When considering how to approach the compliance with the RCM Radio-communications equipment requirements for Australia we need to consider the specific ACMA requirements and also the product itself, i.e. the type of transmitter or receiver.
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 radio communications devices as per the defined ACMA frequency allocations. The class license defines the allowable characteristics including the frequency of operation, maximum radiated power and other conditions depending upon the classification of the device.
There are many types of transmitters and these are categorized along with the standards applying to them as well as the compliance levels. Refer to 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 entails the usage of short-range devices, (SRD) as per item 10, Schedule 2 of the ” Radiocommunications (Short Range Devices) Standard 2014″. Short-range devices (SRD) are classified as compliance level 1.
Included within this group of short-range devices are Bluetooth, Wi-Fi (802.11a,b,g,n, ac,), ZigBee, 433 MHz FOB/remotes etc. These are all compliance level 1.
Compliance requirements
Compliance levels
(1) Before a supplier applies the RCM compliance label to a device, the supplier must ensure that the device complies with each applicable standard per the compliance level in column 3 of Schedule 2 of 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 of the standard.
Compliance level 1 requirement
To comply with compliance level 1 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 your declaration is based upon technical evidence, not forgetting that you still have to ensure and prove that the product complies.
The ACMA’s compliance scheme is similar to Europe’s and is based upon “self-declaration of compliance”. It is the supplier’s responsibility to ensure that the product is compliant before they sign the DoC. This is best done with a test report. The test report details and the standard used should be stated in the DoC.
Ensuring compliance with the LIPD
The LIPD references the methods in the industry standard AS/NZS 4268 ‘Radio equipment and systems – Short range devices – Limits and methods of measurement’. Make sure that you use the current version of AS/NZS 4268. This latest version of the standard has some changes including more guidance on the use of existing approvals such as FCC and ETSI. An FCC test report or an ETSI test report may be used as evidence in full to demonstrate compliance. Either of the two routes may be used to comply.
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. Either route is acceptable, however, the supplier must ensure that the device operates in accordance with the ‘LIPD’. Also, the version of the ETSI of FCC standard must the same as that, which was in effect on the date the device was first imported into or manufactured in Australia. An older version of the standard is technically not acceptable, but the latest version is not strictly required for Level 1 compliance. 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, the current versions of standards would be favoured.
The safest approach is for the supplier to show compliance would be with all applicable requirements included in AS/NZS 4268:2017, including testing at extreme temperatures, extreme voltages etc. However, if the FCC rules or the ETSI standard does not specify such testing (i.e. testing at extreme temperatures) then this is not required. Be mindful however that if an SRD transmitter operates in Australia outside of the parameters, authorised by the LIPD class license, the transmitter will be deemed by the ACMA to be unlicensed and the end user could be prosecuted for the offence(s) under the Radiocommunications Act.
