The final step to product compliance involves labelling the product:
Steps to compliance
|1. Identify the applicable labelling notice
2. Identify the applicable technical standards (prescribed in the relevant labelling notice) and the testing requirements
|3. Demonstrate product compliance
|4. Complete a Declaration of Conformity (DoC) and maintain compliance records
|5. Register as a ‘responsible supplier’
|6. Label the product
The ACMA regulatory arrangements require a supplier to apply a compliance label to a product before the product is supplied to the Australian market.
What is a compliance label?
A compliance label is a durable and legible label that indicates the product complies with the applicable standard/s.
For all ACMA regulatory arrangements, the compliance label is the Regulatory Compliance Mark (RCM). The RCM replaces the A-Tick and C-Tick compliance marks used under previous regulatory arrangements.
What is the compliance mark?
The RCM is a visible indication of a product's compliance with all applicable ACMA regulatory arrangements, including all technical and record-keeping requirements.
Note: The Electrical Equipment Safety System (EESS), administered by the Electrical Regulatory Authorities Council (ERAC), also uses the RCM. The ACMA has no regulatory responsibility for the EESS arrangements. Information about the EESS is available from www.erac.gov.au. Questions about the EESS should be directed to the ERAC Secretariat via email at email@example.com.
The RCM can be downloaded:
Note: Products that were labelled with the C-Tick or A-Tick compliance mark prior to 1 March 2016 can continue to be supplied until labelled stock has been exhausted - they are not required to be re-labelled with the RCM.
Who is responsible for applying the label?
It is the responsibility of the supplier to ensure that a compliance label is correctly applied to each product before it is supplied to the market.
A supplier can give permission to a third party, including an agent, to apply the label. However, ultimate responsibility for applying the label rests with the supplier.
What are the application requirements for the compliance label?
Physical requirements for the compliance label include:
Scale and visibility—The compliance label must be legible and visible to the unaided eye and the compliance mark must be no smaller than three millimetres (3 mm) in height. The label may be in any colour, provided that visibility is assured through either contrast with the background colour or marking in relief (for example, moulding or engraving).
Surface labelling—The compliance label should be a permanent feature placed on the product. It must be applied to a surface of the product that is easily accessible to the user. The label should be durable and applied by any suitable means including printing, painting, moulding, etching or engraving.
Electronic labelling—If a product has a built-in display, the compliance label may be displayed electronically rather than on the surface of the product. Electronic labelling is only permitted if the product has a built-in display—displays that connect to the product, but are external to it, are not considered to be built-in.
The labelling notices do not prescribe how electronic labels should be displayed. Examples of how electronic labels can be displayed include:
- during the device’s power up sequence
- under the device’s system information page
- under the device’s help menu.
The accompanying product documentation must explain how the electronic label can be viewed.
Package labelling—If it is not practical to apply a label to the external surface of the product (and it is not displayed using a built-in electronic display), the label must be applied to both:
- the external surface of the packaging used for the product, and
- the documentation (operating instructions, warranty or guarantee certificates) that accompanies the product when it is supplied to the consumer.
A label applied to the external surface of the packaging must:
- be clearly visible, and
- occupy an area that is greater than one per cent of that external surface—this requirement is not applicable to the Telecommunications Labelling Notice.
Note: A supplier who does not apply a label to the surface of the product is required to maintain records detailing the reasons why and where the label was subsequently applied. This requirement does not apply to a supplier who labels electronically.
Full details of the labelling requirements are provided in the relevant labelling notices.
When all steps to compliance are complete, the product may be supplied to the Australian market.
The ACMA takes a risk-based approach to product compliance. If non-compliance of a product is identified, the ACMA may conduct targeted auditing and may seek to examine a supplier’s compliance records.