When considering the how to approach the compliance for the RCM Radiocommunications requirements for Australia we need to consider the ACMA requirements and also the product itself, i.e. what type of transmitter or receiver the product is.
The Radiocommunications (Low Interference Potential Devices) Class Licence 2015 (the LIPD Class Licence) allows the usage and operation of a wide range of low power radiocommunications devices as per the set out defined frequency allocations over the spectrum. The class license defines the allowable characteristics of the including frequency of operation, maximum radiated power and other conditions depending upon the classification of the device.
There are many types of transmitters for various uses, these are categorized along with the standards applying to them and the compliance levels (which determine the level of compliance evidence required) in “Schedule 2 Applicable standards and compliance levels” of Radiocommunications (Compliance Labelling – Devices) Notice 2014.
Short Range Devices
We will focus on the most commonly used technologies and the most common inquiry we receive. This group entails the usage of short-range devices, as per item 10 ” Radiocommunications (Short Range Devices) Standard 2014″ as per “Schedule 2 Applicable standards and compliance levels” of Radiocommunications (Compliance Labelling – Devices) Notice 2014. Item 10 (Short-range devices (SRD)) & item 3 (Cordless Telephone) both are classified as compliance level 1.
Included within a group of short-range devices are Bluetooth, Wi-Fi (802.11b,g,n etc), ZigBee, 433 MHz remotes etc as stated previously are compliance level 1.
(1) Before a supplier applies a compliance label to a device, the supplier must ensure that the device complies with each applicable standard at the compliance level mentioned in column 3 of Schedule 2 for the standard.
(2) The supplier of a high‑risk device or a medium‑risk device to which subsection 8(3) applies must ensure that the device complies with each applicable standard at the compliance level mentioned in column 3 of Schedule 2 for the standard.
Compliance level 1 requirements
To comply with compliance level 1 for an applicable standard i.e, the supplier of a device must:
(a) prepare a description of the device; and
(b) complete and sign a declaration of conformity for the device.
A test report for a LIPD device is not actually required, however, if you are going to sign the Declaration of Conformity (DoC) you should be sure that is based upon technical justification and evidence, not forgetting you still have to ensure that the product complies with the LIPD.
The ACMA’s compliance scheme is similar to Europe’s and is based upon “self-declaration of compliance” it’s the supplier’s responsibility to ensure that they satisfy themselves that the product is compliant before they sign the DoC. Typically through a test report, you would normally state on the DoC the test report details in the correct section the evidence i.e. “Compliance – applicable standards and other supporting documents”.
Ensuring compliance with the LIPD
The LIPD references the methods as per the industry standard AS/NZS 4268 ‘Radio equipment and systems – Short range devices – Limits and methods of measurement’. The current version of AS/NZS 4268 is the 2017 version. This new version of the standard has some changes including more guidance on the use of existing certifications such as FCC and ETSI standards. An FCC test report or an ETSI test report may be able to be used as evidence in full to demonstrate compliance. This means that there are presently two routes of using existing compliance evidence,
A) a valid FCC test report or
B) a valid ETSI test report.
A combination ‘mix and match’ hybrid of the FCC and ETSI reports is not allowed. With the variations in the required testing for FCC and ETSI compliance, it may require less testing or be deemed easier to comply via the FCC or the ETSI requirements. It is accepted that either route is acceptable, however, the supplier must ensure that device operates in accordance with the LIPD. Also, it was noted that the version of either the ETSI of FCC standard must the same as per the Official Journal of the European Union (ETSI standards) or the FCC rules respectively that apply on the date the device is imported into or manufactured in Australia or New Zealand. An older version of the standard is technically not acceptable, these may include old versions of ETSI EN 300 328 such as Version 1.4.1 etc of FCC Part 15C reports using methods of ANSI C63.4: 2009 and ANSI C63.10: 2009. The ACMA has indicated that they would accept a suitably qualified person, or a test laboratory issuing a statement to the effect that a test report to an ‘old dated version’ of a standard shows the device would also comply with ‘new dated version’ of the standard. However in the case of a dispute or issue arising surrounding compliance then the current versions of testing methods would be favoured.
An example of how to show compliance would be that the supplier can demonstrate compliance to all of the applicable requirements included in the FCC rules or the ETSI standards listed in AS/NZS 4268:2017, including testing at extreme temperatures, voltage extremes etc. However, if the FCC rules or the ETSI standard does not specify such testing (i.e. testing at extreme temperatures is not required) then this is not required. It must be remembered that if an SRD transmitter operates in Australia outside of the parameters, authorised by the LIPD class license, then the transmitter will be unlicensed and the end user could be prosecuted for offence (s) under the Radiocommunications Act 1992.