Regulatory Compliance Mark (RCM). Product Compliance for Australia & New Zealand

RCM Compliance Testing for Australia and New Zealand

Get an RCM approvals Quote Now!

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Supersedes: The C-Tick scheme was superseded and replaced during a 3 year transition period that ended in March 2016.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 these requirements, listed by the ACMA and ERAC is that the RCM logo will indicate compliance of a product with all applicable Australian regulatory requirements, namely:

  • Telecommunications
  • Radiocommunications
  • 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.

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 Compliance 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.

Low-risk Products

  • 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.

Medium-Risk Products

  • 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 switch-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.

High-Risk Products

  • A device described as ‘Group 2 ISM equipment’ in AS/NZS CISPR 11:2011. Examples 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 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. 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:

Class License

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 frequencies 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)

Penalties

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 with the following:

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 device is fixed installation at a specific location, the EME LN might not apply.

If Specific Absorption Rate SAR testing is required our parent company EMC Technologies offers accredited testing services.

Penalties

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 Australian rules are in the:

Some of these telecommunications standards involves specific network connectivity assessment to AS/CA S042.1 and S042.4. These standards are free to download from Communications Alliance website. Some of the referenced additional requirements 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 (AS/NZS 62368.1), Electromagnetic Compatibility (EMC) testing to EN 55032 or equivalent AU/NZS version and an EMR assessment to ARPANSA RPS3.

CE and FCC test reports can in most instances be used 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 Technologies our parent company provides ACMA RCM telecommunications services.

Penalties

If you supply a product that does not comply with the TLN, you might be committing an offense.

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.

Risk Level 2 – electrical equipment that is classified as medium risk and is defined in the AS/NZS 4417.2.A list of the current Level 2 equipment can be found here.

Risk Level 3 –electrical equipment that is classified as high risk and is defined in the AS/NZS 4417.2. A list of the current Level 3 equipment can be found here.

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.

Playlist: How to get the Regulatory Compliance Mark RCM for Australia

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

How to get RCM approvals – Flow diagram

Flow diagram of how to get RCM compliance

EMC Bayswater takes no responsibility if any of the information provided is incorrect this is general guidance

RCM Checklist with links to external websites for further information:

  • After registration on the RCM database, you (The Supplier) will be provided with a copy of AS/NZS 4417 which outlines the use of the RCM.
  • If the equipment falls under the scope of EESS

Upload compliance folders for all types of level 2 and level 3 equipment

Or

Equipment declarations can also be recorded onto the RCM database

We have many more resources regarding RCM compliance for Australia and New Zealand. Further information about overseas reports, refer to our RCM overseas test report assessment page. Your product may also need other Australian approvals such as electrical safety. Through our parent company EMC Technologies we can arrange all other Australian approvals. This includes Electrical safety testing or SAR testing.

ACMA and ERAC arrangements

ACMA arrangements

  • Arrangements will apply to all suppliers.

The Regulatory Compliance Mark scheme does not affect testing, record-keeping and evidential requirements as set out in the relevant labelling notices.

ACMA – “RCM Registration Applicant Guide“. An example RCM Declaration of Conformity can be found here.

ERAC arrangements

The Regulatory Compliance Mark is the only compliance mark for products within the scope of the Electrical Equipment Safety System (EESS).

  • Suppliers must register on the new database and label applicable products with the RCM

Further information about the EESS is available from www.erac.gov.au/.

EMC Compliance, labelling and record keeping for the Regulatory Compliance Mark

ACMA – Australian Communications and Media Authority

The following text is from the Australian Communications and Media Authority’s (the ACMA) website with regards to EMC compliance for Australia and the original version of this can found on the ACMA website regarding EMC labelling requirements for Australia, a link is provided in the relevant section below.

“The Australian Communications and Media Authority’s (the ACMA) electromagnetic compatibility (EMC) regulatory arrangement specifies requirements for the supply of a wide range of electrical and electronic devices, vehicles and devices with internal combustion engines.

The purpose of the regulation is to minimise the risk of electromagnetic interference from products which may affect the performance of electrical devices or disrupt radio-communications services.

Prior to supplying a product to the Australian market, the supplier importer or Australian manufacturer) must ensure that the product meets applicable technical standards, labelling and record keeping requirements.

Step 1 – Comply with technical standards

All devices covered by the EMC regulatory arrangements must comply with an applicable technical standard. The Australian Communications and Media Authority’s (ACMA) website lists the applicable technical standards.

If a device is in the scope of one of the applicable standards listed in Part 2 (Product family and equipment standards) of the list, then that standard should be used as the applicable standard.

Should a device be in the scope of more than one of the listed standards, the supplier should choose the standard that more closely matches the primary function of the device.

If a device is not in the scope of any standards listed in Part 2, then the supplier must use one of the standards listed in Part 1 (Generic standards) of the list as the applicable standard.

Note: It is an offense under the Radio-communications Act 1992 to knowingly supply a non-standard device.

Step 2 – Labelling

Suppliers of devices (other than low risk devices) covered by the EMC regulatory arrangements must affix a compliance label to the device before it can be supplied to the market. Labelling of low risk devices is optional. A supplier will not be required to include supplier identification on devices labelled with the RCM.

The compliance label comprises two parts – a compliance mark and information to identify the supplier of the device. The compliance label indicates that the device complies with an applicable standard and provides a traceable link between a device and the supplier responsible for placing it on the Australian market. (See also EMC labelling requirements for Australia).

Step 3 – Record keeping

In addition to compliance with mandatory technical standards and labelling, suppliers of devices covered by the EMC arrangements are required to maintain documentary evidence (compliance records) to demonstrate that the device complies with the regulatory arrangements.

The level of evidence required to be maintained by the supplier varies depending on the risk of interference that may be expected from the device – high risk, medium risk and low risk (see also the Compliance levels fact sheet).

All compliance records must be in English and may be kept in electronic form. Records must be kept for five years after the device ceases to be supplied in Australia.

The compliance records must be made available to the ACMA within 10 working days if requested”.

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.

GET A QUOTE