Australian EMC

sdouglas Fri, 13 Jun 1997 01:35:29 +0000

What follows are excerpts of a letter I received from Mr. David Brumfield 
re: EMC Compliance in Australia. Mr. Brumfield is the Assistant Manager of 
the Radiocommunications Standards section of the Australian Spectrum Management 
Agency. I asked several questions and he responded to each in turn. Hope you 
find this useful.


Question #1 
Who is considered the Australian Importer or Australian Agent? Our dealer
 who may or may not have an office in Australia? The first customer who buys
 one of our products? Could this be one of our employees in our Hong Kong or
 United Kingdom offices? To my knowledge, we do not delegate authority for
 anyone to act as our representative except in the case of selling our
 products.

Answer #1
"In accordance with the EMC requirement any person of company who imports a 
product whether by direct mail, sea container or air cargo and that product 
is intended for sale in Australia, that person or company is the importer 
and the product is subject to the EMC compliance requirements.

On this point do you envisage individuals or companies bringing into Australia 
your product for their own use? If the product is brought into Australia by 
a single customer and is not intended for sale on the open market here then 
the product is exempt from the EMC framework."

Question #2
What if we do not have anyone resident in Australia? Who is it that must "hold
 the Declaration"?

Answer #2
"The agency does not insist that you have somebody resident in Australia. 
The onus for responsibility for placing a product on the market is on the 
importer. You may assist this importer by providing sufficient information
 to support a declaraion of conformity with the standard by the importer."

Question #3
Is our Declaration issued for the CE Mark an acceptable substitute for an 
Australian version? Would it be if we added the reference to AS/NZS 3548:1995 
to our existing declaration?

Answer #3
"The declaration of conformity must be in the Australian format and be signed 
by a responsible person resident in Australia."

Question #4
Our existing certification label contains our name and address along with
 the CE and CSA marks as well as the appropriate safety information. Is 
that acceptable for the labeling requirements?

Answer #4
"The existing labelling would not meet our requirements and would be deficient
 in important information such as the C-Tick mark and the identity of the 
importer. This agency requires that information for the traceability of the 
product and its importer, particulalry at the time of audit of an importer's 
compliance folder. The legal information relating to this requirement can be 
accessed on our web page."

Question #5
Is the use of the C-TICK marking mandatory or optional?

Answer #5
"The use of the C-Tick is mandatory for products placed on the Australian
 market."

Question #6
How do I deal with private label products? We have arrangements with several 
other companies that sell our products under their own labels. Sometimes the
 certification label I apply has our name on it and sometimes the label 
carries the name of the private label company. In both cases we may ship 
direct to the end-user.

Answer #6
"If the product is shipped direct to the end user and is not intended for
 sale on the open market then that product is exempt from the EMC framework.
 However, if it is sold at a later stage the product will need to be labelled,
 and the end user becomes the importer and he would be required to establish a 
compliance folder. See point 1."

Question #7
If necessary, will you issue a "Supplier Number" to our company in the USA 
and allow the Declaration to be held here at the main office with copies held 
in the UK and/or Hong Kong?

Answer #7
"A supplier code can not be issued directly to an overseas company. If the
 overseas company has an Australian office or Australian subsidiary domiciled
 in this country the supplier code would be issued to that company or 
independent importer in Australia. The declaration would need to be signed 
by the Australian connection and be made available when requested within 10 
days of tha request."

Question #8
Would you please send me a complete copy of your handbook on the EMC Framework
 for Residential, Commercial and Light Industry?

Answer #8
"Full information about the EMC framework can be found on this agency's web
 page http://www.sma.gov.au/. A hard copy of the"Information to Suppliers" is
 enclosed."

That is the end of the transcript. A hearty thank-you to Mr Brumfield for his 
clear answers.

Regards to all,

Scott Douglas
Principal Compliance Engineer
ECRM Incorporated
Telephone:  1-508-851-0207
Facsimilie: 1-508-851-7016
e-mail:      sdoug...@ecrm.com

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Date: 11 Jun 1997 13:58:21 -0400
From: DouglasScott <sdoug...@ecrm.com>
Subject: Australian EMC
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Australian EMC

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