09/11/2026

กฎหมาย PSTI ของสหราชอาณาจักร: กฎข้อบังคับด้านความปลอดภัยสำหรับอุปกรณ์เชื่อมต่อ

 

 

จีน Freight Forwarder

A practical guide for brands, importers and freight teams moving smart products from China to the United Kingdom. Updated for November 2026.

บทนำ

Until recently, the cybersecurity of a smart speaker, a Wi-Fi camera or a connected baby monitor was left largely to the conscience of the company that made it. That era ended in the United Kingdom on 29 April 2024, when the product security regime created by the Product Security and Telecommunications Infrastructure Act 2022, usually shortened to the PSTI Act, became enforceable. Since that date, anyone who makes, imports or distributes consumer connectable products for the UK market has been working under a legal duty to meet a short list of baseline security requirements.

For shippers and freight forwarders, this is not an abstract legal topic. Government figures quoted at launch showed that around 99% of UK adults own at least one smart device and that the average household holds roughly nine connected products. That is a very large volume of consumer electronics, and a big share of it travels in containers and air pallets from factories in Shenzhen, Dongguan and the wider Pearl River Delta. Every one of those shipments has an importer on the UK side who now carries legal responsibility for whether the goods may lawfully be supplied.

This guide explains the PSTI rules in plain language, shows who is responsible for what, and then goes where most legal summaries stop: into the practical logistics of getting compliant connected devices through customs, warehouses and การส่งมอบไมล์สุดท้าย. It also reflects developments through autumn 2026, including the start of mandatory vulnerability reporting under the EU Cyber Resilience Act, which affects many of the same products and the same supply chains.

What the PSTI Act Is and Where It Stands in 2026

The legal structure in brief

The regime has two layers. The first is Part 1 of the Product Security and Telecommunications Infrastructure Act 2022, which gives the government the power to set security requirements for connectable products and creates the duties of manufacturers, importers and distributors. The second is the secondary legislation that sets the technical detail, namely the Product Security and Telecommunications Infrastructure (Security Requirements for Relevant Connectable Products) Regulations 2023, which is SI 2023/1007. Part 2 of the Act deals with telecommunications infrastructure and is outside the scope of this article.

The split matters because the primary Act is durable, while the regulations can be amended and are subject to periodic review. Commentators have noted that the secondary rules must be reviewed at intervals of no more than five years, which gives the government a clear path to tighten or widen the requirements without returning to Parliament for an entirely new statute. The Office for Product Safety and Standards, known as OPSS, is the body that enforces the regime on behalf of the Secretary of State.

What has changed since the regime went live

The core rules have stayed stable since April 2024, but the surrounding picture has moved. OPSS published guidance in 2024 setting out the enforcement tools it can use and the rights businesses have to make representations or appeal. It also confirmed that the statement of compliance that must accompany a product can be supplied in digital form, a point that eased packaging concerns for many brands.

More recently, the Department for Science, Innovation and Technology has published its response to a 2025 call for views on enterprise connected device security. According to the industry body techUK, the government intends to look further at securing enterprise products and will consider whether any future activity should reach beyond the enterprise category. Separately, press reports have described internal UK discussions about wider liability for software and technology companies, with an expansion of the PSTI framework among the options said to be under consideration. None of this changes today’s legal duties, but it signals that the direction of travel is toward more regulation, not less.

Amendments have also been discussed to clarify which products sit outside the regime, for instance certain vehicles that are covered by other legislation. Anyone shipping unusual connected products should therefore check the current list of exclusions on the official GOV.UK guidance page rather than relying on a summary written months earlier.

The Three Baseline Security Requirements

The regulations are deliberately short. Rather than demanding a full security certification, they pick three failures that were behind many of the worst real-world attacks on consumer devices and make avoiding them mandatory. The table below summarises them before we look at each one in turn.

ความต้องการ ความหมายในทางปฏิบัติ What a regulator or buyer may ask to see
รหัสผ่าน No universal default passwords. Each device either has a unique password or forces the user to set one before use. Firmware test results, a description of how passwords are generated or set, and sample units.
การรายงานช่องโหว่ The manufacturer publishes a point of contact so researchers and users can report security flaws, and gives status updates and timelines. A public web page or email address, and an internal process for handling reports.
Update transparency The manufacturer states, in clear language, the minimum period for which the product will receive security updates. The support end date on the product page, the packaging or the statement of compliance.

 

Banning default passwords

The headline rule is the ban on universal default passwords such as admin, 12345 or a factory setting shared by every unit in a production run. Botnets that took down major websites and institutions were built by scanning the internet for devices that still used credentials like these. Under the regulations, passwords must either be unique per product or defined by the user, and they must not be easily guessable or based on publicly available information such as serial numbers in sequence.

For factories this often means a change to the production line rather than just a software tweak. Unique passwords have to be generated, printed on a label or inserted in a quick start guide, and matched to the right unit. Logistics teams see the consequences when a batch is reworked after production, for example when labels need to be reapplied or inserts changed before the goods ship.

A published route for vulnerability reports

The second requirement obliges manufacturers to provide a public point of contact for reports of security issues. The contact must be easy to find, and the manufacturer must tell reporters when they will receive an acknowledgement and status updates. A hidden email address on a legal page is not what the regulator has in mind. Security researchers who find a flaw need a clear, working channel, and the business needs a process behind that channel so reports are triaged and fixed rather than ignored.

Telling customers how long the product will be supported

The third requirement addresses a quieter problem: devices that simply stop receiving patches without any warning. Manufacturers must publish the minimum length of time for which security updates will be provided, and the information must be accessible to consumers before purchase. If a product is sold without an end date, or if the date is buried where a shopper cannot reasonably find it, the supplier risks breaching the rules.

The support period is not a decorative figure. If a manufacturer later shortens the period it has already published, that can be treated as a problem in its own right, and if the period is extended, the new date should be published promptly. Importers and retailers who list the product online need to make sure their own pages show the same information as the manufacturer.

A manufacturer can also be treated as meeting these requirements by complying with the relevant provisions of the European standard ETSI EN 303 645 and with ISO/IEC 29147 for vulnerability disclosure. Many Chinese electronics makers already test to ETSI EN 303 645 for other markets, which makes the UK rules less of a leap than they first appear.

Which Products Are In Scope, and Which Are Not

The regime applies to consumer connectable products, which in simple terms means products that can connect to the internet or to another network and that are made available to UK consumers. That covers a long list: smart televisions, smart speakers, connected cameras and doorbells, alarm systems, baby monitors, wearables, smartphones, game consoles, routers and hubs, and connected household appliances. Products that connect to a computer through a linking device such as a wireless receiver can also be caught.

Some categories are excluded because they are regulated elsewhere or raise different issues. The exclusions are set out in the regulations and in OPSS guidance, and the details can change, so the table gives a general picture only.

Category General position under the PSTI regime
Smart TVs, speakers, cameras, doorbells, baby monitors In scope. Typical examples of the products the regime was designed for.
Smartphones, wearables, game consoles, routers In scope. Network-connected consumer products supplied to UK users.
Connected home appliances (fridges, ovens, vacuum robots) In scope where they can connect to a network, with limited exceptions.
อุปกรณ์การแพทย์ Excluded, as they fall under separate medical device regulation.
Electric vehicle charge points Excluded, because they are covered by their own security rules.
สมาร์ทเมตร Excluded, as they are covered by a separate regulatory framework.
Desktops, laptops and most tablets Generally outside the regime, with some carve-backs such as products designed for children under 14. Check product by product.
Products supplied in Northern Ireland under EU free movement rules Excluded from the UK regime for that supply route.

 

Border cases need real attention. A smart toy aimed at young children, a connected e-bike component or a tablet with a child-friendly case may sit on either side of the line. The sensible approach is to document the reasoning behind every scope decision, so that if OPSS asks why a product was treated as out of scope, the importer can show a considered answer rather than an assumption.

Who Carries the Legal Burden: Manufacturers, Importers and Distributors

A common misunderstanding is that PSTI is the factory’s problem. In reality, the Act spreads duties across the chain, and the weight of those duties shifts depending on where a business sits. In the UK, the practical pressure point is the importer, because the importer is the first UK-based party that puts the product on the market and is the party OPSS can reach most easily.

บทบาท หน้าที่หลัก เอกสารทั่วไป
Manufacturer (including brand owners who have products made under their own name) Comply with the security requirements, produce a statement of compliance, investigate and fix compliance failures, and notify the authority and the rest of the chain where needed. Statement of compliance, test reports, vulnerability policy, support period record.
นำเข้า Check that the manufacturer has complied and that the statement of compliance accompanies the product. Do not supply a product believed to be non-compliant. Notify the authority and others if a problem is found. Copy of the statement of compliance, supplier due diligence file, records of investigations.
ผู้จัดจำหน่าย Check that the product is accompanied by a statement of compliance and the manufacturer and importer details. Do not supply a product believed to be non-compliant. Receiving checks, supplier records, complaint logs.

 

The importer’s position

An importer must do more than simply collect goods at the port. Before supplying a product in the UK, the importer has to be satisfied that the manufacturer has done what the regulations require and that the product comes with the statement of compliance. If the importer knows, or has reason to believe, that a product does not comply, it must not supply it. If a problem emerges after supply, the importer has to notify the enforcement authority and tell other businesses in the chain, and in some cases customers who bought the affected goods.

Importers are also expected to keep records of investigations into non-compliance and to retain them for ten years. That is a long time in a fast-moving sector, and it means document management is part of compliance, not an administrative afterthought. Brands that rely on a third party for importer-of-record services should check carefully who holds those files.

Where a brand outside the UK sells directly to British consumers through a marketplace or its own website, it is typically treated as the manufacturer, and the party that brings the goods into the country takes on the importer’s duties. This is often the weakest point for smaller cross-border sellers, who may not realise that being the named importer of record creates legal duties that go beyond paying ภาษีอากรและภาษีมูลค่าเพิ่ม.

Distributors and marketplace sellers

Distributors, which includes many retailers and resellers, have lighter but real obligations. They must check that the product has the statement of compliance and the right company details, and they must not supply products they believe to be non-compliant. A retailer that stocks goods from several importers should build a simple intake check so that products without documentation are held back before they reach the shelf or the online listing.

Online marketplaces are not a loophole. Sellers who list devices for UK delivery are expected to treat the same requirements as applicable, and a seller who drop-ships from an overseas warehouse still needs to understand which party in the chain is acting as the importer.

The Statement of Compliance: The Document That Travels With the Goods

If there is one document that connects the law to the logistics, it is the statement of compliance. This is the manufacturer’s declaration that it has met the security requirements, or that it has met them by following the recognised standards. It must accompany the product when the product is supplied in the UK. The statement identifies the manufacturer, the product type or batch, and the support period, among other required details, and the regulations set out exactly what it must contain.

OPSS has confirmed that the statement does not have to be printed in every box. A digital version is acceptable, for example a link or a QR code on the packaging that leads to the statement, as long as it is accessible and the product can be matched to it. For a freight forwarder, this changes what a document check looks like. Sometimes the proof is a leaflet in the carton, and sometimes it is a web page that must remain live for as long as the product is on the market.

The practical risk is mismatch. A statement that refers to model A while the goods shipped are model B, or a statement that was written for an earlier firmware version, leaves the importer exposed. Brands that change a component supplier or a firmware build mid-production should update the statement and keep an audit trail of which batches it covers.

Many importers now ask their suppliers to provide the statement of compliance together with the ใบวางบิล and packing list before the goods are booked for shipment. It costs very little to request and it prevents the awkward situation where a container is already at sea when someone notices that the paperwork cannot be produced.

Enforcement, Penalties and Practical Risk

The PSTI regime has real teeth. OPSS can issue a range of notices, and the financial penalties for serious breaches are significant. Penalties of up to £10 million or 4% of qualifying worldwide revenue, whichever is higher, are available, and guidance also refers to additional daily penalties for continuing breaches. In practice, OPSS has said it will take a proportionate approach, and the first step in a less serious case is often a notice requiring the business to put things right. Even so, security experts have pointed out that the value of the law depends on enforcement actually being used, so businesses should not assume the regulator will stay quiet.

Enforcement tool สิ่งที่มันไม่
Compliance notice Requires a business to take specified steps to comply, or to bring a product into compliance within a set time.
Stop notice Requires a business to stop supplying a product, usually while an investigation or remedial work is under way.
Recall notice Requires a business to recall products that have already been supplied, and may require the business to notify customers.
ริบ Allows the authority to seek forfeiture of non-compliant products.
สิ่งพิมพ์ Allows the authority to publish details of compliance failures and the enforcement action taken, which carries a reputational cost.
การลงโทษทางการเงิน Fines of up to £10 million or 4% of qualifying worldwide revenue, whichever is higher, for serious breaches.

 

For a business that imports connected devices, the most disruptive outcome is often not the fine itself but a stop notice or recall. A stop notice can freeze a whole season’s inventory, and a recall means paying to reverse the entire logistics chain. When a pallet of stock cannot be sold, storage charges accumulate and cash is trapped in goods that are physically present but legally unsellable.

Public naming is another risk that is easy to underestimate. A published enforcement action tells retailers, marketplaces and consumers that a brand failed a basic security test, and those retail partners may respond faster than the regulator by delisting the product.

What PSTI Means for Freight Forwarding and Cross-Border Logistics

Why forwarders should care

A freight forwarder does not certify product security, and no forwarder should claim to. Even so, the way goods are documented, labelled, stored and delivered affects whether an importer can show that its obligations were met. Forwarders sit at the point where documents, physical goods and timelines meet, so they are often the first to spot a missing statement, a wrong label or a mismatch between an invoice and a product description.

There is a commercial angle as well. Importers increasingly favour logistics partners who understand the regulatory layer around electronics, because a delay caused by a documentation problem costs far more than a slightly higher freight rate.

Pre-shipment checks that save money later

The cheapest time to fix a compliance problem is before the cartons are sealed. Pre-shipment checks for connected devices should include a sample inspection of whether the correct password label or setup instruction is present, whether the packaging carries the support period or a link to it, and whether the statement of compliance or its QR code is present and readable. A pallet of 5,000 smart cameras with the wrong insert is an expensive thing to find in a UK warehouse.

It also helps to confirm that firmware on the production units matches the firmware named in the compliance documents. If the factory has pushed a later build, the importer should know about it. Spot checks do not replace the manufacturer’s own testing, but they reduce the chance that an obvious error reaches the port.

Where a problem is found in China, rework is far cheaper than it is after the goods land. Relabelling, replacing inserts or repacking can be arranged at the factory or at a consolidation warehouse before the cargo is released to the carrier.

เอกสารและพิธีการศุลกากร

PSTI compliance is not a customs declaration, and customs officers do not typically ask for a statement of compliance as part of a routine entry. Even so, the importer of record carries the legal duty, and a clearance broker works from the information provided. Accurate product descriptions, correct commodity codes and consistent model numbers across the commercial invoice, packing list and compliance documents all make it easier to defend the shipment if questions are raised later. Connected devices usually fall under Chapter 85 of the tariff, but the exact code depends on the function of the product, so classification should be reviewed rather than copied from a previous shipment.

Importers should also remember that the UK import process involves a UK EORI number, import VAT and duty calculations, and that the declaring party must be able to answer questions from HMRC or Border Force. The PSTI file is a separate but related set of records, and it makes sense to keep both together.

The table below sets out a simple document checklist by stage of the journey. It is a working guide, not legal advice, and the importer should adapt it to its own product range.

ระยะ เอกสารหรือเช็ค ทำไมมันถึงมีความสำคัญ
ก่อนการจอง Statement of compliance, model and firmware confirmation, support period text, vulnerability contact URL Confirms the product can lawfully be supplied before money is committed to freight.
ก่อนการส่งมอบ Sample inspection of labels, inserts, QR codes and passwords; photos of cartons and pallets Catches physical packaging errors while they are cheap to fix.
Export and transit Commercial invoice, packing list, bill of lading or air waybill, dangerous goods declaration for batteries Keeps descriptions consistent and avoids carrier refusals.
UK clearance Import declaration, commodity code review, EORI, duty and VAT records Supports the importer’s position if questions arise from HMRC or Border Force.
คลังสินค้าในสหราชอาณาจักร Goods-in check against the PSTI file; quarantine for any unmatched batches Prevents non-compliant stock from reaching customers.
ไมล์สุดท้าย Order and batch traceability, returns handling, recall readiness Makes any recall faster and cheaper.

 

Ocean, air and the battery question

Almost every connected consumer device contains a lithium battery, or is shipped with one, and that has a direct effect on how the goods can move. Batteries packed with or contained in equipment are subject to dangerous goods rules, particularly in air freight, and carriers will refuse cargo that is declared incorrectly. A smart doorbell or a wearable that is fine from a security point of view can still be rejected at the airline desk if the battery paperwork is wrong.

The choice between full container load, less-than-container load and air freight should be made with both cost and compliance in mind. The comparison below gives indicative timings and uses, based on typical market experience, and actual transit times change with carrier schedules and routings.

โหมด Indicative China to UK time เหมาะสำหรับ Compliance angle
มหาสมุทรเอฟซีแอล Around 30 to 45 days port to port, longer when carriers divert Large, regular volumes of one product line Single batch is easy to trace; relabelling after arrival requires a UK warehouse.
มหาสมุทร LCL Similar to FCL plus consolidation time at origin and destination Smaller shipments or mixed SKUs Mixed cargo needs careful documents so that each product matches its own statement.
ขนส่งสินค้าทางอากาศ Roughly 3 to 7 days airport to airport, plus handling High-value, urgent or launch-critical stock Battery declarations and packaging rules are strict.

 

UK warehousing and last-mile delivery

Once the goods arrive in the UK, the warehouse becomes the importer’s control point. A goods-in check that matches the batch to the PSTI file, with the right to quarantine anything that does not match, is one of the strongest defences against supplying a non-compliant product. It also gives the importer a place to add or correct inserts, replace stickers and update the packaging text if the support period or contact details change.

Batch-level traceability is the other benefit. If a vulnerability is found in a particular firmware build, the importer needs to know which cartons, which pallets and ultimately which customers received it. A warehouse management system that records batch or lot numbers turns what could be a chaotic recall into a targeted one.

Last-mile delivery and returns matter too. Returned devices should be reset and checked before resale, since a unit that was set up by one customer may carry personal data or changed credentials. That is a data protection concern as much as a PSTI issue, but the two are closely linked in practice.

Aligning UK PSTI With the EU Cyber Resilience Act

Many brands sell into both the UK and the European Union, and the two regimes are often discussed together. The EU Cyber Resilience Act, Regulation (EU) 2024/2847, entered into force in December 2024. Its manufacturer reporting duties under Article 14 started to apply on 11 September 2026, and the majority of its other obligations apply from 11 December 2027. That means that, as of November 2026, EU reporting is already live while most of the product design obligations are still to come.

Under the reporting rules, a manufacturer that discovers an actively exploited vulnerability, or a severe incident affecting the security of a product with digital elements, must send an early warning within 24 hours and a more detailed notification within 72 hours. Reports go through a single reporting platform operated with ENISA, the EU cybersecurity agency. Commentators have noted that the platform went live alongside the deadline, and that enforcement is likely to build gradually as regulators gain experience.

กระทู้ UK PSTI regime พระราชบัญญัติความยืดหยุ่นทางไซเบอร์ของสหภาพยุโรป
สถานะ In force since 29 April 2024 Reporting duties since 11 September 2026; main obligations from 11 December 2027
ขอบเขต Consumer connectable products Broad range of products with digital elements, consumer and business
โฟกัสหลัก Default passwords, vulnerability contact, support period transparency Security by design, vulnerability handling, conformity assessment, reporting, CE marking
การรายงานเหตุการณ์ Notify the authority of compliance failures 24-hour early warning and 72-hour notification for exploited vulnerabilities and severe incidents
เครื่องควบคุม Office for Product Safety and Standards National market surveillance authorities, with ENISA coordinating reporting
โทษปรับสูงสุด Up to £10 million or 4% of qualifying worldwide revenue Up to 15 million euros or 2.5% of worldwide turnover for the most serious breaches

 

The overlap is practical. A manufacturer that builds a working vulnerability management process for the EU will find the UK contact and update requirements easy to meet, and a product designed to ETSI EN 303 645 gives a head start on both. The sensible approach for brands selling in both markets is a single security file per product, with separate sections that show how each regime is satisfied, and one process for reporting issues to the right authority.

For logistics teams, a split warehouse model is common, with one stock pool for the UK and another for the EU. Keeping the paperwork and packaging for each pool distinct avoids the mistake of shipping a UK-labelled unit to a Dublin customer or the reverse.

How Topway Shipping Supports Compliant Connected-Device Shipments

ตั้งแต่ 2010, ท็อปเวย์ ชิปปิ้ง, headquartered in Shenzhen, China, has been a professional provider of cross-border e-commerce logistics solutions. The founding team has more than 15 years of experience in international logistics and customs clearance, with a strong focus on China to U.S. transportation, and that depth of experience carries over to other trade lanes where electronics are moving under tighter rules.

Topway Shipping’s services cover the whole logistics chain, including first-leg transportation, overseas warehousing, customs clearance and last-mile delivery. For a brand shipping smart devices from China to the UK, that means one logistics partner can handle the pickup from the factory, the booking of the sea or air leg, the clearance work and the final delivery, while keeping the documents for each stage consistent. Fewer handovers means fewer chances for a statement of compliance or a product description to go missing along the way.

The company also offers flexible full-container-load and less-than-container-load ocean freight from China to major ports worldwide. Brands with steady volumes can fill containers on a regular schedule, while newer sellers testing a connected product can start with LCL consolidation and move to FCL as demand grows. Overseas warehousing gives importers a controlled location to check goods against their compliance files, add or correct inserts, and release stock only when the paperwork is in order.

It is worth being clear about boundaries. Topway Shipping is a logistics provider and not a security certification body, and the legal duties under the PSTI Act remain with the manufacturer and the importer. What a capable forwarder can do is make those duties easier to meet by keeping documentation tidy, flagging inconsistencies early and giving the importer reliable records of what moved, when and in which batch. Importers should discuss their specific product range and document requirements with Topway Shipping before the first booking.

A Practical Compliance Roadmap for the Next 90 Days

For a business that already ships connected products to the UK, the first step is an inventory. List every connected SKU, its firmware version, its importer of record and the location of its statement of compliance. Industry advisers have pointed out that without this inventory neither reporting nor patching is possible, and the same is true of PSTI file-keeping.

The second step is to test the three requirements against real units, not just documents. Take a sample from stock, reset it, and check that it has no universal default password, that the vulnerability contact is live and that the support period is visible to a buyer. Any product that fails should be put on hold until the problem is understood.

The third step is to put the documents into the logistics routine. Ask suppliers to send the statement of compliance with the commercial invoice, add a PSTI line to the pre-shipment inspection checklist, and ask the warehouse to record batch numbers at goods-in. Finally, agree an internal route for handling a vulnerability report or recall so that the people involved know who decides, who notifies the authority and who contacts customers.

สรุป

The PSTI Act turned connected-device security from a voluntary good practice into a legal duty for everyone in the UK supply chain. Its three baseline requirements are simple to describe, but the way they are proved, documented and maintained touches product design, packaging, customs paperwork, warehousing and customer service. In November 2026, with EU reporting already live and the UK government studying wider measures, the cost of treating compliance as an afterthought is rising.

For importers and brands, the best results come from joining legal compliance to logistics execution: documents checked before booking, goods inspected before shipment, batches traced in the warehouse and a recall plan ready before it is needed. Working with an experienced partner such as Topway Shipping, which supports the full chain from first-leg transport to last-mile delivery, helps keep that process consistent from the factory gate to the customer’s door.

คำถามที่พบบ่อย

Q: Does the PSTI Act apply to products made in China and sold only through online marketplaces?

A: Yes. The rules apply to consumer connectable products made available to UK customers, whatever the sales channel. The seller needs to identify which party is acting as manufacturer and which as importer.

Q: Who has to provide the statement of compliance?

A: The manufacturer must produce it, and it must accompany the product when supplied in the UK. Importers and distributors must check that it is there. OPSS has accepted that it can be provided digitally.

Q: What are the maximum penalties for non-compliance?

A: Serious breaches can lead to fines of up to £10 million or 4% of qualifying worldwide revenue, whichever is higher. OPSS can also issue compliance, stop and recall notices and publish details of enforcement action.

Q: Do customs authorities check PSTI compliance at the border?

A: Customs entries do not usually include a PSTI check as such, but OPSS enforces the regime and importers remain legally responsible. Accurate documentation helps defend a shipment if questions arise later.

Q: Can Topway Shipping certify that my device meets the PSTI requirements?

A: No. Topway Shipping provides logistics services, including first-leg transport, overseas warehousing, customs clearance, last-mile delivery and FCL and LCL ocean freight. Certification and legal compliance remain with the manufacturer and importer, but Topway Shipping can help keep the shipment and its paperwork organised.

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