CDT respectfully submits these comments in response to Consumer Product Safety Commission’s (CPSC, or the Commission) request for written comments on the Internet of Things (IoT) and consumer product hazards. While there is no doubt that the IoT presents enormous value, poorly designed and inadequately secured devices can present risks to consumers’ safety and can be exploited for costly cyber-attacks.
As the CPSC explores potential safety issues and hazards in IoT, CDT recommends the Commission:
- Recognize the unique scope and characterization of IoT devices and how this impacts hazardization considerations;
- Identify existing IoT standards to bolster security practices across different consumer product domains;
- Collaborate with relevant stakeholders to provide guidance to consumers and manufacturers on IoT-related informational harms;
- Develop a plan for addressing hazards associated with abandoned and unsupported IoT devices;
- Track IoT products, including component disclosures and IoT designations, for complaint databases.