As of 1 March 2016 all electrical/electronic devices entering the Australian market, either locally or by import, must comply with the appropriate EMC standard if they fall under the scope of one of the EMC standards mandated by the Australian Communication and Media Authority (ACMA). Compliance is by means of Declaration of Conformity (DoC) and suppliers placing products on the Australian market must ensure that each product meets the appropriate EMC standard and be labelled with the RCM label.
The C-tick mark will no longer be applicable for new products after that date. This article will discuss the critical advantages afforded by NATA (National Association of Testing Authorities) accredited testing as a rigorous basis for proving compliance with the RCM, C-tick and international EMC regulations. NATA testing is the most economical path to compliance for the majority of products and the application of a NATA accredited test will greatly enhance the value of a product and facilitate its access to lucrative global markets.
ENFORCEMENT OF EMC REGULATIONS
In the event that a product’s compliance is called into question, the ACMA will carry out an audit of the relevant compliance folder and may undertake further investigations. The ACMA will accept a NATA test report as final in any determination. For willful violations, penalties may apply to both individuals and companies. Regulations are enforceable under the Radio-communications Act 1992, the Trade Practices Act 1974, the Telecommunications Act 1997 and the Crimes Act 1914.
A primary offence under the Radio-communications Act for the supply of a non-standard device may result in the seizure and forfeiture of stock and up to $160,000 criminal penalties. Imprisonment is also possible under the Crimes Act and offences are also committed for breaches of the RCM/C-Tick labelling provisions under Trade Mark and Copyright regulations. Similarly, harsh penalties are applicable in most other countries that have EMC regulations.
The ACMA will accept a NATA test report as proof of compliance. The use of NATA testing provides the best possible protection to the person signing the DoC since it can be used as the basis of a “due diligence” defence in any legal action. Where the DoC is based on non-NATA testing, then the supplier may be required to bear the cost of testing at a NATA test laboratory. The test samples and the NATA test laboratory will be nominated by the ACMA.
NATA REQUIREMENTS FOR ACCREDITATION OF TEST LABORATORIES
NATA accredited facilities meet the requirements of ISO/Guide 17025, demanding full calibration traceability of measurement equipment to the national standards at the National Measurement Institute (NMI) of the CSIRO, and thereby to international standards. Calibration traceability is essential for the acceptance and recognition of test reports. NATA accredited test houses must be thoroughly evaluated by NATA and accredited as meeting internationally recognised standards for good laboratory practice, the availability of the necessary test facilities, an adequate level of technical competence and the appropriate quality management systems. ISO 9002 alone is not acceptable for accreditation of laboratories as it does not include the key criteria of technical competence and adequate facilities prescribed by IEC/ISO Guide 17025. NATA accredits laboratories against each specific EMC standard and a test report may not be endorsed with the NATA logo unless the test house is accredited to the specific standard. NATA laboratories must also perform on-going proficiency tests in their field of accreditation and they are continually assessed and audited against the requirements of IEC/ISO Guide 17025.
The use of unaccredited laboratories carries a great risk that the testing may not be 100% competent. Consequently, the risk is carried by the person who signs the DoC.
ADVANTAGES OF USING NATA (ACCREDITED) TESTING
In Australia, testing by an accredited NATA laboratory is the safest way of proving compliance. A NATA endorsed report is acceptable by the ACMA (Australian Communications and Media Authority) and most of Australia’s trading partners including all EU (European Union) countries. Accredited testing will minimise the risks should a dispute arise with the regulatory agencies. Non-accredited testing should be avoided as there is no guarantee of the reliability or the accuracy of the results. The use of non-accredited testing is generally a little cheaper, but in practice, it may be rejected by the regulator. A NATA endorsed test report adds value to your product by providing it with the most credible and internationally accepted compliance status available.
NATA’s Global Recognition
How can NATA Accredited Testing Adding Value to your Product? NATA reports are considered equivalent to the following overseas accreditation bodies who have an MRA with NATA. • EUROPE UKAS/NAMAS, STANAG, DANK, SWEDAC, SINAL, COFRAC, RELE, ICLAB, FINAS, NA, SAS
• AUSTRALIA NATA
• USA NVLAP, A2LA
• HONG KONG HOKLAS
• NEW ZEALAND IANZ
• USA NIST/NVLAP/A2LA (FCC recognised)
FACTORS IN SELECTING AN EMC TEST HOUSE
Test Time and Test Costs
The cost of testing is directly proportional to the test time and the use of the test facilities. The number of applicable tests and the nature of the product will impact the total test time. Devices that are slow to respond or difficult to exercise during the testing require longer test times and are therefore subject to higher test charges. Test house charges in Australia vary greatly depending on the nature of the test, the technical competence of the test house, the sophistication of the test facilities and most importantly, the accreditation status.
Appropriate Standards Accreditation’s
A test house may use NATA or an equivalent endorsement when it is accredited for testing to just one standard. Some NATA accredited test houses have a very limited scope of accreditation, often being accredited to one standard only. Some consultants are NATA accredited as Competent Bodies and Conformity Assessment Bodies (CAB). The NATA (or equivalent) logo often appears in advertising literature giving the perception that the Competent Body or CAB consultancy is accredited for testing. A NATA test house with limited accreditation may appear to have a wider scope of accreditation than it actually has. This practice is misleading and results in confusion and extreme disappointment among those unfamiliar with the vagaries of NATA rules for the use of the NATA logo.
When selecting a Test House, the supplier must be satisfied that the laboratory is NATA accredited to the appropriate standard as well as all the applicable clauses of that standard. A NATA endorsed test report may only be issued by a laboratory accredited to the specific EMC standard including all the relevant clauses. Be very wary of non-accredited test organizations or some that may claim dodgy overseas accreditation.
Risks of Overseas Testing
The cost of EMC testing in Australia is comparable to the cost in South East Asia (excepting some labs in China) European and North American test houses. Testing overseas can be extremely risky and hence this is how NATA Accredited Testing Adding Value to your Product. The probability of compliance failure is very high for first time tests, particularly for those products tested against the more stringent residential class B limits.
The initial savings offered by budget testing are quickly erased if a failure occurs as the time required to effect solutions and retest incurs additional costs well above the initial outlay. The cost of freight, courier fees, phones and faxes will result in further escalation of the costs.
The supplier is advised to select a NATA accredited Australian test house that allows you to attend the testing. This ensures that the testing proceeds smoothly and allows you to assist in overcoming compliance problems should they occur. In general, budget testing or non-NATA testing should be avoided.
QUESTIONS TO ASK THE TEST HOUSE
Are you a NATA accredited Test House?
Some consultants have NATA accredited Competent Bodies or Conformity Assessment Bodies (CAB). The role of the CB or CAB consultant is to review documentation and they must not perform testing in support of a TCF assessment unless they are specifically accredited by NATA for testing. This is against the NATA rules and the EMC Framework and it presents a conflict of interest.
What is the Scope of the NATA Accreditation?
Will I get an unconditional NATA endorsed test report.? Does the test house have specific accreditation for the appropriate test standards that my product must satisfy to earn compliance? For example, a test house accredited by NATA for EMI testing to AS/NZS CISPR 22 cannot issue a NATA endorsed report for testing AS/NZS CISPR 14 or to any other standard not covered by the terms of the accreditation.
Does the Scope of accreditation cover the complete standard?
An accreditation for a particular standard may limit the frequency range or exclude some of the clauses in that standard. A limited accreditation may mean that it may not be possible to establish compliance with the complete standard.
Will the report have international recognition?
Will the report be recognised by the FCC, Industry Canada, Japan, Singapore, Taiwan etc? The test house must have these recognitions otherwise the test will need to be repeated in those countries.
Is the Testing Subcontracted to another Test House
Does the test house have an in-house test capability or will your test be subcontracted to another test house? Some consultants including CB and CABs advertise testing and certification services but actually subcontract the testing to local or overseas test houses. Double handling such as this will inevitably inflate test costs, delay report generation and inevitably frustrate the flow of correspondence required if a failure and fix are required.
NATA Test Report
Will a NATA accredited endorsed report be provided? Is there a surcharge for a NATA report? Are the reports suitable for the intended country?
Test House Expertise
How experienced are the staff actually engaged in performing the tests? The experience and proficiency of the test house personnel will directly impact on the test duration and on the accuracy of the test. The use of automated and sophisticated compliance test equipment and test procedures enables greater efficiency in testing time and test costs.
Does the quoted price include a desk/design review prior to the testing program? The probability of test failure is very high for first time testing of most products. A brief desk/design review by an experienced EMC test house can quickly identify potential trouble spots and help to minimise potential test failures, and thereby minimise test time and testing costs. Why employ an expensive consultant when you can get expert advice and assistance free from your NATA test house?
What Happens if my product fails the EMC Tests?
What is the test house policy if the product fails the compliance test? Does testing proceed to conclusion followed by the issue of a non-compliant report? Does the test house automatically perform simple diagnostic tests once a non-compliance has been recorded? A little time spent on fault investigations at this stage can save one pass through the test house. Does the test house supply spectrum plots of EMI measurements? Spectrum plots of different test configurations are of enormous help in the diagnosis and rectification of an EMI failure. If your product fails the test, what are the additional costs for a retest? Does the original fee apply again?
Witnessing the Test
What is the test house policy on allowing you to witness the testing of your product? Is it permitted? If so, is there a surcharge? Witnessing testing provides a valuable insight into the EMC testing process and provides hands-on training that is not generally available. The future value of this experience in new product design strategies is invaluable. It is strongly recommended that you visit and inspect the facilities to ensure that you are getting what you pay for.
Does the test house provide a consultation service to assist in achieving compliance? What are the levels of experience and qualifications of the consultant? Your company can benefit enormously from the test house experience gained from thousands of tests and fixes. The cost of the consultation charge is slight in comparison to the cost of the many man-hours that your company’s engineers will have to devote to rectifying EMI fixes that are essentially routine for an experienced test house technical team.
Most countries have regulations that mandate compliance with EMC standards before products can be legally marketed. Selecting an experienced EMC Test House accredited to test to all of the ACMA standards, the CE, FCC, IC, VCCI and other regulations will provide you with a valuable partner who can offer all the expertise required in dealing with the complexities of Australian and international regulatory approvals, standards and specifications.
The use of non-accredited testing, whether in Australia or overseas, may expose you to unnecessary risks. The use of NATA accredited testing is the lowest risk approach to EMC compliance and will also facilitate global acceptance of your product. NATA reports are accepted by CBs and CABs and may be used to support a TCF (Technical Construction File). NATA accredited testing adding value to your product and NATA test reports add value to your product and are your product’s passport through trade barriers into lucrative overseas markets. Your NATA test house is your partner in approvals and has a common interest in the success of your product and the success of your business.
“NATA Accredited Testing Adding Value to your Product” Written by Chris Zombolas, Technical Director, EMC Technologies Pty Ltd and director of EMC Bayswater Pty Ltd.