DoC and record-keeping | ACMA

DoC and record-keeping

The fourth step to product compliance is to complete a Declaration of Conformity (DoC) and maintain compliance records: 

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

Each regulatory arrangement includes record-keeping requirements for product compliance.

Record-keeping requirements apply to a supplier of a product to which a compliance label has been applied. Under the telecommunications regulatory arrangements, the record keeping requirements also apply to a supplier of particular cabling products to which a label was not applied.

What are compliance records?

Compliance records are a collection of documents that support a supplier’s claim that the product complies with the applicable standard/s. The specific requirements depend on the relevant regulatory arrangement, the required level of evidence (based on the compliance or risk level) and the type of product. 

Records must be in English, can be in written or electronic form and can be a certified reproduction of an original record. 

What records are required to be kept by suppliers?

This information below is a guide only, not a definitive list. You should refer to the relevant labelling notice to identify the exact requirements.

  • Declaration of Conformity (DoC)—A declaration made by the supplier asserting that the product being supplied is compliant with the applicable standard/s and that all products of this type supplied in the future will also be compliant. A product must not be supplied in Australia unless a DoC has been completed for that product.  A supplier may rely on a DoC that has been signed by an overseas manufacturer if compliance is declared to an applicable Australian standard. A DoC must be completed for all product families (please note, under the EMC regulatory arrangements, there is an exemption for certain low-risk devices).   
  • Product description—Information that unambiguously identifies the product. Usually the test report provides detailed information including photographs or statements regarding batch or model numbers and identifying characteristics. A supplier should consider if they need to provide additional information that removes any doubt about product identification. 

Additional records that may be required

  • Test reports—The type of test report required is based on an assessment of the potential consequences arising from the supply of a non-compliant product. The higher the risk, the higher the evidentiary proof of compliance.
  • Other supporting documentation—Statements of conformity, certification body statements and other evidence.
  • Agency agreements—If a manufacturer or importer uses an agent, the records must contain a copy of the agency agreement. 

What are the record-keeping requirements for each regulatory arrangement?

Telecommunications

DoC and a description of the product

Test report
(from testing body or in-house test facility)

Endorsed test report (RTA, NATA-accredited testing body or NATA MRA Partner) or Certification body statements

Non high-risk applicable standard

(test report not required to be held)

 

High risk applicable standard

 

(endorsed test report not required to be held, but must have been sighted)

Note: The Telecommunications Labelling Notice does not require a supplier to hold a test report/endorsed test report. However, the supplier should be confident that the item complies with the applicable standard. It is the supplier’s choice to maintain a test report supporting conformity.

Radiocommunications

DoC and a description of the product

Test report/
Reasonable evidence
(from FCC or testing body)

Test report
(from NATA-accredited testing body or NATA MRA Partner)

Compliance level 1

Low-risk device

(test report not required to be held)

 

Medium-risk device

 

High-risk device

 

Note: Though Compliance level 1 (low-risk device) does not require a supplier to hold a test report, the supplier should be confident that the device complies with the applicable standard. It is the supplier’s choice to maintain a test report supporting conformity.

EMC

DoC and a description of the product

Test report/
Technical construction file
(from a testing body or in-house test facility)

Accredited test report/Technical construction file
(NATA-accredited testing body or NATA MRA Partner)

Low-risk device

√ (DoC not required if device not labelled)

(test report not required to be held)

 

Medium-risk device

 

High-risk device

 

Note: Though Compliance level 1 (low-risk device) does not require a supplier to hold a test report, the supplier should be confident that the device complies with the applicable standard. It is the supplier’s choice to maintain a test report supporting conformity.

EME

DoC and a description of the product

Test report
(from testing body or in-house test facility)

Report
(from NATA-accredited testing body or NATA MRA Partner

Compliance level 1

 

 

Compliance level 2

 

Compliance level 3

 

Do compliance records have to be available for inspection?

Records must be available for inspection by the ACMA upon request. The ACMA may request records as part of an audit or an investigation.

In some cases, the records may not be enough to establish conformity. The ACMA can require a supplier to obtain additional evidence, including conducting additional testing at an accredited laboratory.

Next step:

Register on the national database.

Last updated: 05 February 2016