Regulatory Compliance Mark (RCM). Product Compliance for Australia & New Zealand
RCM Compliance Testing for Australia and New Zealand
C-Tick and A-Tick were replaced by the Regulatory Compliance Mark
A brief description of RCM compliance testing, approval & certification
Expansion: Regulatory Compliance Mark
Effective region: Australia and New Zealand
Regulator: Australian Communications and Media Authority (Australia) and Radio Spectrum Management Group (RSM) (New Zealand).
Legal status: Mandatory
AC Mains supply: 230VAC 50Hz
Supersedes: The C-Tick scheme was superseded and replaced during a 3 year transition period that ended March 2016.
Please note: All customers should now have transitioned from the C-Tick scheme to the Regulatory Compliance Mark scheme.
Countries requiring the Regulatory Compliance Mark approvals
Regulatory Compliance Mark labelling is mandatory for certain product groups within Australia and New Zealand.
Legal Implications of the Regulatory Compliance Mark scheme
All suppliers must register on a new national database and there is no longer a requirement to include supplier identification on product labelling.
Approval and compliance requirements
C-Tick and A-tick compliance marks were phased out and ended in March 2016. The old C-Tick and A-tick were consolidated with one single compliance mark, known as the RCM or Regulatory Compliance Mark. The new Electrical Regulatory Authorities Council (ERAC) Electrical Equipment Safety System (EESS) commenced on the same date. The result of thesy requirements, namelom the ACMA and ERAC is that the RCM logo will indicate compliance of a product with all applicable Australian regulatory requirements, namely:
- Electromagnetic compatibility (EMC)
- Electromagnetic energy (EME) / Electromagnetic Radiation (EMR)
- Electrical safety
For more information for each of the 5 categories click the relevant tab below.
- Electromagnetic Compatibility (EMC)
- Electromagnetic Energy (EME)
Electronic and electrical product Electromagnetic Compatibility compliance is mandated under Australian legislation (Australian law) i.e. the Radiocommunications Act 1992. For more information on the ACMA RCM Electromagnetic Compatibility (EMC) requirements please visit our dedicated consumer product page.
Under the ACMA Regulatory Complance Mark mandatory evidence of EMC compliance to the relevant ACMA EMC standards list (electromagnetic compatibility standards) and labelling (Labelling (Electromagnetic Compatibility) Notice 2017) is required.
Products must be compliant with the relevant applicable accepted standard. The ACMA has a published an EMC standards list that includes all recognised standards. These standards may include specific product standards for certain types of products. Alternatively, if a product standard does not apply, a generic standard could be used. Based upon the intended typical EMI environment the product will be used in. Typically only EMC emissions compliance evidence is required (excluding harmonics & flicker, EN 61000-3-2 and EN 61000-3-3). However immunity testing is recommneded to ensure a reliable product. Some immunity testing such may be required under different legislation such as safety testing requirements.
The ACMA utilize product classification levels for products within the EMC scope.
- A device that is not a medium-risk or high-risk device
- A battery‑powered device is not a medium-risk device unless the ACMA has declared the device to be a medium risk device under subsection. A battery‑powered device is a device that is not capable of being connected, directly or indirectly, to an external power supply. This includes USB charging or USB powered products.
- EMC Benign products, these are products that inherently don’t produce EMI such as passive components.
- The ACMA may include specific devices that may be listed as a medium or high risk. So any listed device as such becomes a medium or high-risk device.
Compliance level 1—low risk device evidence
There are no additional requirements for a low risk device that complies with an applicable standard.
- A device that is not a high-risk device
- A device is a medium risk device if it is not a high risk device and contains 1 or more of the following:
(a) a switch mode power supply;
(b) a transistor switching circuit;
(c) a microprocessor;
(d) a commutator;
(e) a slip‑ring motor;
(f) an electronic device operating in a switching mode or a non‑linear mode.
- A battery‑powered device that has been declared by the ACMA as a medium risk device.
Compliance level 2—medium risk device evidence
For a medium risk device, the supplier must establish that the device complies with an applicable standard by:
(a) obtaining a test report from a testing body; or
(b) obtaining a technical construction file.
- A device described as ‘Group 2 ISM equipment’ in AS/NZS CISPR 11:2011. Eaxamples including microwave ovens, electrical welders etc.
Compliance level 3—high risk device
For a high risk device, the supplier must establish that the device complies with an applicable standard by:
(a) obtaining an accredited test report from an accredited testing body; or
(b) obtaining a technical construction file.
Only products that fall under Medium or High-risk require evidence of compliance. Either through test reports or technical construction file (TCF). Showing the device complies with an applicable technical standard. Responsible suppliers must register on the National Database which is the foundation of the RCM system. If a responsible supplier wishes to use the RCM logo on a level 1 product then a declaration of conformance is required. Products incorporating Radiocommunication modules i.e. RF transmitters and receivers such as Bluetooth, WiFi and so on, require compliance under section 162 of the Radiocommunications Act 1992.
Penalties for non-compliance
Penalties for breaching the Act i.e. non-compliance can reach up to AUD$18,000. A breach of compliance may be considered as:
- Supplying a product that has no RCM label (if applicable)
- Applying a label before complying with all EMC LN rules
- Not keeping records, i.e. description of the product, test reports, declaration of Conformity, etc.
In Australia, to use a radiocommunications device you require a licence. For more information about ACMA RCM Low interference potential devices (LIPD) Radiocommunications testing for Australia visit our dedicated Radio testing page.
The details of the madatory RF transceiver, transmitter and reciever requirements fall under the Australian Radiocommunications Act 1992. The definition of radiocommunication is:
(a) radio emission; or
(b) reception of radio emission;
for the purpose of communicating information between persons and persons, persons and things or things and things. So this does not include inductive charging loops etc. unless they also embed data within the signal, example smart charging.
There are there three main types of Radiocommunication licesnes:
Types of licenses:
- Apparatus Transmitter licenses (You require licence to use a transmitter)
- Includes the following licenses: Aeronautical licence, Aircraft licence, Amateur apparatus licence, Area-wide licence, Broadcasting licence, Defence licence, Earth licence, Fixed licence, Land mobile licence, Low Power Open Narrowcasting (LPON) licences, Maritime coast licence, Maritime ship licence, Outpost licence, public telecommunications service, Radiodetermination licence, Scientific licence, Space licence, Receiver licences, Defence receive licence, Earth receive licence, Fixed receive licence, Major coast receive licence, Space receive licence
- Class license (Shared frequency allocation, no license)
- Includes the following class licenses: 27 MHz handphone stations, Aircraft and aeronautical mobile stations , Body scanners , Cellular mobile telecom devices, Citizen band radio stations, Communication with a space object, Cordless communications devices, Emergency locating devices, Intelligent transport systems, Low interference potential devices (LIPD), Maritime ship station – 27 MHz and VHF, Overseas amateur visiting Australia, Public safety and emergency response, Radio-controlled models, Radio navigation satellite service.
- Spectrum Class (Through the ACMA the usage can be gain by auction, tender, set price or negotiation)
- A spectrum licence lets you operate a range of radiocommunications devices. You can only operate in the area and frequency range your licence allows.
We will focus on the Class licence as this is what most products fall under, technologies that fall with the class Low interference potential devices (LIPD) include:
You don’t need to apply for a class licence or pay any fees.
But you must follow all the rules in the:
Low interference potential devices (LIPD) class licence lets you use some short-range devices on shared frequencies. All users operate on shared frequencie and can include devices:
wireless microphones, garage door openers, telecommand for drones, radars including automotive, home detention monitoring equipment, personal alarms, ultra-wideband transmitters, infrared equipment, video sender transmitters, radiofrequency identification (RFID), barcode readers.
The radio-controlled models class licence is for models (such as model ships or planes) that you control with radio frequencies.
Technologies can include the following examples:
- Radio-frequency identification (RFID) (125kHz, 13.56MHz etc.)
- Door openers (433MHz)
- LoRa, SigFox & Z-Wave (915MHz)
- Bluetooth Classic (all versions) and Bluetooth Low Energy (BLE) Transceivers (2.4GHz)
- Zigbee Transceivers (2.4GHz)
- Wi-Fi Transceivers (2.4GHz and 5GHz)
If you supply a product that does not comply with the EME LN, you might be committing an offence.
Penalties for breaching the Act i.e. supplying or using a non-compliant device can include up to:
$270,000 for having or supplying a non-standard product (i.e. non compliant with EME LN)
$18,000 for supplying a product that has no RCM label, applying the RCM label before complying with all EME LN rules, or not keeping records
In Australia, to use a radiocommunications device you require a licence. The details of the mandatory RF transceiver, transmitter and receiver requirements fall under the Australian Radiocommunications Act 1992. The definition of radiocommunication is:
(a) radio emission; or
(b) reception of radio emission;
for the purpose of communicating information between persons and persons, persons and things or things and things.
To ensure the Electromagnetic Energy (EME) is at prescribed safe levels for people the Australian Laws exist, which also as per the Radiocommunications requirements fall under the Australian Radiocommunications Act 1992. And require compliance to the following:
- Radiocommunications (Compliance Labelling – Electromagnetic Radiation) Notice 2014 (EME LN) made under section 182 of the Act
- Radiocommunications (Electromagnetic Radiation-Human Exposure) Standard 2014 (human exposure standard)
For many technologies under the Low interference potential devices (LIPD) class licence testing to show compliance is not usually required. EMC Bayswater can determine is your transmitter is exempt from further investigation i.e. SAR testing, EMR meter etc. due to the low RF power (valid trustworthy radio compliance test report required). If your the device is fixed installation at a specific location, the EME LN might not apply.
If Specific Absorbtion Rate SAR testing is required our parent company EMC Technologies offers accredited testing services.
If you supply a product that does not comply with the EME LN, you might be committing an offence.
Penalties for breaching the Act include up to:
- $270,000 for having or supplying a non-standard product (non-compliant with EME LN)
- $18,000 for supplying a product that has no RCM label, applying the RCM label before complying with all EME LN rules, or not keeping records
All telecommunications equipment connecting to an Australian telecommunications network must be RCM compliant under the Australian Telecommunications Act 1997.
Telecommunications equipment regulation applies to the following type of products:
- Customer equipment or customer cabling
- may connect to a telecommunications network or facility in Australia (3G, 4G 5G, etc)
- are at the customer’s place (for example, a house or office) rather than with the service provider
- It may also include telephone handsets, TV set-top boxes, cable plugs, and sockets
The applicable Austrlian rules are in the:
- Telecommunications (Labelling Notice for Customer Equipment and Customer Cabling) Instrument 2015 (TLN)
- telecommunications standards
Some of these telecommications stanards involves specific network connectivity assessment to AS/CA S042.1 and S042.4. These standards are free to download from Commuications Alliance website. Some of the refernced additional requirments may include Radiated Spurious Emissions (RSE) testing to EN 301 908-1 and FCC Part 22 (S042 sub requirements), IP testing to AS/NZS 60950.1, Electrical safety, Electromagnetic Compatibility (EMC) testing to EN 55032 or equiveanlt AU/NZS version and an EMR assessment to ARPANSA RPS3.
CE and FCC test reports can in most instances be used to in part of the compliance process. This includes radio test reports to standards such as EN 301 908-1, EN 301 908-2, EN 301 908-13 and FCC Part 22 for cellular modules.
EMC Technologiesour parent company provides ACMA RCM telecommunications services.
If you supply a product that does not comply with the TLN, you might be committing an offence.
Penalties for breaching the Act can reach up to:
- $18,000 under section 413
- $21,600 (for example, for connecting a product that has no label to a network or facility without permission)
Responsible suppliers must determine if the device falls under the in-scope electrical equipment. A product that falls under this scope means the supplier must register on the EESS database. Certain products are “prescribed or declared articles”. These products must have tested electrical safety approvals under the RCM scheme.
Our parent company EMC Technologies offers a NATA and A2LA accredited electrical safety testing.
In-Scope Electrical Equipment
The EESS aims to increase consumer safety through regulating household electrical equipment. The term “in-scope” is defined in law and means electrical equipment that is:
- rated at a voltage greater than 50 V AC RMS or 120V ripple-free DC; and
- rated at a voltage less than 1000V AC RMS or 1500V ripple-free DC; and
- is designed or marketed as suitable for household, personal or similar use.
It is immaterial whether the equipment is designed or marketed for commercial or industrial purposes as well as for household use. If Regulatory Authorities (RAs) claim that an item is in-scope , it will be taken that way unless the Responsible Supplier can prove otherwise.
Risk Levels – Definition
A feature of the EESS is the provision of a more proactive risk based approach to regulating electrical equipment. The EESS provides for in-scope electrical equipment to be classified into three levels:
Risk Level 1 – electrical equipment that is classified low risk or unknown risk and is any in-scope electrical equipment not classified as Risk Level 3 or Risk Level 2.
Not In-scope Electrical Equipment
The EESS is only intended to capture electrical equipment that is for household, personal and similar use.
Electrical equipment exclusively for commercial, industrial, medical, extra low voltage (operating below 50V AC RMS or 120V ripple-free DC) and high voltage (operating above 1000V AC RMS or 1500V ripple-free DC) is defined as not in-scope.
Responsible Suppliers of electrical equipment that is not in-scope under the EESS definition, do not have to register, or register equipment in the EESS Registration Database.
Note: The supplier of electrical equipment that is not in-scope still has responsibility to ensure the equipment is electrically safe. This is achieved by meeting the essential safety criteria of AS/NZS 3820, essential safety requirements for electrical equipment which requires the supplier to hold evidence of compliance to the relevant standard.
Examples of equipment which is not in-scope could be a commercial bakery oven, cash register or mobile phone (please note that the mobile phone ‘charger’ is in-scope equipment Level 3 under – Power supply or charger).
More information for Not In-Scope electrical equipment safety criteria please see here.
Note: Not in-scope electrical equipment may be required to comply with the Australian Communications and Media Authority (ACMA). For more information on ACMA’s requirements contact ACMA at www.acma.gov.au
RCM compliance certification & approvals requirements
EMC Bayswater offer accredited compliance services including Radiocommunications and EMC testing, certification and approvals.
Watch our “How to get” the Regulatory Compliance Mark product compliance for Australia video lesson/tutorial.
Click on one of our useful tabs for more information!
Why use EMC Bayswater for your compliance approvals?
If your device does not comply, we can offer compliance engineering help (consulting, R&D). If your device does not comply, we can offer compliance engineering help (consulting, R&D). For extra information on EMC testing failures and fixes visit our blog section. Also about how we can help using consultancy and pre-compliance testing to achieve compliance.
We offer excellent customer support from a friendly team. Providing great value for high-quality testing and test reports. We provide a fast turnaround. Helping your product get to market with the shortest possible lead time. EMC Bayswater has accreditation for many of the mandated Australian EMC standards. In the case of a dispute, NATA endorsed accredited testing is favoured by the ACMA over others.
Please visit our Electromagnetic compatibility, EMC testing page for the types of types of EMC testing required.
Flow diagram and steps on how to get the RCM mark
ACMA and ERAC arrangements
EMC Compliance, labelling and record keeping for the Regulatory Compliance Mark
ACMA – Australian Communications and Media Authority
Overseas report reviews and other compliance requirments
Importing products for sale/distribution in Australia.
Who is responsible for product compliance?
- Manufacturers in Australia of electrical and electronic products, and vehicles and devices with internal combustion engines
- Importers in Australia of electrical and electronic products, and vehicles and devices with internal combustion engines
- Authorised agents in Australia acting on behalf of manufacturers or importers of electrical and electronic products, and vehicles and devices with internal combustion engines
The local supplier accepts total responsibility for device conformity. Thus they need to make a commercial decision on the level of testing required
I am importing a product from overseas for sale in Australia, do I need proof of RCM compliance?
Yes, you must have proof in the form of a full formal EMC test report(s) to an EMC standard(s) accepted by the ACMA.
Note: Compliance certificates or Declaration of Conformity statements (DoC’s) are not acceptable as proof of RCM compliance
Can I use an overseas test report for proof of compliance?
A test report from an overseas test laboratory can be used to demonstrate compliance. Provided a suitable ACMA accepted standard is applied. The report must prove testing has been performed correctly. The report should also clearly identify the product.
Acceptable RCM EMC standards are listed on the ACMA website: ACMA EMC Standards list.
Test reports from overseas laboratories must be written in English and must be original or certified copies.
How do I know the report and the information within are acceptable?
Adequate technical knowledge of the applicable ACMA accepted RCM EMC standards is essential. EMC Bayswater regularly performs reviews of overseas EMC test reports. We issue a detailed report of our findings highlighting any required actions/recommendations. We also detail other RCM housekeeping requirements.
What happens if an existing EMC test report is not available? Or is not acceptable as proof of RCM EMC compliance?
The product may need testing to meet the required Australian RCM EMC standards. This may involve complete or partial RCM testing. The scope of testing depends on the report assessment findings.
Is the cost of technical review worth it?
Having experts review your documents ensures peace of mind. Helping to ensure your products meet the requirements set by the ACMA is essential. The banning of sales, fines or product recalls is possible. Report assessment can prevent this before importation.
Are test laboratories, competency and test reports around the world the same?
Unfortunately no!! There is a major discrepancy in the standard of testing services. The technical understanding between testing laboratories worldwide varies. Many overseas test reports are rejected due to insufficient evidence to prove compliance. Only an accredited laboratory can provide 100% peace of mind.
I have a valid report, what now?
You must register on the ACMA supplier database. Fill out a Declaration of Conformity statement (in most cases). Label the product with the RCM logo. Keep your documents in a compliance folder. The folder may contain any relevant product information such as brochures or datasheets. Have the records available in case of an ACMA audit.
Why choose EMC Bayswater to review EMC test reports
The ACMA suggests that suppliers check the accreditation status of a laboratory. Not all laboratories hold accreditation for all standards and parts. An accredited testing laboratory has been assessed by an independent agency as competent. This may include providing accredited EMC testing services. The local accreditation agency in Australia is NATA (National Association of Testing Authorities). EMC Bayswater is accredited for the majority of RCM EMC testing standards. We have a dedicated team of experienced, knowledgeable qualified engineers. We ensure the highest level of service to our customers with short lead teams. Our facility incorporates modern equipment and a friendly environment. The ACMA suggest using a NATA laboratory as a risk-free investment.
For further RCM information such as using overseas reports etc please refer to our EMC test report validity assessment service page.