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Cellular Approvals and RCM Certification in Australia

In Australia, all electrical and electronics devices, including cellular modules, need to comply with the requirements of the Regulatory Compliance Mark (RCM). The RCM is of two parts jointly owned by the Australian Communications Media Authority (ACMA) and the Electrical Regulatory Authorities Council (ERAC). Cellular approvals are technically complex and involve all aspects of the ACMA regulations and the ERAC Electrical Equipment Safety System (EESS) RCM certification process. 

ACMA RCM Requirements

Most recently amended in 2018, the ACMA’s standard TLN: Telecommunications (Labelling Notice for Customer Equipment and Customer Cabling) Instrument 2015 mandates that cellular devices intended for connection to the public mobile telecommunications service (PMTS) must comply with Telecommunications (Mobile Equipment Air Interface) Technical Standard 2018, which in turn references AS/CA S042.1, Requirements for Connection to an Air Interface of a Telecommunications Network – Part 1: General. 

All telecommunications devices, including those utilizing 3G, 4G, 5G, or satellite communications technologies, must comply with the requirements of the latest updated version of the standard issued in 2020. 3G and 4G devices must also comply with the requirements of AS/CA S042.4, Requirements for Connection to an Air Interface of a Telecommunications Network—Part 4: IMT Customer Equipment. 

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The Communications Alliance (the CA of AS/CA) Working Committee 94 (WC94) has been established and is currently discussing an update to the scopes of AS/CA S042.1 and AS/CA S042.4, and the introduction of a new Part 5 to the S042 series to address the requirements of 5G technologies. The new and updated standards are likely to be published in 2022.

Compliance requirements for the current AS/CA S042.1 (2020) and AS/CA S042.4 (2018) vary depending on device functionality and the technologies used. Devices such as remote dataloggers, where the cellular and/or satellite functionality are only used for data transfer, are the simplest devices to assess for conformity. But requirements for even these simple devices vary depending on technology (i.e., satellite, 3G, 4G, Cat M1, or NB-IoT) and the frequency bands used (e.g., Band 5 devices must comply with U.S. Federal Communications Commission (FCC) Part 22 requirements). 

Complexity increases when voice functionality is introduced. The least complex assessment is for walkie-talkie type devices, where the device is restricted to a preconfigured call group and does not operate in a standard telephone service (STS) access mode. STS access mode allows devices to make cellular or satellite calls to other devices (cellular, satellite, or landlines). 

Additional requirements apply to the devices operating in an STS access mode. Cellular and satellite devices must be assessed to confirm their emergency service access and their handling of emergency calls to the national emergency service numbers 000, 112, and 106. Test calls for satellite services are limited to 000 (the general emergency service number), whereas cellular devices additionally include 112 (the alternative emergency service number for digital mobile phones). Test calls are performed with the device in multiple configurations, such as various lock states, with and without SIM, and using manual and/or soft keys.

Devices capable of both satellite and cellular functionality are required to comply with the requirements of each service. Additionally, if a device is incapable of operating in STS access mode but can provide these services to another device through a local port and/or RF interface, the gateway device is subject to the requirements of each provided service.

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AS/CA S042.1: 2020 introduced advanced mobile location (AML) testing. Test calls made to the emergency service numbers 000 and 112 by a device supporting AML and GPS functionality now require contacting the emergency call person (ECP) to confirm that the device information and location data was received correctly.

Devices used in close proximity to the ear for voice communications in a typical handset style or a headset are also required to comply with the maximum sound pressure level output requirements to confirm that the device will not cause acoustic shock to the user. Devices used in a speaker phone or walkie-talkie style where the device is not used near the ear in a typical handset style are not required to undergo this testing. 

To reflect the importance of emergency service access and acoustic safety, AS/CA S042.1 for devices that are used to supply a standard telephone service (STS access mode) is treated as a high-risk standard, and the test report must be endorsed by an accredited facility. 

The requirements of Part 4 do not vary as much as those in Part 1. Most devices coming to market are integrating pre-certified modules from well-known manufacturers. The test reports and declarations for these modules are usually available from the module manufacturer and passed on to testing laboratories for use in the telecommunications assessment. These reports are used to demonstrate the RF compatibility, network integrity, and interoperability with the STS of the module and host device. 

A common misconception with host device manufacturers is that these module reports are enough to establish conformity for their device to AS/CA S042.4. However, the standard refers to the device undergoing assessment as customer equipment, not the cellular module itself. 

It is understood that the ACMA’s position is that device manufacturers integrating a pre-certified module (with suitable evidence of conformity for Australian requirements) are not expected to re‑establish the RF compatibility, network integrity, and interoperability with the STS conformance of the module. However, the integrated host device must be assessed for radiated spurious emissions to determine that integration into the host device and antenna configuration used has not caused any unintentional emissions from the module that exceed the limits.

AS/CA S042 Part 1 and 4 assessments mainly requires gathering documentation, including the following information:

S042.1:2020 General

  • Testing for emergency service access and AML (if applicable)
  • Testing for audio acoustic safety (if applicable)
  • Manufacturer’s Declaration of Conformity (DoC) for mobile identity requirements
  • Warning notice requirements

S042.4:2018 3G/4G Devices

  • The cellular module test reports to FCC Part 22 Rules; or FCC/TCB Grant of Equipment Authorization based on FCC ID/Manufacturer’s DoC.
  • The cellular module test reports to ETSI EN 301 908, Parts 1, 2, and 13 (as applicable); or EU-type examination by a Notified Body (NB)/
    Manufacturer’s DoC, based on conformity assessment procedures described in the EU’s Radio Equipment Directive (2014/53/EU, also referred to as the RED). 
  • Manufacturer’s DoC stating compliance with mandatory requirements of the core protocol specifications as per applicable ETSI technical standards.
  • Radiated spurious emissions test report on the final integrated/composite customer equipment.

A National Association of Testing Authorities (NATA)-accredited report is largely accepted as proof of compliance by the ACMA and the Australian telecommunications industry. NATA is a signatory to the ILAC Mutual Recognition Agreement (MRA). Therefore, a report accredited by an equivalent accreditation body is also acceptable. A Certification Body Statement (CBS) by an ACMA Certification Body is not mandatory but a NATA (or equivalent) endorsed report may be used to obtain one.

Other ACMA Requirements

The ACMA requirements also include EMC, EMR/SAR, Radiocommunications, and Electrical Product Safety as follows:

EMC Compliance

For most telecommunication devices, the most common standard is CISPR 32, Electromagnetic compatibility of multimedia equipment – Emissions requirements. As the title suggests, this standard relates to multimedia equipment (IT, audio, video, broadcast receivers, entertainment lighting control equipment, or any combinations). EN/IEC 61326‑1, Electrical equipment for measurement, control and laboratory use – EMC requirements – Part 1: General requirements, is another common standard as it relates to measurement, control, and laboratory equipment (e.g., dataloggers). 

For equipment used in vehicles, UN ECE R10, Electromagnetic Compatibility, is usually applicable. 

Where multiple standards are applicable, the ACMA advises selecting the standard that best matches the main purpose of the product.

EMR/SAR Compliance

The ACMA standard, Radiocommunications (Electromagnetic Radiation – Human Exposure) Standard 2014, is the applicable standard for electromagnetic radiation (EMR) and specific absorption rate (SAR) compliance. If the integral antenna of the device is greater than 20 cm from a human body, e.g., a wireless router, compliance with the ACMA EMR standard requires an assessment of the radio frequency (RF) exposure levels performed in accordance with AS/NZS 2772.2:2016, Radiofrequency fields – Principles and methods of measurement and computation – 3 kHz to 300 GHz. 

International human exposure assessments (FCC Part 2.1091, RSS-102, EN 62311, etc.) provide useful information for the AS/NZS 2772.2 assessment, but only AS/NZS 2772.2 is accepted as evidence of conformity for the ACMA EMR standard. 

For the ACMA standard, the human body includes only the torso, neck, and head, and not limbs such as arms and legs. 

If the device has an integral antenna and is normally used within 20 cm of a human body, a NATA (or equivalent)-endorsed SAR test report is required. SAR must be measured in accordance with methods described in EN 62209-1 (at the ear) and EN 62209-2 (at the body). All bands and all radio transmitters must be assessed. If simultaneous operation via telecommunications (3G/4G), and/or radiocommunications (Wi-Fi/Bluetooth) is possible, SAR measurements must be conducted with the device in a simultaneous transmission mode. 

The exposure levels are assessed against the reference limits for occupational and general public exposure (as applicable) as defined in the recently released ARPANSA RPS S-1 (February 2021).

European EN 62209 SAR reports must state compliance with the performance requirements of the ACMA EMR Standard 2014. FCC SAR reports are not acceptable for ACMA compliance purposes.

Radiocommunications Compliance

Bluetooth, Wi-Fi, and NFC transmitters must comply with ACMA Radiocommunications (Compliance Labelling – Devices) Notice 2014 as per the short-range devices (SRD) standard, AS/NZS 4268:2017, Radio equipment and systems – Short range devices – Limits and methods of measurement. EU RED reports showing compliance with EN 301 893 (5 GHz Wi-Fi), EN 300 328 (Bluetooth and 2.4 GHz Wi-Fi), EN 300 220 (25 MHz to 1 GHz), and EN 300 330 (9 kHz to 25 MHz) can be used to show compliance with AS/NZS 4268. In most instances, a CE RED radio report or an FCC radio report may be used to show compliance to the requirements of AS/NZS 4268.

Electrical Product Safety Requirements

The ACMA TLN requirements mandate that satellite/3G/4G devices must comply with the Telecommunications (Customer Equipment Safety) Technical Standard 2018 (AS/NZS 60950.1:2015, Information technology equipment – Safety, or AS/NZS 62368.1:2018, Audio/video, information and communication technology equipment – Safety requirements). The Customer Equipment Safety standard is classified as a high-risk standard, and test reports must be NATA or equivalent endorsed.

AS/NZS 60950.1 has been superseded by AS/NZS 62368.1 and the transition period ends on 15 February 2022. For those targeting CE marking compliance as well, AS/NZS 62368.1 with EN variation testing is the preferred option as EN 60950‑1 is no longer accepted for CE marking. 

For devices where the intended application is such that the ingress of water is possible, the electrical safety standards require an ingression protection (IP) test report to IEC 60529:2004, Degrees of protection provided by enclosure (IP Code), to a declared IP rating.

Although the Telecommunications Customer Equipment Safety standard mandates AS/NZS 60950.1 or AS/NZS 62368.1, there may be additional relevant electrical safety product standards. The EESS defines products as being in-scope and not in-scope. Suppliers of electrical safety equipment that are not in-scope still have a responsibility to ensure their products are electrically safe. AS/NZS 3820, Essential safety requirements for electrical equipment, provides the essential safety criteria for electrical equipment and requires evidence of conformity to the relevant product standard to be held. 

In-scope products are classified as risk level 1, 2, or 3. Risk levels 2 and 3 are defined in AS/NZS 4417.2, Regulatory compliance mark for electrical and electronic equipment – Specific requirements for particular regulatory applications. Products not defined in the standard are classified as Risk Level 1 and are low or unknown risk. 

One point of note for international suppliers or manufacturers is that the ACMA requires a local Australian representative such as the supplier, importer, or an agent (someone in Australia who acts on behalf of a manufacturer or importer) for their RCM compliance declaration. However, agents cannot be registered as Responsible Suppliers under the ERAC/EESS.

ERAC EESS RCM Requirements for Charger/Power Adapters

The applicable standard for electronic or ferromagnetic power supplies or chargers for use with IT, audio, and video equipment is AS/NZS 60950.1:2015 as per the in-scope electrical equipment definitions and risk levels for the Electrical Equipment Safety System (EESS) document published by the EESS. This document is a freely available alternative summary of the class 2 and 3 applicable standards available in AS/NZS 4417.2.

An accredited test report (NATA or equivalent) to the applicable Australian safety standards is required to obtain electrical authority approval and certification for chargers/power adapters. Assuming an Australian approved plug and cord set is provided, the local supplier or importer into Australia must prepare and submit for electrical authority approval, application, and certification, pay fees, obtain approval number, and register the charger/adapter on the ERAC national database. 

It is recommended that an Australian-approved (ERAC registered) OEM charger be used (must be sourced in Australia) to eliminate testing, certification, and registration costs. An EMC report to AS/NZS CISPR 32 or EN 55032 is also required for the charger if sourced separately.

An external power supply used as a charger is required to meet the minimum energy performance standards (MEPS) and needs to be tested to AS/NZS 4665.1:2005, Performance of external power supplies – Part 1: Test method and energy performance mark, and registered in the Equipment Energy Efficiency (E3) database. 

Existing report to AS/NZS 60950.1:2015 or AS/NZS 62368.1:2018 will be suitable if the report of the testing is NATA- (or equivalent-) accredited. CB reports or reports to IEC 60950 or IEC 62368 that include Australian variations are also acceptable.


The compliance requirements for cellular devices that connect to the mobile phone networks in Australia involve all aspects of the ACMA technical regulations including EMC, telecommunications, electrical safety, radiocommunications, electromagnetic radiation (EMR/SAR), and the ERAC regulations for chargers and power adapters. Most information on the technical requirements is readily available on the respective regulatory body websites. 

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