Alternative to labelling for suppliers of cabling products

Under the Telecommunications Labelling (Customer Equipment and Customer Cabling) Notice 2001, as amended, (Telecommunications Labelling Notice) there is provision for an alternative arrangement for the labelling of a range of products used by the cabling industry. This arrangement provides the opportunity for manufacturers, importers or their agents (suppliers) to reduce their costs by not applying the compliance label (A-tick and identifier) to specified products.

Suppliers who are eligible to use the alternative arrangement and not affix the compliance label to their product are required to maintain a publicly available register on the internet listing each of their compliant cabling products which are supplied under this alternative labelling arrangement. These products will be identified in the market place by their unique markings and labels applied during the manufacturing process.

The internet register maintained by the supplier will provide, in particular, licensed or registered cablers and the ACMA quick and easy access to the supplier's list of compliant, non-labelled product. The ACMA has a register of all suppliers using the alternative labelling arrangement.

Eligibility of products

Only products that:

• are required to be compliant with the standards TS008: 1997, AS/ACIF S008:2001, AS/ACIF S008:2006 or AS/CA S008:2010 Requirements for Authorised Cabling Products and
• require a licensed or registered cabler to install and
• are marked with a unique identification

are eligible to use the alternative labelling arrangement. These 'trade' products include cable, connectors, distributors and patch panels.

Cabling products destined for the consumer market must continue to be marked with the A-Tick compliance label. Examples of such products include pre-terminated (terminated with plugs and sockets) telephone extension cords, plug-in socket adaptors and pre-terminated patch leads.

The A-Tick continues to play a primary role for suppliers to demonstrate compliance, and to enable consumers to determine product compliance and whether the product can be legally connected to the telecommunications network.

Alternative arrangement

Details of the requirements for suppliers using the alternative labelling arrangement are specified in the Telecommunications Labelling Notice. In brief, suppliers of cabling product intended for use in Australia who wish to use the alternative arrangement must:

1. apply for permission to use the alternative labelling arrangement using the form contained in the Telecommunications Labelling Notice
2. prove that items comply with either TS008:1997, AS/ACIF S008:2001, AS/ACIF S008:2006 or AS/CA S008:2010
3. ensure the items bear unique identification and are labelled in accordance with the Telecommunications Labelling Notice
4. maintain compliance records for each product (or family of products)
5. establish an internet register which clearly identifies products using the alternative labelling arrangement and
6. advise the ACMA of the internet address of this register.

Compliance records are subject to audit by the ACMA.

1. Permission

If the supplier of cabling product destined for the 'trade' market wishes to use the alternative to the labelling arrangements, a Notice of intention not to apply a compliance label (T004) form must be forwarded to the ACMA.

2. Testing

Testing of cabling products is a mandatory requirement. Compliance requirements for cabling products are set at compliance level 2. This means that testing against the applicable standard TS008:1997, AS/ACIF S008:2001, AS/ACIF S008:2006 or AS/CA S008:2010 can be done by a NATA-accredited test house, non-accredited test house or in-house, provided you have the required test facilities.

3. Unique identification

Products will be identified in the market place by their unique markings and labels as applied in the course of manufacturing. A supplier of cable must ensure that there is displayed on the sheath of the cable at regular intervals of not more than 2 metres:

• a company name, trade name or trade mark and
• part number, identification number, product name or part name.

A supplier of other cabling product must ensure that there is displayed on the product:

• a company name, trade name or trade mark
• a part number, identification number, product name or part name
• if applicable the international protection rating and
• for multiple use (e.g. telecommunication and electrical) product markings which must be distinguishable from markings used on hazardous circuits and readily visible when the equipment is installed.

4. Maintaining compliance records

The supplier must hold compliance records for all items of cabling product supplied to the Australian market. The records are described in detail in the Telecommunications Labelling Notice but briefly comprise:

• the description of each item
• declarations of conformity
• test reports and
• the entry in relation to each item on their register.

5. Internet register

Suppliers wishing to use this alternative labelling arrangement must establish on the internet a publicly available register that:

• states the name of the supplier
• clearly identifies each item subject to the alternative arrangements and
• provides the details of each exempt item.

The item details include:

• for cabling:
  • a company name, trade name or trade mark
  • a part number, identification number, product name or part name and
  • the number of pairs within a cable.
• for other cabling products:
  • a company name, trade name or trade mark and
  • a part number, identification number, product name or part name.

In addition, the register must:

• include only items that do not bear a compliance label and
• list the items in groups of like items, according to:
  • the technical characteristics of the item
  • the function of the item
  • the purpose for which the item is used, or for which it is intended that the item be used or
  • the location of the item and
  • be separated from any other lists of products.

6. Advising the ACMA

The ACMA will establish a link to the supplier's web page of non-labelled product based on the information supplied in the application to use the alternative labelling arrangements. The supplier must advise the ACMA of changes to the URL within 21 days.

This article is only intended to be a brief overview. It is important that suppliers read the requirements specified in the Telecommunications Labelling (Customer Equipment and Customer Cabling) Notice 2001 and consult the ACMA.