This update has been revised on 2012-07-11 with new information. If you reviewed it before, please review it again now.
Until the official commencement of the EESS, some suppliers may wish to transition to the RCM sooner, to simplify production schedules. This is presently possible, with some limitations and conditions, under the legacy rules (excluding telecommunications products), but is not possible under the new rules until 1 March 2013. Please note the following issues related to this:
- The new AS/NZS 4417.1 & AS/NZS 4417.2 edition: 2012 standards were published on 29 June 2012. These will replace all of the earlier editions and parts of 4417.x on the 1st March 2013 (refer to the preface in the standards). Until then the RCM process requirements are unchanged, and the existing 2009 edition documents with their associated amendments continue to apply.
- The EESS registration database is not in production at the time of writing and cannot be used for official purposes, even though there’s a link to an evaluation version on the ERAC web site. The EESS database may be available for trial registrations later in 2012, but I’m advised these trial registrations will not have regulatory effect. If suppliers use the trial registration system, they will still need to re-register when the official database is cut over.
- The advice at this time is that the 2012 edition of AS/NZS 4417.1 cannot be used for EESS or ACMA purposes until 1 March 2013. The Preface says the 2012 edition “supersedes the 2009 edition … on 1 March 2013”. It does not say the 2012 edition can’t be used before that date. However regulators indicate that the 2009 editions and the associated legacy processes will remain in place until 1 March 2013.
- The 2009 edition legacy RCM standards can still be used until 1 March 2013, when the EESS is scheduled to commence, as they are currently being used up to now. The RCM registrar will continue to allow new supplier registrations up to the time the EESS commences. New-supplier registrations on the old system will terminate when the EESS process has officially begun.
- Note that under the 2009 edition legacy requirements, a level 1 electrical article under the EESS scheme (i.e non-declared electrical article) is required to have a Certificate of Suitability (or equivalent) from an Australian electrical safety authority before the RCM can be used. This applies too for EMC or radio-communications purposes (note that the legacy requirements don’t apply to telecommunications regulations). For battery-powered or ELV-powered EMC or radio-communications products, a Certificate of Suitability is not required, since it’s not mains-powered, thus out of scope of AS/NZS 4417.2:2009 (+Amdt1)
- Telecommunications products can’t use the RCM in lieu of the A-Tick mark until ACMA updates the relevant Telecommunications Labelling Notice (TLN) to give it legal effect, and formal registrations have commenced under the EESS. See the following web site: http://www.acma.gov.au/WEB/STANDARD/pc=PC_312467 for links to the various labelling notices managed by ACMA.
- Also under the legacy requirements, the supplier identification needs to be marked with the RCM on the products (this won’t be required under the 2012 RCM standard). This does allow several alternative forms of supplier ID, such as the company logo of the responsible company. It doesn’t have to be the registered supplier code number specifically
I hope this is clear. If you have any questions please let me know or leave a commen
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