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Australian EMC Regulation and Routes to ComplianceThe C-tick scheme is standards based and reliant on self-declaration of conformity by equipment suppliers.
This article outlines the EMC
regulations in Australia and the available
routes to compliance. It details the scope
of the regulations, the applicable standards,
and the compliance requirements for various
product categories. The testing and technical
construction file routes to compliance are
explained, as are labeling requirements
and enforcement mechanisms.
Overview of Australian EMC Regulations In July 1997 the Spectrum Management Agency and Austel merged to form the ACA, the single regulatory body now responsible for administering product compliance regulations in the areas of EMC, radiocommunications, and telecommunications. The ACA has moved away from the premarket approval approach to a scheme that features minimal regulator responsibility for the approval of products. The new self-declaration scheme facilitates efficient and unimpeded access to the Australian market, without the processing delays and filing fees prevalent under traditional premarket approval systems. It does, however, place primary responsibility for product compliance directly on the supplier. On January 1, 1997, compliance with the appropriate emission standards became mandatory for all equipment marketed for the first time for use in the commercial, light industrial, and residential environments. Products on the market prior to that date had until January 1, 1999, to be made compliant. On November 11, 1998, the legal instruments were changed in order to clarify the scope of the new regulatory scheme and to support its practical implementation. The new regulation mandated EMC standards without reference to the particular use environments, thus removing the problems associated with the previous regulation's specification of EMC environments (light industrial, heavy industrial, and so on). This made implementation of the EMC regulations easier by shifting the focus from the specification of particular products and environments to the applicability of the scope of some individual EMC standard. If a product comes under the scope of one of the mandated EMC standards and it is not specifically excluded from the EMC framework, it must comply. Compliance with the EMC regulations requires that the supplier placing the product on the Australian market declare that the product meets the applicable EMC standards. The declaration is to be supported by a compliance folder including test data or other evidence to support the claims of compliance. The product must be labeled with the C-tick mark and other information that is used to trace the supplier. Permission to use the C-tick mark must be obtained from the ACA before a supplier can legally apply it. Permission, granted in the form of a supplier code, is available only to residents of Australia. The ACA will recognize agents authorized by manufacturers in cases where the resident agent accepts the responsibility for compliance. The ACA supplier code, or other information that makes the identity of the supplier evident, must be used in conjunction with the C-tick on all products marketed by a supplier. The ACA uses this information to trace the responsible supplier if the compliance of a device is called into question or in the event of an audit. Mandatory EMC Standards. The ACA has addressed the problem of electromagnetic interference by implementing a standards-based regulation. All electrical and electronic products that fall within the scope of one of the mandated standards of the EMC framework, and that are not covered by the exemption provisions, must comply with the regulations. There are no mandatory immunity requirements except for medical equipment covered by the Therapeutic Goods Administration (TGA). The Australian EMC standards are derived from the internationally harmonized CISPR standards and are generally adopted by Standards Australia and Standards New Zealand as harmonized Australian/New Zealand standards (AS/NZS), sometimes with minor national deviations. In some cases, interpretations and variations in implementation of the standards may conflict with the requirements of other regulatory regimes, such as the FCC and the European EMC Directive. Retesting or "top-up" testing of products approved elsewhere may sometimes be necessary to ensure that the product has been fully tested to the Australian variations and at the Australian mains voltage of 240 V ac at 50 Hz. The ACA mandatory standards (with their international source standards in parentheses) are
It is important to note that not all EMC standards published as AS/NZS standards are mandated by the ACA into regulation. A product must comply with the EMC standard applicable at the time the product enters the market for the first time. If the particular EMC standard was modified within six months of the product's introduction to the market, then the previous version of the standard may be used. The standard applicable at the time the product is first marketed is applicable for the life of the product. There is no set date for withdrawal of superseded standards as is the case with the European EMC Directive. Whenever the product is modified, the new (current) standard applies. Exemptions. Equipment that falls within the scope of other regulatory bodies is exempt from the ACA EMC regulations. The Civil Aviation Safety Authority approves equipment fitted to aircraft. Equipment used by defense forces for military operations is under the purview of the Australian Department of Defense. The Department of Transport and Regional Services regulates design safety codes for road-registrable vehicles. EMC requirements modeled on the European Automotive Directive have been adopted by the Federal Chamber of Automotive Industries. However, aftermarket products intended for automotive applications are subject to the full provisions of the EMC regulations. And, lastly, all medical devices covered by the listing requirements of the TGA are exempt from the ACA EMC regulations. In general, equipment that falls under the scope of one of the mandated standards must comply unless it meets the exclusion criteria. Categories of products receiving general exclusion from the EMC regulations include
Other exemptions have come into existence as a result of legal interpretation of the CISPR standards. The EMC regulation has modified the scope of some standards so that some equipment is intentionally exempted from the compliance requirements. Equipment powered by three-phase mains supply, or by battery, and being governed by AS/NZS 1044 (CISPR 14) or AS/NZS 4051 (CISPR 15) is exempted from the EMC regulations (that is, only single-phase equipment under these standards must comply). The intention of this exemption was to exclude industrial machines and simple battery-operated devices, such as toys and domestic appliances. Another special-case exemption involves the generic emission standard, AS/NZS 4251.1 (EN 50081-1/IEC 61000-6-3). In general, products not covered by the scope of a family standard or a product-specific standard are covered by the generic standard. According to legal advice received by the ACA, battery-operated equipment does not fall under the scope of the generic emission standard; hence, it is exempt from the regulations. Declaration of Conformity.
The Australian regulations are based on
the manufacturer's declaration of conformity
(DoC). Once compliance is established, and
prior to marketing, a DoC with a sound and
justifiable basis is prepared. The DoC is
placed in a compliance folder, and the C-tick
is then affixed to the product. At this
stage there is no need to submit products
or any documentation to the ACA for testing
or certification. A test report accredited
by NATA (National Assocation of Testing
Authorities, Australia) has national and
international recognition. The ACA will
always be satisfied with a bona fide NATA
report or one produced by a mutual recognition
agreement (MRA) partner.
Accredited Testing Although the previous system of
Austel permits has been changed to a DoC
system, NATA- or MRA-accredited testing
remains compulsory. All devices connecting
to the telecommunications system must be
tested for compliance to the appropriate
limit under AS/NZS 3548. As of January 1,
1998, Class A limits apply to all devices
to be used in a commercial or industrial
environment, and Class B limits apply to
devices used in a domestic or residential
environment. There are some differences
in the compliance and marking requirements
for telecommunications and terminal equipment
(TTE), which are covered under the "Labelling
Instrument" section of the Telecommunications
Act 1997. The C-tick is not used for TTE
devices. The A-tick must be applied once
the additional requirements of the labeling
notice have been met.
Items of equipment covered under AS/NZS 2064 (CISPR 11) as Group 2 ISM devices are considered high risk and must be declared only on the basis of a NATA or NATA MRA partner–endorsed report. The C-tick Mark. Use of the C-tick mark is regulated under a legal instrument issued in September 1998, under Subsection 183 of the Radiocommunications Act 1992, "Radiocommunications (C-Tick Mark) Determination 1998," which established the design of the C-tick mark and specified it as a protected symbol under the regulations. The determination regulates the use and application of the C-tick mark for products under the scope of the Radiocommunications Act, including products subject to the EMC requirements. It is an offense to use the C-tick mark without first registering as a supplier or to use it on products that are not covered by the EMC regulations. The C-tick mark may be used in advertising, packaging, displays, warranties, and user instructions to indicate that a product complies with applicable standards. It may also
Compliance Requirements Compliance Levels. The Australian EMC regulation defines three levels of compliance requirements based on the expected risk of interference to radiocommunications and telecommunications arising from use of the product. Compliance Level 1. Level 1 covers low-risk devices that are unlikely to generate emissions with the potential to cause interference. Examples are low-EMI-risk squirrel-cage motors, simple relays, and basic ac-to-ac transformers. Conformance assessment procedures are not mandatory, and the C-tick can be applied without necessarily performing formal testing. Responsibility for proof of compliance, however, still rests with the supplier, who must sign a DoC, establish a compliance folder, and apply the C-tick. Compliance Level 2. Level 2 devices are those not qualifying for Level 1 (low risk) or Level 3 (high risk). They are considered to have medium potential to cause interference. Level 2 devices include most of the electrical devices covered by the mandated (CISPR) standards except for high-risk TTE devices covered by AS/NZS 3548 (CISPR 22) and Group 2 ISM products within the scope of AS/NZS 2064 (CISPR 11). While NATA or MRA reports are not mandatory, the ACA views provision of a test report from a laboratory accredited for the particular standard as constituting a high-confidence, low-risk approach to compliance. If the compliance of the product should be challenged, the ACA will request the testing of three samples by a NATA-accredited laboratory at the supplier's expense. For documentation, the supplier must establish a compliance folder that includes a signed DoC, test reports, and a technical description of the product. Compliance Level 3. Level 3 requirements encompass high-risk devices likely to generate emissions with a high potential to cause interference with communications. This compliance level currently applies to only two categories of equipment: Group 2 ISM devices under AS/NZS 2064 (CISPR 11) and telecommunication products requiring A-tick under AS/NZS 3548 (CISPR 22). Because it requires the highest confidence of compliance, a NATA or NATA MRA-partner conformance report is mandatory. The supplier must establish a compliance folder that includes a signed DoC, a technical description of the product, and an accredited test report. Documentary Recordkeeping. The EMC regulation lays down minimum requirements for the content of a compliance folder. The supplier must retain the compliance folder and all relevant records for a period of five years after the date of last sale of the device. The compliance folder may be stored electronically, but it must be produced for ACA audit or investigation purposes within 10 working days of a written request. The DoC must be held in Australia at the registered supplier code address. Keeping the compliance folder overseas is permissible, but the supplier should check that it contains the necessary information before committing it to storage. Enforcement. The ACA is the enforcement
body, and regards it as an obligation to
responsible suppliers who comply with the
regulations to ensure that an effective
enforcement mechanism operates. This is
critical for a system based on self-declaration
by suppliers. The general policy of the
ACA is to enforce the regulations by educating
suppliers and by negotiating in order to
resolve problems and complaints. As a last
resort, the ACA will use the penalty provisions
against suppliers who are in willful violation
of the regulations.
If a product's compliance is questioned, the ACA will conduct an audit of the compliance folder and may undertake further investigations. Penalties for willful violations can be imposed on both individuals and companies, with regulations enforceable under the Radiocommunications Act 1992, the Trade Practices Act 1974, the Telecommunications Act 1997, and the Crimes Act 1914. Prosecution for breaches of the C-tick labeling provisions under trademark and copyright regulations is also possible. The supply of a nonstandard device, a primary offense under the Radiocommunications Act, may result in the seizure and forfeiture of stock and up to $160,000 in criminal penalties. Imprisonment is a possible punishment under the Crimes Act. The ACA can issue a notice to prohibit the sale or use of a device that is causing interference until the problem is corrected. Provisions exist for fines of up to $12,000 per day for the period of the infringement. A system of on-the-spot fines for minor transgressions is also in place. In addition, failure to prepare and maintain a compliance folder that adheres to the ACA requirements for a device imported or placed on the market may constitute a number of offenses. If the ACA auditor is not satisfied
with the evidence of compliance, then an
accredited report demonstrating compliance
must be provided within 30 working days
of request. The supplier may also be required
to submit three samples of the device to
a NATA-accredited test laboratory nominated
by the ACA. All testing costs must be borne
by the supplier.
Routes to Compliance The Testing Route. The most common and cost-effective means of compliance with the EMC framework involves testing against the ACA emission standards. EMC test houses are accredited by NATA to specific EMC standards in accordance with IEC Guide 25. The test report to be included in the compliance folder must be in English, and, if not an original, must be a certified copy. Product variants whose altered features are irrelevant to the question of RF emissions or do not increase RF emissions can be presumed to comply. The supplier may market any number of such product variants under a single DoC. However, the compliance folder must identify variants and contain descriptions of the changes made to the basic model. It must also include the rationale for marketing the device and its variants under the one DoC. The Technical Construction File Route. In some cases, a technical construction file (TCF) can be prepared and submitted to a competent body for assessment. The TCF route is intended to be used when the product is too large or otherwise impossible to test or when there are a large number of variants of a basic model. The Australian EMC regulation permits either the testing or the TCF route to compliance to be taken at the discretion of the supplier. The Australian TCF route is virtually identical to the European TCF route. The only difference is that compliance is assessed against specific emission standards (limits) in Australia; whereas, in the European Union compliance is assessed against broadly based noninterference requirements. The Role of the Competent Body. Competent bodies (CBs) are accredited by NATA in accordance with the requirements of IEC Guide 39/EN 45004, Guidelines for the Accreditation of Inspection Bodies. The role of the CB is to provide a technical report based on technical assessment of the TCF prepared and submitted by the supplier and which confirms the claims of compliance made by the supplier. Any testing requested by the CB must be NATA accredited. The report issued by a CB will be a NATA-endorsed document that will have the same status as a NATA test report. Only NATA-accredited CBs are able to issue endorsed reports against TCFs. A competent body may not approve
test reports, whether accredited or not,
and it may not conduct testing itself as
part of the assessment of a TCF unless it
has NATA accreditation for that testing
and unless the testing and CB functions
are totally independent of each other. Only
organizations like NATA can approve test
laboratories or manufacturers' in-house
testing.
When the CB requires extra testing in support of a TCF assessment, it may use only NATA-accredited testing or its equivalent. These test data may be used in conjunction with other data supplied by the manufacturer, including nonaccredited testing, in the assessment of the device against the appropriate standard. The TCF route to compliance is generally not cost-effective except when there are a number of variations of the same model within a family of products. Some very large or complex products can be difficult or impractical to transport to a test laboratory. For these, the supplier may prepare a TCF with assistance from a CB. The TCF route to compliance may be the best for large and complex products. In these cases, some standards permit in situ testing at the user installation; this option should be seriously considered, especially for single installations. As more EMC standards permit in situ tests for products that are difficult to test at a test house, the supplier is advised to consult with a test laboratory accredited by NATA for testing to the standard in question or to seek advice from a competent body. Product variants are approached in a manner similar to that of the TCF route under the EMC Directive. In cases involving product variations, the supplier must identify variants that are benign and those that do not require testing or CB assessment of a TCF. The ACA framework specifically allows the presumption of compliance for electromagnetically benign products and those variants of a basic model that are irrelevant to the RF characteristics of the device (cosmetic changes) or that do not increase the RF emission characteristics established for the basic model. The supplier can legally claim compliance under these circumstances without testing and without the involvement of a CB. It is still necessary to prepare a compliance folder for that product. An MRA between the European Union
and Australia/New Zealand was ratified in
1999. This MRA facilitates the acceptance
of testing and CB reports among Australia,
New Zealand, and the EU member countries.
The EU CBs must be accredited to the ACA
requirements, and the Australian CBs must
be accredited to the EU EMC Directive.
Conclusion Compliance with the Australian EMC regulations became mandatory on January 1, 1999. All products encompassed by the scope of the mandated standards and marketed in Australia must be labeled with a C-tick and supported by a compliance folder maintained at the disposal of the ACA. The ACA actively enforces the self-certification system by the regular audit of compliance folders. Following extensive industry consultation,
the new Australian EMC regulations are now
firmly entrenched. The C-tick scheme is
widely regarded as a success. General industry
and community awareness of the C-tick is
very high, and the ACA strategy of conciliation
and education has fostered industry cooperation.
Despite a certain spirited opposition and
difficulties experienced by some industry
sectors, implementation of the new EMC regulations
has gone well.
Chris Zombolas is technical director at EMC Technologies Pty Ltd. (Melbourne, Victoria, Australia). Illustration by Bob
Schuchman
|
On
January 1, 1997, EMC compliance with national
emission standards derived from CISPR
standards became mandatory for electrical
equipment marketed in Australia. The Australian
Communications Authority (ACA) later,
in 1998, clarified the scope and application
of the EMC regulations. Compliance with
the revised regulations is by means of
self-declaration, and suppliers must ensure
that the products they are placing on
the Australian market meet the relevant
EMC standards. New Zealand's EMC regulations
are similar to Australia's but contain
small differences. Negotiated harmonization
is expected soon to bring about transparency
between the two countries. The Australian
EMC framework displays similarities to
both the European EMC Directive and the
FCC Part 15 Rules.