RCM Part 1: ACMA System For RCM

RCM Part 1: ACMA System For RCM

Summary

This scheme is a process for registration of suppliers of electrical and electronic equipment that are manufactured in Australia or imported into Australia.  A shared national database has been designated for all supplier registration and is jointly used by the ACMA, the Electrical Regulatory Authorities Council (ERAC) and Radio Spectrum Management (New Zealand).

The new process for ACMA replaces the previous ACMA registration process for Australian suppliers, which included the allocation of an ACMA Suppliers Number and the use of the C-Tick and A-Tick. There are no changes to the testing and record-keeping requirements applicable to devices subject to ACMA arrangements for telecommunications, radiocommunications, EMC and EMR. Testing, compliance folders and Declarations of Compliance prepared by the Australian manufacture or importer still apply.

From an ACMA perspective, the RCM indicates a device’s compliance with applicable ACMA technical standards - that is, for telecommunications, radiocommunications, EMC and EME. A supplier will not be required to include supplier identification on devices labelled with the RCM.

National Database

A supplier who intends to supply devices that are required to be labelled under an ACMA Labelling Notice must register on the National Database as a ‘responsible supplier’.

If registering only for ACMA purposes, a supplier must ensure that only the ACMA acknowledgement is checked.

A supplier who is registering only for ACMA purposes is not able to enter any equipment details.

Devices that were labelled with the C-Tick or the A-Tick can continue to be supplied until labelled stock has been exhausted but must change to RCM label by the 1st March 2016.

Fees for Registration

When you register on the ERAC database, you will be asked for equipment details. You'll then have an option to choose registration for the purposes of complying with the ACMA and/or its electrical equipment safety system (EESS) requirements.

If you elect for ACMA only (i.e. your device is not subject to electrical safety requirements), there is no charge for registration.

What is a supplier?

In broad terms, a supplier from the perspective of the ACMA is an Australian entity (person or company) that supplies equipment to the Australian market that is scoped by one or more of the ACMA's regulatory arrangements.

A supplier can be (as defined by the ACMA):

  • an importer in Australia with an ABN
  • a manufacturer in Australia with an ABN
  • an Australian agent of a manufacturer or importer who is acting on their behalf - an agent must have an ABN

The arrangements only apply to equipment intended for supply to the Australian market.

There are three categories of Suppliers from an ACMA viewpoint:

  1. First-Time Supplier
  2. Existing Supplier
  3. Agent

First-Time Suppliers

First-time suppliers are suppliers new to the arrangements. They are supplying goods subject to one or more of the arrangements for the first time (post 1st March 2013) and were never issued a Supplier Code Number (SCN) by the ACMA or Standards Australia.

Under the new single compliance mark scheme, the Regulatory Compliance Mark (RCM) becomes the compliance label. First-time suppliers can only label with the RCM as the compliance label. The C-Tick and A-Tick are not available to first-time suppliers as compliance marks.

First-time suppliers must register on the National Database operated by the Electrical Regulatory Authorities Council (ERAC) before using the RCM. To register on the database, the supplier must provide an ABN (Australian Business Number) and other details. A supplier cannot register without an ABN.

The new single compliance mark is used to indicate compliance with both ACMA arrangements and electrical safety arrangements. Some devices only need to meet ACMA arrangements and do not need to meet electrical safety arrangements.

Existing Suppliers

Existing suppliers include anyone registered with the ACMA to use the A-Tick or C-Tick compliance marks, or who are registered with Standards Australia to use the RCM. These suppliers would have first supplied goods prior to 1st March 2013. These suppliers were issued with a Supplier Code Number (SCN) by the ACMA or Standards Australia.

Existing suppliers will have used a 'compliance label' that comprised one of the compliance marks and 'supplier information' that identified the supplier. Supplier information included the SCN, ABN, or a number issued by Standards Australia under AS/NZS 4417 (where the RCM was the compliance mark).

Existing suppliers can continue to label equipment in the same manner (A-Tick or C-Tick), but must move to the single compliance mark by 1st March 2016.

Under the new scheme, there is no need to affix supplier identification to the equipment alongside the RCM as previously required. There is nothing stopping the continued appending of supplier information if it suits business purposes, but it is not a requirement under the new arrangement (existing suppliers using the RCM under the old arrangement must continue to include supplier identification until they have registered on the national database).

ACMA Agents

An agent can act on behalf of an Australian importer or manufacturer in regard to its obligations under one or more of the ACMA arrangements. When given authority (Agency Agreement), an agent can apply appropriate compliance labels, complete the Declaration of Conformity (DoC) in relation to an item, arrange for equipment testing, and compile and hold compliance records.

Agents can be independent consultants who regularly act as agents of Australian importers or manufacturers. Agents can also be an importer of a specific line of products that is also acting as an agent for other importers supplying that identical product.

A person acting on behalf of an international manufacturer that does not have a presence in Australia is not considered an agent but will be considered to be the importer for the purposes of the ACMA arrangements.

Responsibility for failure to meet the regulatory arrangement will ultimately lie with the importer or manufacturer.