Some imported LED globes are knocking out people’s television reception.
If you’re a supplier of LED globes, you’re responsible for ensuring that they (or any other devices you supply) don’t cause interference. For a quick spotlight on the link between LEDs and interference, take a look at our video:
How do I know I’m a supplier?
Anyone who imports electronic devices, including LED globes, for use by someone other than themselves is a supplier under the Radiocommunications Act 1992. Even if you’re not ‘selling’ LED globes as a retailer, you still may be considered a supplier if you:
- are responsible for buying and supplying the lighting for your company’s clients
- do fit-outs or other contract work where you or your business imports and installs lighting
- sell globes online that you drop-ship or otherwise source from overseas.
This means you’re subject to technical standards compliance requirements.
Why are we focusing on LEDs?
Some models of LED light globes cause interference to TV signals. This interference may consist of a sudden loss of signal or picture quality in a residence or neighbouring house.
In these cases, the ACMA needs to be able to quickly contact the supplier of the globes to notify them of the problem. People experiencing TV reception problems may also wish to contact the supplier to arrange an exchange or refund.
The consequences of supplying a device that does not comply with Australian law can be serious and may risk your business’s reputation. Taking some simple steps before making a bulk purchase of LED globes (or any electronic device) directly from overseas will help prevent interference.
How can I make sure my imported LED globes comply?
Do your research first. Some points to consider include:
Confirm the product can be legally supplied and used in Australia
Ask the overseas wholesaler or manufacturer to give you compliance test reports showing that the globes comply with the applicable Australian or international equivalent electromagnetic compatibility (EMC) standards (such as CISPR 15 or EN 55015). If your manufacturer can’t provide test reports, you’ll need to arrange and pay for testing yourself. While overseas test reports are acceptable, you must provide information explaining how the overseas standards are equivalent to the Australian standards.
Check if other standards also apply
The EMC standards are in addition to electrical safety standards that may also apply.
Give your overseas supplier or manufacturer clear specifications
Make sure your manufacturer or wholesaler understands that globes that are suitable for some markets may not be suitable for Australia, and must conform to Australian or equivalent international standards.
Be wary of unauthorised changes made by manufacturers
In several cases, overseas manufacturers appear to have changed components or internal designs of globes without telling Australian suppliers, leaving Australian suppliers holding large quantities of non-standard globes.
For example, a manufacturer might remove an internal filter or alter the components or circuit for efficiency reasons. Such changes may not be visible on the outside of the product and may not be reflected in a change in model number. In reality, such unauthorised changes will constitute a new product, which requires a new test report. When receiving a new batch of what you expect to be the same model, inspect a sample to ensure that there have been no internal product design changes.
Check the terms of sale and the wholesaler or manufacturer’s reputation
Make sure you’ll be able to return any stock that does not comply with Australian standards. If the globes are found to cause interference in Australia, your customers will have to disconnect them.
Carefully scrutinise any test report provided to you by a manufacturer
The Australian Competition and Consumer Commission (ACCC) has warned that fake (forged or modified) test reports have been uncovered.
The ACCC’s supplier guide includes the following advice for suppliers:
To help ascertain whether a report has been forged or tampered with, look for:
- missing elements of the report
- different fonts throughout the report that could suggest cutting and pasting
- different background shades that could suggest cutting and pasting, the use of white-out or photocopying
- an unknown laboratory name or logo that does not appear to exist anywhere else
- spelling and grammatical errors
- inconsistencies in codes, identification numbers and page numbers, or
- conclusions that clearly do not match, or seem at odds with, the test results or body of the report.
These days, test laboratories often send reports in PDF format via email. Always ask the test laboratory to send you the test results in PDF format at the same time they are sent to any other party (such as a manufacturer or agent). This limits the potential for alteration of test results.
You can ask for security provisions associated with these files that prevent changes, restrict access and limit recipients to printing only. This reduces the possibility of electronic tampering with original documents. To prevent tampering and forgeries, always ask test companies to activate security measures for electronic reports.
If you feel suspicious about a test report, try to contact the laboratory that has written it and ask them to verify its authenticity in writing. Check the validity of claims to accreditation by contacting the relevant accreditation body and asking for evidence of this. If a supplier or manufacturer cannot verify the authenticity of a report, it should not be relied upon for choosing, buying or selling stock.
Check the manufacturer will label the globes with the regulatory compliance mark (RCM)
Make sure you register on the National Database before applying the RCM. Registration is free if you only need to register for ACMA compliance purposes (not electrical safety purposes). Many overseas manufacturers will print the RCM and a brand name on bulk orders. If not, you will need to do this yourself.
As a supplier, what must I do to comply?
The ACMA administers a largely self-regulatory regime, which is designed to be low in cost and light on red tape for Australian suppliers.
As a supplier, you must:
Register as a supplier and label your globes
There is no fee to register as a supplier for ACMA compliance purposes, which you can do online. You can then affix the RCM symbol (this replaces the old C-tick) to your globes. Read more about supplier registration.
Keep compliance documentation on file
You must keep a copy of the declaration of conformity, a description and the test report that demonstrates compliance for each model of globe. If there is an interference complaint about the particular model, the ACMA may audit you by asking you to produce these documents. The ACMA also conducts targeted audits of devices as part of our compliance programs.
Be prepared to pay for a local test report
If the ACMA audits your compliance documentation and it is insufficient, we may legally require you to have an Australian-accredited laboratory to test three samples of your globes—at your expense.
Remember, continued intentional non-compliance can result in fines or prosecution, so do the right thing—make sure your LED globes comply.