cross-reference table.
(b)Outline of manufacturing process.
(c)Specimen of Chinese label.
(d)Samples: two containers, each container shall be at least one liter in volume.
b.Inspectors shall check whether the sample submitted has the same code number or specification as
that specified in the type classification table.
(2)Inspection items: commodities of every main type and type of series shall be inspected in accordance
with the aforementioned Article.
(3)A CNS Mark test report with the issue date that is within one year before the application for type
approval or registration of product certification may supersede the type-test report with the same
commodity's name and code number.
(4)Type-test fees: shall be collected in accordance with the fee charging standards from the inspectors.

6.The relevant regulations for type approved batch-to-batch inspection:
(1)Application procedures for type approval:
a.technical documents to the inspection authority for the application for type approval  in order to
obtain a type-approved certificate.
b.Terms for type-approval inspection: 14 working days after the inspection authority has granted the
application of type approval (excluding the waiting time for re-submitted documents or samples). For
those containing random testing samples, the term is 7 working days after the arrival of the samples.
c.The terms of validity for a type-approved certificate shall be three years. The certificate holder
may then apply for an extension.
(2)The relevant regulations for batch-to-batch inspection
a.Before the commodities are imported to or sold in Taiwan, the obligatory inspection applicant shall
submit an application form and a copy of the type-approved certificate to the inspection authority
within the jurisdiction of the port where the commodities arrive or the location where the commodities
are manufactured to apply for inspection and issuance of the commodity inspection mark C imprinted by
the BSMI.
b.During the application process, the obligatory inspection applicant shall ensure that commodities
with the “same type” that are in the same batch. The inspection authority may conduct a
random-selected batch inspection with a 20% probability. If the selected batch includes different
series of type, the inspection authority may conduct inspection for every series of type. Unless
otherwise deemed necessary for inspection by the inspection authority, those that are not sampled
shall be released after document examination to simplify the inspection procedure, if necessary, they
may then be subject to batch examination.
c.For commodities of the same type, if the number of filed inspections reaches 20 batches and no
unapproved records have been found, they may then be subject to random-selected batch inspection
with a 10% probability.
d.Numbers of samples for sampling inspection: two containers, and each container shall be at least
one litre in volume.
e.Sampling inspection items are inspected in accordance with Article 4.
f.Inspection agency: Keelung Branch, Taichung Branch, Kaohsiung Branch and the Sixth Division of
the BSMI.
g.The term for batch-to-batch sampling inspection is 12 working days after sampling.
h.In principle, the VOC content inspection for paints shall be rectified in accordance with CNS 15039-1
「Paints and varnishes - Determination of volatile organic compound (VOC) content - Part 1: Difference
method」. If the commodities fail the inspection and the amounts of VOC are lower than 15%`, they shall
be sent to 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 or not such commodities pass the inspection.
i.Commodities that have failed the inspection shall be further inspected as follows:
(a)Commodities of the same type may resume sampling with a 20% probability after they pass three
consecutive sampling inspections.
(b)If part or all of the commodities fail the inspection, the applicant can depart the commodities. The
applicant shall return the shipment, destroy the commodities or apply to the inspection authority for a
new inspection application by submitting an improvement plan in accordance with the Regulations
Governing Disposition of Commodities Failing Inspection. After the applicant removes the commodities that
have passed the inspection, they can be released.
(c)The application of departing the commodities 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.The relevant regulations for the registration of product certification:
(1)An inspection authority (unit) shall examine whether a factory equips the basic inspection and testing
equipments which include 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 defect.
(2)The application for the issue of the registration of product certification shall be submitted along
with the following documents:
a.Type -test report (shall be applied in accordance with Article 5).
b.The copy of a certificate for the 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)Terms for Registration of Product Certification: 14 working days after the inspection authority has
granted the application of registration of product certification (excluding the waiting time for
re-submitted documents or samples). For those which contain random testing samples, the term is 7
working days after the arrival of samples.
(4)The term of validity for Registration of Product Certification certificate shall be three years. The
certificate holder may apply for an extension which is limited to one time only.
(5)The commodity inspection mark R and a designated code may be printed by obligatory inspection
applicants themselves in accordance with regulations.

8.The basic inspection and testing equipments about cone calorimeters mentioned in the preceding
article may be replaced by the following methods:
(1)Establish a comparison module:
a.Manufacturers shall have regular inspection and testing equipments based on the test equipment subject
to CNS 6532, ISO 1182, ASTM-E84, UL 723, ISO 1716, EN 13823, ISO 11925-2, ISO 9705 or other equipment
with the same level.
b.Compare the test results conducted by regular inspection and testing equipments with those conducted
by CNS 14705-1 test equipment, and stipulate the cut-off value of each manufacturer.
(2)Production control: conduct inspections by using regular inspection equipment and the cut-off value
stipulated by a comparison module to control product quality.
(3)Regular entrusted inspection:
a.Submit certified products to inspection authority, designated test laboratories approved by BSMI or
Taiwan Accreditation Foundation to conduct inspection of fire-retardant property in accordance with
CNS 14705-1.
b.Compare the result with test value of a manufacturer to form the basis for modifying the cut-off value.
c.Frequency of entrusting:
(a)Any product of every registered type products manufactured in the quarter shall be submitted to
entrusted authorities or laboratories for tests in accordance with CNS14705-1 during Q1 to Q3 every
year. In Q4, every registered product manufactured in that quarter shall be submitted to entrusted
authorities or laboratories for tests in accordance with CNS14705-1.
(b)Every registered product manufactured in Q4 shall be submitted to original inspection authority
by the end of a year.

9.Products which obtain the registration of product certification in accordance with the aforementioned
article shall be processed in accordance with the following regulations every year:
(1)Entrusted inspection reports and samples of every registered type manufactured in Q4 of the year
shall be submitted regularly to the original registered authority for reference and examination. Products
which are not submitted to the inspection authority shall conduct border checks or checks before releasing
from the production premises in accordance with Article 7 of the Regulations Governing Registration of
Product Certification. The sampling inspection authority shall finish inspection within one month. If the
product does not conform to the inspection standards, its registration of product certification shall
be rescinded in accordance with Article 42 Clause 1 of the Commodity Inspection Act.
(2)A CNS mark test report may supersede an entrusted inspection report mentioned in the preceding
clause. One CNS mark test report can only replace an entrusted inspection report of one main type or one
type of series.