The fundamentals of Australian RCM compliance

By Nisha Lad, Compliance Project Manager at C-PRAV Labs & Certifications
Monday, 11 September, 2023

The fundamentals of Australian RCM compliance

Generally, standards and regulations have their own classifications and levels for electronic products.

It can be confusing to some readers, especially someone in the initial phase of their career in product testing and compliance. Here, Nisha Lad, Compliance Project Manager at C-PRAV Labs & Certifications, explains the differences in classes and levels in RCM compliance.

EMC classes: (Class A and Class B) as defined in most EMC Standards

In the context of EMC (electromagnetic compatibility), Class A and Class B refer to two different levels of electromagnetic emissions limits for electronic devices.

Class A: Devices that comply with Class A standards are typically intended for use in industrial environments, where there are fewer restrictions on electromagnetic interference. Class A devices are expected to have higher emission levels of electromagnetic emissions compared to Class B devices. Class A compliant devices are not meant to be used in a Class B environment.

Class B: Devices that comply with Class B standards are intended for use in residential, commercial and business environments, where there are stricter regulations on electromagnetic interference. Class B devices are required to have a higher level of electromagnetic interference suppression compared to Class A devices to minimise their impact on other electronic systems operating in their close vicinity. Class B compliant devices can be used in a Class A environment.

Under the Australian Communications and Media Authority (ACMA), most electronic products are regulated to mandatorily comply with prescribed standards for EMC, telecom, radio and telecom safety.

Electrical safety classes (Class 1, Class 2 and Class 3)

Class 1, Class 2 and Class 3 are classifications used to define different levels of electrical safety for electrical/electronic equipment.

Class 1: Class 1 equipment is considered the most basic level of electrical safety. It includes devices that have basic insulation and rely on a protective earth connection (grounding) for user safety. This class of equipment typically has a three-wire power cord, with two conductors for line and neutral, and the third conductor for grounding. Class 1 equipment must be connected to a properly grounded electrical system to ensure safety.

Class 2: Class 2 equipment, also known as double-insulated equipment, provides an extra layer of protection against electric shock. Unlike Class 1, Class 2 equipment doesn’t rely on a protective earth connection for safety. Instead, it incorporates additional insulation or other means of protection to prevent electric shock hazards. This class of equipment is commonly identified by a double-box symbol 回 on its labelling. Class 2 equipment is designed to be safer even if the grounding is faulty or absent.

Class 3: Class 3 equipment represents the lowest level of risk among the three classes. It includes low-voltage equipment that operates at extra-low safety voltages (typically 50 VAC or 120 VDC or less). Class 3 equipment is often powered by a separate power supply that converts higher voltage levels into these safe extra-low voltages (SELV). While Class 3 equipment reduces the risk of electric shock, it is still important to handle these devices properly to maintain safety.

In-scope electrical equipment levels (Level 1, Level 2 and Level 3) in Australia

If you are selling electrical equipment in Australia, it is important to comply with the regulations set by the regulator coordinator ERAC (Electrical Regulator Authority Council of Australia). The regulations set forth by various individual states/territories/NZ is called the Electrical Equipment Safety System (EESS). The electrical equipment offered for sale is categorised as risk levels of Level 1, 2 or 3 so they are electrically safe with the aim of enhancing consumer safety.

EESS classifies electrical equipment into two categories based on the environment of use ie,

  • In-scope electrical equipment
  • Not in-scope electrical equipment

In-scope electrical equipment

The EESS applies to in-scope electrical equipment, which is defined as equipment:

  • rated at a voltage greater than 50 VAC RMS or 120 V ripple-free DC
  • rated at a voltage less than 1000 VAC RMS or 1500 V ripple-free DC
  • designed or marketed as suitable for household, personal or similar use.

If your electrical equipment falls under in-scope electrical equipment, to legally sell electrical equipment under the EESS, the following applies to household electrical equipment (eg, consumer devices, domestic appliances etc):

In-scope electrical equipment Equipment registration in the EESS Evidence of compliance with the relevant standard Compliance Folder Certificate of suitability Certificate of conformity Marked with the RCM
Level 1 Voluntary Mandatory Highly recommended Voluntary N/A Mandatory
Level 2 Mandatory Mandatory Mandatory Voluntary N/A Mandatory
Level 3 Mandatory Mandatory Highly recommended N/A Mandatory Mandatory

Level 3 equipment has the most stringent safety rules to follow while Level 2 is less onerous, and Level 1 is voluntary but the equipment must still be electrically safe for consumer use.

Not in-scope electrical equipment

If your electrical equipment is classified as not in-scope electrical equipment, here’s what you need to know to legally sell it under the EESS:

  • Certification and ERAC registration: Getting certification and registering with ERAC (Electrical Regulatory Authorities Council) is voluntary.
  • Essential safety criteria: Your equipment still needs to meet the essential safety criteria specified in the AS/NZS 3820 standard, regardless of certification and registration. This standard outlines the fundamental safety requirements for electrical equipment in Australia and New Zealand.
  • Accreditation testing: You are not required to conduct accreditation testing for your equipment.

Regardless of the scope, all devices must be electrically safe before they are sold and during usage. However, for level 1 and not in-scope equipment, demonstration of the equipment’s safety is on the onus of the manufacturer or supplier. It is strongly recommended that there is evidence of compliance with the relevant safety standard.

ACMA compliance levels (Level 1, Level 2 and Level 3)

ACMA stands for the Australian Communications and Media Authority, which is the regulatory body responsible for the regulation of telecommunications and radiocommunications in Australia. ACMA compliance refers to adhering to the rules, regulations and standards set by the ACMA. Regardless of the prescribed regulations or compliance levels set by the ACMA, no electronic product in its operation must cause interference to other products working in its vicinity. ACMA holds the right to pull such a product off the market if it is causing interference.

ACMA has established different compliance levels to categorise the regulatory requirements based on the type of service or activity being regulated. Here’s an overview of ACMA compliance levels:

Level 1 compliance:

  • Level 1 compliance is typically associated with low-risk devices.
  • These devices may not be required to undergo any testing or evaluation; however, the product must comply with the standards and not cause interference.
  • For Level 1 compliance, you need to submit a Self-Declaration of Conformity (SDoC) stating that the product complies.
  • Although testing is not mandatory, you have the option to obtain a test report from a test lab as evidence of proof to demonstrate compliance. Accredited test reports to ISO 17025 are not mandatory.

Level 2 compliance:

  • Level 2 compliance applies to medium-risk devices.
  • The manufacturer or supplier must maintain a compliance folder, technical construction file, SDoC and test reports are necessary.
  • Accredited test reports to ISO 17025 are not mandatory.

Level 3 compliance:

  • Level 3 compliance pertains to high-risk devices.
  • The manufacturer or supplier must maintain a compliance folder, technical construction file, SDoC and accredited test reports to ISO 17025 are necessary.
  • In addition to the existing reports you may already have, it is possible that some local testing also may be required. This depends on the product and further investigation is required to determine if any additional gap testing is required.

Energy efficiency: an additional requirement applicable to some products

When it comes to energy efficiency, there are certain regulations and standards that govern the energy performance of products. Here are the key points:

Greenhouse and Energy Minimum Standards (GEMS) Act: The GEMS Act, established in 2012, along with the GEMS regulator, oversee energy efficiency. They ensure that products meet specific requirements to conserve energy.

Minimum Energy Performance Standards (MEPS) and Energy Rating Labelling (ERL): Products regulated under the GEMS Act must adhere to MEPS, which set the minimum energy performance levels they must meet. Additionally, these products need Energy Rating Labels that display their energy efficiency rating. In Australia and New Zealand, several products have mandatory MEPS, and they must be registered on the GEMS portal to ensure compliance with energy efficiency standards.

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