EMC record-keeping requirements | ACMA

EMC record-keeping requirements

A supplier of a product subject to the EMC regulatory arrangements is required to maintain documentary evidence (compliance records) to demonstrate that the product complies with the applicable technical standard. These requirements are specified in the Radiocommunications Labelling (Electromagnetic Compatibility) Notice 2008 (the EMC LN).

The level of evidence required to be obtained and maintained by a supplier varies depending on the risk of interference that may be expected from the product–high-, medium- and low-risk.

Compliance records help to:

  • accurately identify the product
  • provide information about compliance of the product with applicable technical standards
  • confirm the supplier’s reasonable satisfaction that all products of the same class supplied comply with the applicable technical standards.

Specific record-keeping requirements

A compliance record must be in English, may be a copy of the original record, and may be kept in electronic form.

A supplier must ensure the compliance records for the product are available for inspection within 10 working days of receiving a notice of intent to inspect the records from the ACMA.

A supplier or agent, must retain compliance records for five years after the supplier ceases to supply the product in Australia. This includes a supplier of a low-risk device who decides not to apply a compliance label to the product.

Compliance records

Compliance records must be appropriate for each risk level and consist of:

Required records (as applicable)

  • a Declaration of Conformity (DoC) – except for a low-risk device that has not been labelled
  • a description of the product or a variant
  • a copy of any agency agreement between an agent and a supplier.
  • test reports for some products or other supporting documentation, showing the product conforms with the applicable EMC standard
  • technical construction file
  • particular written statements (for example, reasons why a label cannot be affixed to the surface of a product, and information about a variant of the product).

Additional records that may be required

A description of each compliance record is set out below.

Declaration of Conformity

A DoC is a document made by or on behalf of a supplier asserting that the product being supplied is compliant with the applicable ACMA technical standard/s and, that all products of that type supplied in the future will also comply with the standard.

The format of the DoC is flexible, a supplier may create their own form. However, any declaration must contain, as a minimum, all of the information listed in the sample DoC (Form C02) on the ACMA website.

Completing the Declaration of Conformity

The person signing the declaration must sight the evidence that supports the declaration and be satisfied that the evidence contained within the compliance records is sufficient to demonstrate compliance with the technical standard/s.

There are significant penalties for knowingly or willingly providing false or misleading information.

Description of a product or a variant

A description of a product must include sufficient information for a person to determine whether the particular product is identical to the product for which a DoC, test report or statement by a competent body was prepared.

The description of a product must be updated when necessary to ensure the description complies with the requirements of the EMC LN.

The description of the product:

  • must include the current model number for the product and, if relevant, any related model numbers
  • must include the version of any software or firmware incorporated into or supplied with the product where changes in these may affect the compliance of the product with the technical standard
  • may include a photograph/s of the product illustrating its internal and external aspects (including printed circuit boards).

Agency agreements

A manufacturer or importer engaging the services of an agent must have a written agency agreement with the agent.

The agreement allows an agent to act as the representative for compliance with the ACMA regulatory arrangements.

A copy of the agreement must be kept with the required compliance documentation.

More information can be found on the Agency agreements page.

Test reports

A test report should identify the product (type, model and batch number), the testing agency, the standards tested to, the tests conducted and the test results, and (if appropriate) the methodology used to conduct the test.

Technical construction file

A technical construction file is documentary evidence, in English, that includes a report produced by a competent body assessing a product against the requirements of an applicable standard, in which the report:

  • identifies the product assessed
  • identifies the applicable standard against which the product was assessed
  • includes a statement by the competent body stating that, in the opinion of the competent body, the product complies with the applicable standard.

Documentary evidence (compliance records) of each compliance level

Compliance level 1/low-risk device

For a low-risk device, in order to comply with an applicable technical standard at compliance level 1, a supplier must:

Product has been labelled

  • prepare a description of the product
  • complete and sign a DoC.

Product has not been labelled

  • prepare a description of the product.

Note – While a supplier is not required to hold a test report as evidence, a supplier should be confident that the product complies with the applicable technical standard. This may include a manufacturer’s performance specification documents for the product.

Compliance level 2/medium-risk device

For a medium-risk device, in order to comply with an applicable technical standard at compliance level 2, a supplier must:

  • prepare a description of the product
  • complete and sign a DoC
  • obtain a test report from a testing body or a technical construction file.

Compliance level 3/high-risk device

For a high-risk device, in order to comply with an applicable technical standard at compliance level 3, a supplier must:

  • prepare a description of the product
  • complete and sign a DoC
  • obtain an accredited test report produced by an accredited testing body or a technical construction file.

More information on Compliance levels can be found in sections 4.4, 4.5 and 4.6 in the EMC LN.

Availability of compliance records for inspection

Compliance records must be available for inspection by the ACMA within 10 working days 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:

Register on the national database and apply a compliance label to the product.

Last updated: 11 February 2016