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C-Tick 2002: The Australian
EMC Regulations Simplified
Chris
Zombolas
Updated
EMC regulations in Australia
and New Zealand provide greater
flexibility for manufacturers.
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Illustration
by TAISHA PAYTON
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In
2000, the Australian Communications
Authority (ACA) convened an
electromagnetic compatibility
(EMC) review committee to discuss
areas of deficiency identified
during ACA's course of management
as well as from industry submissions.
Fifteen recommendations were
considered, and the legal instrument
was changed in late 2001 to
accommodate the most important
proposals. The most significant
change was the adoption of the
list of International Special
Committee on Radio Interference
(CISPR), European Committee
for Electrotechnical Standardization
(CENELEC), and International
Electrotechnical Commission
(IEC) standards as mandatory
ACA standards. This change better
identifies the applicable mandatory
standard for virtually any electrical
product on the market.
The
new regulations also harmonized
the Australian and New Zealand
EMC requirements under the Trans-Tasman
Mutual Recognition Arrangement
(TTMRA). The aim of aligning
compliance procedures was to
remove barriers to trade between
the two nations and effectively
lessen costs by providing a
mutually accepted and recognized
route to product compliance.
After
much consultation between ACA
and the Radio Spectrum Management
Group (RSM) of the New Zealand
Ministry of Economic Development
(NZMED), the Trans-Tasman EMC
Compliance scheme was introduced.
At this stage, the harmonized
TTMRA scheme regulates only
the EMC aspects of product compliance.
The
C-Tick mark is valid for both
countries and may be applied
by either a New Zealand supplier
or an Australian supplier. A
parallel declaration of conformity
(DoC) notification scheme is
still available for New Zealand
suppliers who do not wish to
use the C-Tick mark. ACA and
RSM plan to extend the scope
of the TTMRA to include telecommunications
and radiocommunications compliance.
This article provides an overview
of the new requirements, their
enforcement, and penalties for
noncompliance.
Evolution
of the Australian EMC Compliance
Scheme
In
1997, ACA introduced the EMC
Compliance scheme, which was
designed to limit the amount
of electromagnetic interference
to Australia's radiocommunications
and radio-frequency (RF) spectrum.
The scheme outlined compliance
with technical limits for emissions
from all electrical and electronic
products marketed in Australia
under the Radiocommunications
Act of 1992.
ACA
modified the scheme in 1998
in a bid to clarify its scope
and application. The compliance
scheme was based on a system
of self-declaration, with the
responsibility for compliance
resting solely on the supplier.
Although
the scheme was standards based,
it was evident after implementation
that the scope was not adequately
defined for many products, and
some loopholes became apparent.
In
January 1999, the regulations
were rewritten so that the scheme
became totally standards based.
If a product fell under the
scope of one of the ACA mandatory
EMC standards (and was not specifically
excluded) then compliance with
all the provisions of the C-Tick
regulations was mandatory. The
major problem faced by industry
and suppliers was in determining
the appropriate standard to
apply. This standards-based
approach eliminated many ambiguities,
removed most loopholes, and
clarified the scope of the regulations.
However, vagaries in the scopes
of some CISPR standards made
it difficult for suppliers to
decide which standard applied
to their product.
The
primary responsibility for enforcement
of the EMC regulations now rests
with ACA and RSM through the
list of standards made under
their respective legislative
instruments. The EMC regulations
apply to suppliers of a wide
range of electrical and electronic
products offered for sale in
Australia and New Zealand. A
supplier is defined as:
-
An
Australian or New Zealand
manufacturer who makes products
for supply to the Australian
or New Zealand market.
-
An
importer of products intended
for supply in Australia or
New Zealand.
-
The
authorized agent (resident
in Australia or New Zealand)
acting on behalf of a supplier
of products to either country.
Standards
Under
the TTMRA-harmonized EMC compliance
scheme, all electrical and electronic
products seeking approval for
the Australian or New Zealand
markets must comply with the
applicable, mandated EMC emission
standards, unless specifically
excluded. All products must
also comply with the electrical
safety requirements of appropriate
regulatory bodies. Mandatory
immunity requirements are not
covered within the scope of
the existing scheme. Manufacturers
are encouraged to consider immunity
issues when designing products.
(Immunity requirements are mandatory
under other regulatory regimes
such as the Therapeutic Goods
Administration, Civil Aviation
Safety Authority, and Defense).
ACA
and RSM have mandated the following
EMC aspects of the standards:
EMC phenomena of emitted disturbances
only associated with conducted
(continuous and intermittent)
RF disturbance or radiated RF
disturbance, and test procedures
and requirements associated
with these EMC
phenomena. The standards are
listed in Table
I.
The
regulations apply to all products
that fall under the scope of
one of the mandatory standards
and operate from the domestic
residential mains supply or
from battery or similar supply.
This modification brings previously
exempt three-phase equipment
into the scope of the regulations,
but it exempts equipment that
operates from a high-voltage
supply.
Transitional
Arrangements
The
transitional arrangements for
amendments or implementation
of the standards are two years
for IEC, CISPR, and AS/NZS standards
at the time of publication.
For EN standards, the transitional
period is as published in the
Official Journal of the European
Communities. The transitional
arrangement is the time period
in which ACA and RSM recognize
conformity to either the earlier
or later version of the same
standard for products supplied
to the market. Upon expiry of
the transitional period, ACA
and RSM will recognize only
the later version of a standard
for compliance purposes with
the EMC scheme.
EMC
Compliance Arrangements
To
comply with the EMC regulatory
arrangements, Australian and
New Zealand suppliers must satisfy
four basic requirements:
-
Ensure
that the product complies
with the appropriate mandated
EMC standard.
-
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Prepare
and keep compliance records.
-
Label
the product with the C-Tick
mark.
Once
these basic requirements have
been satisfied, a product can
be offered for sale without
the involvement of ACA or RSM.
Compliance
Levels
The
EMC scheme defines three levels
of compliance as well as requirements
based on the risk of interference
that may be expected from a
product. Each compliance level
has a series of requirements
that are applicable for Australian
and New Zealand suppliers.
Compliance
Level 1. Level 1 covers
products whose emissions are
considered to have a low impact
(minimal risk of interference)
on devices using the RF spectrum.
Level 1 products include products
such as manually operated switches
or simple relays, brushless
squirrel-cage induction motors,
and resistive elements.
Compliance
Level 2. Level 2 covers
products whose interfering emissions
would have some impact on devices
using the RF spectrum. Examples
of these devices include the
following:
-
A
microprocessor or other clocked
digital device.
-
A
commutator or slip-ring motor.
-
-
Switched-mode
power supplies.
-
-
Suppliers
in Australia and New Zealand
must ensure that products falling
within this compliance level
meet the appropriate EMC standard.
For level 2, they must hold
a compliance folder containing
a product description, completed
DoC, and an adequate EMC test
report or technical construction
file (TCF) that demonstrates
compliance with the limit defined
in the applicable EMC standard.
Testing must be performed using
the procedures specified by
the standard. This change appears
to disallow the use of precompliance
test equipment and procedures.
Compliance
Level 3. Level 3 covers
products whose interfering emissions
have the highest risk of serious
impact on devices using the
RF spectrum. Level 3 applies
to devices that belong to the
industrial, scientific, and
medical (ISM) group 2 (CISPR
11) and telecommunications terminal
equipment under information
technology (CISPR 22). After
November 2003, telecom equipment
will be classified as compliance
level 2.
Suppliers
in Australia and New Zealand
must ensure that products falling
within this compliance level
meet the appropriate EMC standard.
For level 3 products, suppliers
must hold a compliance folder
containing a product description,
completed DoC, and an accredited
test report or TCF. The test
report must be issued by a laboratory
that is accredited by National
Association of Testing Authorities
(NATA), or a NATA MRA partner
accreditation body. The laboratory's
scope of accreditation must
include all of the relevant
clauses of the applicable version
of AS/NZS 3548/CISPR 22/EN 55022
or AS/NZS 2064/CISPR 11/EN 55011.
The
Declaration of Conformity
The
DoC is a statement signed by
the supplier certifying that
the product has been tested
and found to comply with any
required standards. The supplier
establishes the compliance folder
after viewing evidence of compliance
(i.e., one or more test reports
outlining compliance margins).
Although suppliers are not required
to submit the product or proof
of compliance to the regulatory
bodies at this stage, they must
retain a compliance folder containing
the DoC and all required compliance
records.
Required
compliance records include test
reports indicating compliance
margins, a description of the
product and all documentation
that clearly identifies it (e.g.,
photographs, block diagrams,
drawings, and circuit diagrams),
and paperwork showing the product's
brand name, model number, etc.
Compliance
records, which must be in English,
can be kept electronically.
Records must be kept for five
years after the product ceases
to be supplied in Australia
or New Zealand. Hard copies
of compliance documentation
must be made available to ACA
or RSM for audit or investigation
within 10 business days of a
written request from the regulatory
body.
A
supplier must complete and retain
a DoC every time a new product
or model of a product is to
be marketed. If a product has
had changes that are either
cosmetic or that do not alter
its RF emission characteristics,
then compliance is presumed
under the DoC maintained for
the earlier model. In situations
where variants exist, the supplier
must add a signed statement
to the original compliance records
outlining the changes made and
the reasons for using a single
DoC for marketing.
Exemptions
Although
the EMC schemes in Australia
and New Zealand have been harmonized,
the categories for exemption
are slightly different in each
country.
Australia.
Equipment that falls within
the scope of other regulatory
bodies is exempt from the EMC
regulations in Australia. The
Civil Aviation Safety Authority,
for example, approves equipment
related to avionics and ground
facilities. Equipment used for
military purposes is approved
by the Department of Defence,
and the Department of Transport
and Regional Services regulates
design safety codes for road-registrable
vehicles. All devices that fall
within the jurisdiction of the
Therapeutic Goods Act are assessed
by the Therapeutic Goods Administration.
All devices used solely for
law enforcement by the following
agencies are exempt from the
EMC regulations:
-
The
Australian federal police.
-
A
police force or service of
a state or territory.
-
The
National Crime Authority.
-
The
New South Wales Crime Commission.
-
The
New South Wales Independent
Commission Against Corruption.
-
The
Criminal Justice Commission
of Queensland.
-
A
prescribed authority established
by or under law of the Commonwealth,
a state, or territory.
-
A
body or organization responsible
to the Australasian Police
Ministers' Council for the
facilitation of national law-enforcement
support.
-
In
addition to the exemptions
for these agencies, products
that meet the following criteria
are also excluded from the
Australian EMC regulations:
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Any
product designed or adapted
for the purpose of conducting
any test, measurement, or
study of electromagnetic phenomena
in an educational, training,
or research establishment.
-
Installations
comprising two or more combined
items of apparatus or systems
put together at a given place
to fulfill a specific objective,
but not designed by the manufacturer
for supply as a single functional
unit.
-
Prototypes
or products to be used for
exhibition and demonstration
purposes (e.g., at trade fairs).
-
Spare
parts--a component or combination
of components intended for
use in replacing parts of
electronic products.
-
Secondhand
products previously sold in
Australia, but not including
modified products.
-
Products
with a total power consumption
of less than 6 nW.
Radiocommunications
products are intentional radiators
and, as such, are generally
excluded from the EMC regulations.
These products are covered by
a different set of standards
and compliance arrangements
administered by ACA. It should
be noted that carrier telecommunications
equipment has been removed from
the list of exempted devices
and must now be C-Ticked.
New
Zealand. In New Zealand,
the administrative components
of the EMC regulations do not
apply in the following circumstances:
-
Products
supplied in a total quantity
of less than 10.
-
Some
battery-powered products.
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Prototypes
for demonstration purposes.
-
Parts
that will only perform a function
when incorporated into a finished
product.
-
Fixed
installations, being a combination
of parts, components, or products
assembled and installed at
a place of use in such a way
that the combination cannot
be moved without being at
least partially disassembled.
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Radiocommunications
products (i.e., intentional
radiators).
-
Military
equipment or weapons systems
of the New Zealand Defence
Force.
-
Military
equipment or weapons systems
of the defense force of another
country operating in cooperation
with the New Zealand Defence
Force.
Labeling
The
labeling of compliance level
1 products is voluntary (but
compliance is still mandatory).
All level 2 and level 3 products
must be labeled appropriately
before they can be marketed.
The required label consists
of either the C-Tick mark or
its alternative, the regulatory
compliance mark (RCM), or the
A-Tick mark for telecommunications
devices. In New Zealand, the
A-Tick mark does not signify
compliance with telecom standards
as it does in Australia.
In
addition to the relevant, applicable
compliance mark, each label
must also contain acceptable
supplier identification. If
it is not practical to attach
a label to the exterior of a
device, the label can be attached
in the following order:
-
To
the outer surface of the packaging;
or if impractical
-
To
instructions for use; or if
impractical
-
To
guarantee or certificates.
These
options can only be used with
the written permission of ACA
or RSM. A valid reason must
be given to explain why it is
not practical to label the product
itself.
C-Tick.
The C-Tick is a certification
trademark registered to ACA
under the Trade Marks Act of
1995 and to RSM in New Zealand
under Section 47 of the NZ Trade
Marks Act (see Figure 1). The
mark must be used in accordance
with its governing regulations
and is therefore only issued
to an Australian or New Zealand-based
supplier. The label is expected
to be durable and limited in
its size, scale, and color according
to the regulations.
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Figure
1. C-Tick certification
mark.
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A-Tick
(Telecommunications Standards).
All products subject to the
Australian Telecommunications
Labelling Notice must also meet
the requirements of an EMC standard
such as AS/NZS 3548 or AS/NZS
CISPR 22. The A-Tick mark illustrates
compliance with both the EMC
and telecommunications requirements
in Australia, but only with
EMC requirements in New Zealand
(see Figure 2). AS/NZS 3548
has been replaced with AS/NZS
CISPR 22:2002. This standard
incorporates CISPR 22:1997 and
Amendment 1:2000. The requirements
for conducted emissions on telecom
ports have been deferred by
the revised EMC regulations
until November 2003.
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Figure
2. A-Tick mark for telecommunications
products.
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RCM.
The regulatory compliance mark
(RCM) is a trademark owned by
Australian and New Zealand regulators
and alternatively signifies
EMC compliance. Suppliers intending
to use the RCM mark should register
with Standards Australia (in
accordance with AS/NZS 4417.1)
and complete the application
form in AS/NZS 4417.3. The RCM
is not an alternative mark to
the A-Tick telecommunications
compliance mark.
Supplier
Identification. In addition
to one of the marks, product
labels must also include the
identification of the manufacturer,
importer, or agent. In Australia,
one of the following must be
on the label:
-
A
business name and address
in Australia.
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