Need a broader understanding of when two products are "identical". E.g., a 42" and 55" smart TV may be identical except for display size. They should not require separate certification.
§ 8.205 Cybersecurity labeling authorization.
...
(b) Cybersecurity labeling authorization attaches to all units of the complying Consumer IoT Product subsequently marketed by the grantee that are identical (see § 8.206) to the sample determined to comply with the program requirements except for permissive changes or other variations authorized by the Commission.
§ 8.206 Identical defined.
As used in this subpart, the term identical means identical within the variation that can be expected to arise as a result of quantity production techniques.
"...other variations authorized by the Commission" is a possible opening to clean this up during the 90-Day. If the recommendation for a clean "identical" comes out of the 90-Day and approved by PSHSB, it would seem to fix the problem.
Need a broader understanding of when two products are "identical". E.g., a 42" and 55" smart TV may be identical except for display size. They should not require separate certification.
§ 8.205 Cybersecurity labeling authorization. ...
(b) Cybersecurity labeling authorization attaches to all units of the complying Consumer IoT Product subsequently marketed by the grantee that are identical (see § 8.206) to the sample determined to comply with the program requirements except for permissive changes or other variations authorized by the Commission.
§ 8.206 Identical defined. As used in this subpart, the term identical means identical within the variation that can be expected to arise as a result of quantity production techniques.
"...other variations authorized by the Commission" is a possible opening to clean this up during the 90-Day. If the recommendation for a clean "identical" comes out of the 90-Day and approved by PSHSB, it would seem to fix the problem.
Need text on the clarification of "identical".