EMC Bayswater are often asked about products with Wireless integrated telecommunication modules for RCM compliance such as 2G, 2.5G & 2.75G (GSM, GPRS & EDGE), 3G (WCDMA, UMTS, HSPA) or 4G (LTE) modules. usually these wireless modules come with existing certifications with the idea of making the route of compliance for the intended market easier. The biggest confusion comes around how to go about the process of re-evaluating or testing a host product with such a module installed.

If a wireless telecommunication module is already RCM marked does that mean no testing is required?

If the module is itself is modified, altered or uses different software of firmware that may impact the modules performance then re-assessment maybe required. If the module used in manner not in accordance with how existing approvals for that product then re-assessment maybe required. If the module is incorporated into another unit i.e. a host then incorporated then re-evaluation against the mandated RCM requirements is required. If for any reason that particular combination of wireless module and host is changed i.e. the wireless module is substituted for a different technology or another manufacturer or model of module then re-evaluation against the mandated RCM requirements is required for the new host and module combination.


All the compliance requirements for the combined product for Australian and New Zealand would be the responsibility of the final manufacturer who integrates the module into the final product. This is not to say existing documentation may not be used to show evidence against the required compliance requirements. This may include using existing documentation supplied that may be provided by the Australian distributor of the wireless device. After the host device has the module incorporated it will require evaluation against the EMC compliance requirements through testing and possible other testing depending upon the product and the accompanying documentation.

Who is responsible for compliance of the wireless telecommunication module

As per any product sold in Australia and New Zealand the applicable mandated RCM compliance requirement are the responsibility of the Australian importer or manufacturer. This includes if the product is radio-communication classified device such as Bluetooth or Wi-Fi or if the module a 2G, 3G or 4G module, any product in the scope of the RCM regulatory framework. If you purchase an LTE (4G) module from an Australian company then the compliance requirements must be met by them as they are the first point of supply within Australia. If you purchase and import the module from outside Australia or New Zealand then the responsibility falls to you, as you become the first point of the supply chain. Please also see the end note of this post (consumer information), regrading the implications for operating non-compliant communication devices within Australia.

Wireless integrated telecommunication modules for RCM

Electromagnetic Compatibility (EMC)

Lets start with the easiest and most asked topic RCM Electromagnetic Compatibility (EMC) requirements. EMC testing applies to most electrical and electronic products, there are a few products that may exempt for RCM EMC testing. The product as a whole system must comply with the relevant ACMA approved or listed product specific EMC standard or generic standard where no product specific standard can be applied. When a wireless module is substituted for a different module the EMC should be re-evaluated through testing to ensure compliance. If the same wireless module has extensive firmware/software changes that may affect their telecommunication compliance then the EMC/EMR compliance may need re-evaluation.


A radio communication device in basic terms is a device that uses radio emissions or receives radio emissions for the purpose of for the purpose of communicating information between persons and persons, persons and things or things and things. Applicable for all products incorporating Radio-communication RF transmitters, transceivers and/or receivers (Telecommunication devices such as 2G, 3G and 4G fall under the telecommunication scope of the RCM requirements).


Typically wireless radio transmitters, transceivers and receivers sold and distributed through reputable manufacturers incorporated into products have already Radio-communication compliance testing for FCC compliance and CE mark Compliance. One of the the main standards used in Australia for Radio equipment and systems relating specifically to Short range devices is AS/NZS 4268. This standard has parallels with both FCC and CE certification’s and this allows in many instances reduced or in some instances no testing required (for the radio-communication component) with the evidence based upon available existing test reports. For further information please contact our parent company EMC Technologies. Short range devices includes technologies such as WI-Fi, Bluetooth, RFID, key fobs etc, but does not include 2G, 3G or 4G only products. Most products now incorporate more than one technology such as mobile phones, laptops etc.

Electromagnetic Radiation (EMR) or Electromagnetic Energy (EME)

Evidence of exemption or testing is required for all products incorporating wireless RF transmitters and or receivers. Assessment with the module fitted into the host if the unit has a transmitter that is not exempt based upon the usage (such as position of usage relating to head and torso of body), frequency and maximum RF output power. Products that usually required assessment include 2G, 3G and 4G telecommunication Technologies for products such as Mobile Phones, Smartphones. Testing or assessment to ACMA EMR Standard 2014 (same as EN62311) may be required, for further information please contact our parent company EMC Technologies.

Electrical Safety

Usually compliance to the Australian such as standards like AS/NZS 60950 – Safety of Information Technology Equipment (may apply depending on the product) is required. If the unit has a 2G, 3G or 4G telecommunication module installed safety testing is required, for further information please contact our parent company EMC Technologies.


By definition a Telecommunication is device the uses the transmission of signals by wire, radio, optical or other electromagnetic systems. Telecommunications Technical Standards for connection to an air interface of a Telecommunications Network apply for products that connect to a Telecommunications Networks. Products affected would include GSM, 3G and LTE products or products containing these technologies.


For 2G and 2.5G products the AS/ACIF S042.1 & AS/ACIF S042.3 – GSM Telecommunications Equipment standards would apply. Additionally AS/CA S002 Analogue interworking and non-interference requirements for Customer Equipment for connection to the Public Switched Telephone Network and AS/CA S003 Requirements for Customer Access Equipment for connection to a Telecommunications Network may apply.


For 3G (WCDMA, UMTS, HSPA) & 4G (LTE) products the AS/ACIF S042.1 & AS/CA S042.4 – IMT-2000 Telecommunications equipment standards would apply.


For further information please contact our parent company EMC Technologies.

To contact our parent company EMC Technologies regarding the Wireless integrated telecommunication modules for RCM electrical safety, EMR and telecommunication requirements, please visit their website and complete the quote form or contact them via the contact page on www.emctech.com.au

Finally as a cautionary general Public notice (consumer information) their may be legal implications for operating non-compliant communication devices within Australia as per the ACMA notice: bringing communication equipment from abroad into Australia.

If you require Electromagnetic Compatibility (EMC) testing your host product that incorporates Wireless integrated telecommunication modules for RCM compliance for Australia and New Zealand contact us and find out how we can help.

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