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Progress made on 26 issues from the 2021 Position Papers

The ECCT made progress on 26 of the issues raised in its 2021 Position Papers. The announcement was made by ECCT Chairman Henry Chang during his presentation at the launch of the chamber's new 2022 Position Papers. As of the cut-off date for compiling papers (1 October 2021), since the publication of the 2021 Position Papers (in November 2020), the following progress has been made:

  • Seven issues have been successfully resolved.
  • Sufficient progress has been made in 3 issues and they have therefore not been raised again.
  • 16 issues have been partially but not completely resolved and are therefore listed again this year.
  • 32 issues have been removed at the committees' discretion.
  • 102 other issues from last year remain unresolved and are repeated.
  • 52 new issues have been raised.

Issues resolved since the publication of the 2021 Position Papers



  • Additional options to post audited financial statements: The Financial Supervisory Commission (FSC) has allowed foreign bank branches to post links to their audited financial statements on the websites of the Bankers Association of Taipei as an alternative digital option.
  • Ensuring regulatory consistency with regard to client classification: 1) The Agricultural Bank of Taiwan and post offices that handle deposits and remittances have been included in the scope of investors in "Regulations Governing Issuance of New Taiwan Dollar (NT$) Bank Debentures by Foreign Bank Branches", and 2) The Securities and Futures Bureau (SFB) issued a new ruling to enable post offices that handle deposits and remittances to invest in foreign bonds provided by the bond agency platform.

Electrical Engineering & Equipment

  • Energy storage systems: Taiwan Power Company (Taipower) has announced an aggressive plan for the expansion of its energy storage capacity to 590 megawatts (MW) by 2025. The industry is currently working with Taipower on relevant initiatives.


  • Public transport and commercial mobility - Euro VI emission standards: On 15 June, the Environmental Protection Administration (EPA) officially announced that Euro VI emission standards for diesel commercial vehicles would be implemented as planned on 1 September 2021.
  • Individual mobility - Government vehicle tender specifications for NEVs: On 16 April, the Directorate-General of Budget, Accounting and Statistics announced “2022 Budget Standards for Common Expenditures”, which updated the category of EV fleets from “5-seater” to “passenger car” (without passenger capacity limitation), thereby giving government entities flexibility to choose either four or five-seater EVs.
  • Regulatory issues - Trading platform for Corporate Average Fuel Economy Standards: On 28 April, the Bureau of Energy (BOE) introduced a “CAFE Information Exchange Platform” (耗能總量額 度資訊交流平台), via which OEMs can voluntarily disclose information on credits available or needed for trading.


  • Streamlining the zero percent VAT filing process and the E-GUI system: The Ministry of Finance (MOF) has simplified the zero percent VAT filing process to align with the Electronic Government Uniform Invoice (E-GUI) system, and thereby eliminated the cumbersome paperwork for business entities.

Issues where sufficient progress has been made since the publication of the 2021 Position Papers

Healthcare Enhancement

  • Fertility and childcare - Expansion of the new-born screening programme: Under Article 48-2 of the Pharmaceutical Affairs Act, the Taiwan Food and Drug Administration (FDA) has issued announcement No.10814106030 that allows for fast-track approval of paediatric medicines for urgent needs.

Medical Device

  • Regulatory approval issues - Medical system importation and registration: The Food & Drug Administration (FDA) now allows importers of equipment components and accessories for repairs and replacement parts to apply for special import permits on a case-by-case basis.
  • Reimbursement issues - Flexibility in the definition of function improvement categories: The National Health Insurance Administration (NHIA) has established subcategories for more products.

Partially resolved 2021 Position Paper issues


  • Relaxation of guidelines on outsourcing IT systems: The FSC accepted the committee's recommendation to relax Taiwan's outsourcing guidelines Q&A. However, Taiwan maintains overly strict restrictions on outsourcing IT systems.


  • Regulatory clarity and implementation - Advertising regulatory clarity and implementation: Consensus has been reached between the FDA and industry that supporting data for advertising claims may refer to “Guideline of Preparing Cosmetics Product Information File” and will not be limited to specific tests on final products. However, there are inconsistent interpretations and implementation of the new advertising guidelines among FDA officials and local departments of health.
  • Regulatory clarity and implementation - Parallel work of notification and pre-market registration: The FDA launched its online notification system on 1 July 2021, enabling new registrations and changes to existing notifications. However, problems with the new system include insufficient notice about updates, lack of flexibility in payment methods and excessive fees for minor changes.


Electrical Engineering & Equipment

  • Upgrading Taiwan's switchgear industry: A draft amendment of the “MOEA Accreditation of Inspection Institutes and OEM Factories and Guidelines on Inspecting High-Voltage Electrical Facilities” shared with industry in September 2021 included a statement that the "old standard dual-track system (CNS3990 & 3991) will not be qualifiable for type test review applications". However, an official announcement of the amendment is pending and there are no sunset clauses for phasing out the old standard.
  • Healthcare Enhancement   Healthy demographic development – Fertility: The Ministry of Health and Welfare's (MOHW) Health Promotion Administration (HPA) has expanded In Vitro Fertilization (IVF) subsidies to support IVF treatment for women under the age of 45. However, more could be done to promote reproductive health, childbearing, and child-rearing.


  • Creating a friendly business environment for life insurance development: The FSC increased the exclusion limit from 35% to 40% of various reserves for non-investment-linked life insurance business by revising article 15-2 of Regulations Governing Foreign Investments by Insurance Companies, which is helpful for insurers to expand foreign investments. However, this does not go far enough as there is still an investment limit on foreign investment based on the ratio of foreign currency General Account (GA) to NT dollar GA.


  • Individual mobility - Drivetrain electrification - Encouraging electrification of passenger vehicles - Extension and expansion of incentives: On 31 August, the Ministry of Finance announced to the media that an amendment to extend the EV commodity tax reduction until 2025 had been sent to the Executive Yuan for approval. On 23 September, a public hearing on the amendment gained support from all stakeholders. However, an official announcement of the extension is pending.
  • Individual mobility - BEV/PHEV non-fiscal incentives - Exclusive use of charging spaces: The Ministry of Transportation and Communications (MOTC) has agreed that municipal governments may implement their own measures for the exclusive use of charging spaces for EVs, as long as the measures do not contradict the central government's regulations. Starting early in 2021, Taipei City has implemented various measures to facilitate the exclusive use of charging spaces. However, it remains a common problem for EV charging spaces to be occupied by Internal Combustion Engine (ICE) cars, leaving the EVs with no space and access to charging equipment.
  • Individual mobility - New energy vehicle charging infrastructure and interfaces - The development of public and private charging stations led by the government: The MOTC's Freeway Bureau awarded contracts for charging stations in March 2021. The Bureau of Standards Metrology and Inspections (BSMI) has updated the CNS standard with CCS1 DC charging specifications and communication protocols based on the latest IEC standards. However, there is a lack of incentives for building EV charging infrastructure.
  • Public transport and commercial mobility - Homologation issues for commercial vehicles - Width limitations on electric trucks and buses: The MOTC's Directorate General of Highways, MOTC announced pilot projects to allow a maximum permissible length for highway coaches of up to 15 meters to evaluate the feasibility of lifting the current restriction. However, restrictions remain on the maximum width of trucks and buses, which is not aligned with international standards.
  • Regulatory issues and business environment - Regulatory inspections for after-service vehicle components: In a meeting in August 2021, the MOTC and BSMI both agreed to the proposal raised in the 2021 position paper and agreed to work with the committee to develop a procedure to put into practice. Currently, the regulatory inspection of components is conducted by the BSMI and MOTC according to two testing processes and testing standards, depending on whether the components were imported as individual parts or as integrated components of the complete vehicle.
  • Regulatory issues and business environment - Mandatory and prohibitory provisions of standard contracts for mobile vehicles: In a public hearing on the “Lemon Car law” held by a legislator on 27 August, all stakeholders supported the conclusion that a government agency should specify a third-party testimonial body. The MOTC also promised to work on the proposal within 2021. At present, regulations on standard contracts for motor vehicles do not confirm and identify Expert Testimony authorities.

Retail & Distribution      

  • Transparency and consistency of government policies - Translations of Taiwan standards and testing methods: The Bureau of Standards Metrology and Inspections (BSMI) issued an official letter on 28 January 2021, which provided an "Analysis Table of Difference of Key Technical Content" (重點技術內容差異分析表) responding to the committee's request. However, certain CNS standards were not included.
  • Transparency and consistency of government policies - Government digitalisation - E-inspections for food: The Food and Drug Administration (FDA) has implemented e-inspections of certain imported food products at borders. However, the number of food categories permitted to use e-inspections and e-documents is limited.
  • Technical barriers to trade for European food products – Organic Agriculture Promotion Act: The Council of Agriculture (COA) recognizes the necessity of complementary measures during the pandemic, and has offered flexibility on cooperation between Taiwan and European certification bodies (CB), such as streamlining qualifying procedures and reducing the number of mandatory training hours. However, the approval process for foreign CBs is cumbersome and no foreign CB has yet been approved.
  • Regulatory framework issues for food products - Regulation of Foods for Special Medicinal Purposes (FSMP) - Product variation changes post registration approvals: The FDA has responded positively to the committee's proposals regarding product variation and labelling changes. However, there have been no actual changes to regulations and practice. According to existing regulations, minor changes to formulas require new product registrations while labelling changes require pre-approval.
  • Integrated sustainability policies - Better use of recycled materials: On 7 January 2021, the EPA officially announced amendments to the "Management Regulations for Reuse of Common Industrial Waste", according to which recycled plastic would be permitted to be used for the production of food containers as long as the products comply with the "Act Governing Food Safety and Sanitation" supervised by the FDA. By September, the FDA had developed draft recycling plastic guidelines for food packaging for further discussions with relevant stakeholders.