The RCM is now mandatory for electrical safety in Australia and New Zealand
On March 1, 2013, Australia’s Regulatory Compliance Mark (RCM) commenced the transition to replace the C-tick and A-tick marks, and the introduction of the new Electrical Equipment Safety System (EESS). The RCM became mandatory as of March 1, 2016. The EESS requires the use of the RCM for all in-scope equipment and has replaced the current state and territory based electrical safety approval systems, except for those in New South Wales (NSW).
The use of the RCM requires Australian-based manufacturers, importers or suppliers to register the company and all medium and high risk products on the EESS national data base. The RCM is a single compliance mark and may only be used by Australian/New Zealand suppliers after establishing compliance with all applicable regulations, including EMC, telecoms, radiocoms, electromagnetic radiation (EMR) and electrical safety.
This brief article will explain the new Australian Communications and Media Authority (ACMA) and EESS regimes, including testing, certification and administrative requirements.
ACMA Requirements for RCM
If you use the RCM for ACMA compliance, you must first register as the ACMA Responsible Supplier at the website of Australia’s Electrical Regulatory Authorities Council (ERAC), the peak body of electrical safety regulators in Australia and New Zealand. ERAC acts to ensure electrical safety regulatory systems are contemporary and harmonized wherever possible.
Next, you must identify the ACMA-applicable standards and obtain the appropriate test reports. Products that do not have wireless or telecom function are relatively straight forward and only require an EMC test report to an EMC standard listed on the ACMA list of applicable standards (easily found with a web search).
Products that include a wireless transmitter such as Bluetooth, WiFi, portable radios, etc., must also comply with the relevant ACMA Radiocommunications (Radcom) standard and the ACMA (EMR) standard
If a product also includes a connection to the mobile phone network, satellite telecom network or the public switched telephone network (PSTN), it must comply with the relevant standards prescribed in the Telecommunications Labelling Notice (TLN) 2015. However, if the product includes a mobile phone network interface, determining the applicable ACMA requirements is often fraught with risk. It may be prudent to consult with an ACMA accredited certification body. (The A-tick label formerly applied to telecom products).
There are some exemptions from the ACMA RCM labelling requirements and these are listed in the ACMA EMC Labelling Notice. RCM labelling of some battery powered equipment is voluntary; however, care should be taken when interpreting the “battery powered” definition. The battery must be internal to the product and it must not be possible to operate when it is being charged by an external supply. Devices that use an automobile 12V supply are not exempt, nor are devices that have a wireless transmitter such as Bluetooth or WiFi.
The Compliance Folder must be kept at the disposal of the ACMA for audit purposes. It must include a signed Declaration of Conformity (DoC), the relevant test reports and a description of the product. The labelled product can then be sold in Australia and New Zealand.
EESS Safety Compliance – Mains Operated Equipment
Most mains powered products other than Level 2 or Level 3 products are Compliance Level 1 under EESS classification. Registration is not mandatory, but compliance with an appropriate safety standard is required under various state and federal laws. A valid safety test report should be kept on file in case of regulator request.
Domestic appliances and AC adapters/chargers are considered high risk devices and are classified as Compliance Level 3 devices. A complete list of Compliance Level 3 (in-scope) equipment can be found in AS/NZS 4417.2:2012. Under the EESS RCM rules, Compliance Level 3 products must be registered on the ERAC national database by the Responsible Supplier (also the importer). A Certificate of Conformity must first be obtained from an accredited certification body. For imported Level 3 products, registration must be done by each importer (who must be based in Australia/NZ), even if another importer has registered the same product. Registration as a Responsible Supplier is not possible for overseas entities.
The importer in Australia or New Zealand is solely responsible for safety compliance of the product. This responsibility cannot be delegated through a local representative agreement with an overseas manufacturer. However an importer can delegate the registration process to an authorized representative (consultant) based in Australia or New Zealand. Registration and certification fees can be avoided by using a charger/adapter that is sourced from a supplier located in Australia or New Zealand.
A single consolidated mark, the RCM, has now replaced the former C-tick and A-tick labels. All imported equipment falling within the scope of ACMA and the EESS must be labelled with the RCM and compliance records, including the DoC, must be kept. Existing stocks of products still in the supply chain that have the C-tick or A-tick labels may be sold until the stock is exhausted. ACMA suppliers now have a less onerous labelling system; however suppliers of Compliance Level 2 and Level 3 products have a more strict and transparent regime with which to comply.
Chris Zombolas is the Technical Director of EMC Technologies Pty Ltd, an ACMA accredited certification body and internationally recognizsed NATA accredited test house with labs in Melbourne, Sydney and Auckland (NZ), specializing in EMC, EMF/EMR, SAR, safety and radiocoms testing and approvals. He has over 35 years of experience in the EMI/EMC/EMF/SAR test and approvals disciplines. He can be reached at firstname.lastname@example.org.
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