All, A couple of clarifications may be helpful. EMC Requirements Australian EMC regulations do not include any 'product safety' requirements. As such, the Compliance Folder for EMC should include:
* a DoC declaring compliance with currently acceptable versions of AS/NZS CISPR 22 or CISPR 22 or EN 55022; and * a test report from a reputable test lab confirming compliance with the same standard; and * the usual product information required to uniquely identify the device This is all that is required in terms of EMC. NOTE: Just a warning that EMC Handbook as mentioned by Ron should not be used as the definitive last word on compliance. While the EMC handbook si helpful in describing the requirements in everyday language, it is not the actual instrument of regulation and as such may not necessarily accurately reflect the requirements at any given time and may well lag behind in describing changes made to the regulations. To be absolutely sure you are dealing with the current requirements you should always refer to the regulatory instrument itself, i.e. the "Radiocommunications Labelling (Electromagnetic Compatibility) Notice 2008" (commonly referred to as the EMC Labelling Notice). This can be found at: http://www.acma.gov.au/WEB/STANDARD/pc=PC_310703 <http://www.acma.gov.au/WEB/STANDARD/pc=PC_310703> The actual regulatory instrument is kept at a different government website however, it is easier to start from the above link on the ACMA website. Safety Requirements In terms of electrical safety, if I understand correctly this "in-line filter" device is a stand-alone device that includes a plug to plug into the mains and also a connector for the PC mains plug to plug into and it incorporates overvoltage and line filtering components. If this is the case, then sounds like this device, most likely, would be classified as a "Control or Conditioning Device" under Australian Electrical Regulations and is therefore a 'Declared/Prescribed Article' and requires formal approval by an Australian Electrical Authority. Although some of this has been mentioned before, every device that connects to the mains supply in Australia is captured by the Electrical Regulations in each Australian State or Territory, administered by that State's/Territory's Electrical Authority. These electrical regulations divide products into two categories as previously described by others. These being "Prescribed or Declared Articles" and Non-prescribed or Non-declared Articles" (terminology depends on the State or Territory). For Prescribed or Declared Articles formal approval from the Regulatory Authority in one of the Australia States/Territories is required. Approval from any State/Territory is accepted in all other States/Territories. As previously stated by someone else, prior to sale/supply, such devices must display the approval number issued by the approving Regulatory Authority. Using the NSW State Electrical Regulations as an example, this device is captured under category 8 of the 'Declared Article's category listing, see extract below: 8. CONTROL OR CONDITIONING DEVICE - an electrical device which - (a) is a household type; (b) is for controlling or conditioning the electrical input to electrical apparatus; (c) is self contained; and (d) connects to supply by means of a flexible cord and plug, appliance inlet or pins for engagement with a socket-outlet. Class specification: AS/NZS 3100 and AS/NZS 3197:2005 with amendment 1. The applicable standard would be AS/NZS 3197 as identified above. The mains plug and mains cordage (if it had cordage rather than the device incorporating mains plug pin connectors) are also in their own right, Declared/Prescribed Articles and must be approved and display the approval number. Requirements for Non-Declared/Non-Prescribed Articles For Non-prescribed or Non-declared Articles, while there is no requirement for formal approval etc the device is still captured by the Electrical Regulations and must comply with the requirements for Non-prescribed or Non-declared Articles, i.e. AS/NZS 3820. Those requirements are as described by Peter in an earlier email, i.e.: Non-prescribed electrical equipment A person who sells non-prescribed electrical equipment must comply with section 120 of the Regulation. Generally speaking all non-prescribed electrical equipment must comply with the safety criteria of AS/NZS3820 (Essential safety requirements for low voltage electrical equipment). This would include, but not be limited to: · a test report showing compliance to the relevant Australian product standard; · if no relevant Australian product standard exists, a test report showing compliance to another relevant standard such as AS/NZS3350.1, AS/NZS60335.1 or AS/NZS 3100; · a certificate of approval issued as per relevant Australian/NZ legislation; · another method consistent with clause 5 of AS/NZS 3820 Usually, the easiest way means of complying is by way of the 1st option of using a test report showing compliance with with the relevant Australian product standard. Consumer Protection Laws Consumer protection laws by way of the Australian Trade Practices Act also require the device be "safe" and "fir for purpose". "Safe" is defined as complying with the relevant Australian product safety standard or generic safety standard where no product standard exists so by default, in complying with the Electrical Regulations of the various Australian States/Territories you comply with the consumer protection laws. While the consumer protection laws concern all aspects of safety, not just electrical safety, by complying with the Australian product safety standard you would be considered to have taken all reasonable precautions. Safety of a Telecommunications Device The Australian telecommunications regulations have specific safety requirements and require the product Compliance Folder includes, apart from other things, a test report to AS/NZS 60950.1 from an RTA (Recognised Testing Authority). A listing of RTA test labs is maintained by NATA (National Association of Testing Authorities). A CB test lab is not necessarily an RTA so a CB test report may not be acceptable. The issue mentioned by Ron about ACMA auditors not accepting a test report to IEC 60950.1 + Australian National deviations etc should not occur where: * the IEC 60950.1 report also clearly states compliance with Australian National deviation according to AS/NZS 60950.1:2003 (the report should clearly spell out the Australian standard, including the version); and * the test report is from an RTA listed test lab; and * is an "endorsed" test report (i.e. clearly states the test report is produced under the test labs accreditation to test to that standard and identify the accrediting organisation etc) Hope this helps along with the input from others. Best regards, Kevin Richardson Stanimore Pty Limited Compliance Advice & Solutions for Technology (Legislation/Regulations/Standards/Australian Agent Services) Ph: 02-4329-4070 (Int'l: +61-2-4329-4070) Fax: 02-4328-5639 (Int'l: +61-2-4328-5639) Mobile: 04-1224-1620 (Int'l: +61-4-1224-1620) Email: kevin.richard...@stanimore.com or kevin.richard...@ieee.org URL: www.stanimore.com Confidentiality This material (this email including all attachments) may contain confidential and/or privileged information intended to be read or used by the addressees only. If you are not one of the intended recipients, any copying, disclosure, distribution, use of or reliance upon this material is prohibited. If you receive this material in error, please immediately notify Stanimore Pty Limited and delete/destroy all copies (electronic and hardcopy) of this email and all attachments. While the sender tries to ensure the accuracy of the information contained in this material, Stanimore take no responsibility for any actions taken as a result of receiving this material or for any consequence of its use. -----Original Message----- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Pickard, Ron Sent: Saturday, 21 February 2009 4:34 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: Australia C-Tick and safety requirements Dan, Jim et al, I believe the Australian document that you were requesting is the ACMA’s EMC Handbook, which can be accessed at: http://www.acma.gov.au/webwr/aca_home/ ublications/reports/industry/manuals/emcbook.pdf <http://www.acma.gov.au/webwr/aca_home/ ublications/reports/industry/manuals/emcbook.pdf> The ACMA does not impose safety requirements for C-tick (ACMA) or RCM (Regulatory Compliance Mark, owned by AU & NZ regulators) markings, but I believe the “state authorities” that Peter refers to do and are the provincial electrical authorities (refer to Appendix D) which must ensure that equipment attaching to the electrical power grid is safe and in almost all cases pertains to power supplies and power cords. Please note that in some cases, registration will be needed. Also, Appendix E may also apply to your product. So, it is a good idea to also include an acceptable Australian/New Zealand safety report and the electrical authority’s acceptance, where applicable, into the product’s DofC and the compliance folder. In regard to your last question, although a CB certificate/report with AU/NZ deviations does indeed cover your product for safety in Australia & New Zealand, the ACMA has been a bit persnickety during compliance folder audits about it preferring actual AS/NZS 60950-1 reports generated from NATA accredited labs. If anyone can point to an actual ACMA requirement on this point, we all would be grateful. I hope this answered your questions and as always, I stand to be corrected where needed. Comments? I look forward to your reply. Best regards, Ron Pickard ron.pick...@intermec.com <mailto:ron.pick...@intermec.com> ________________________________ From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Jim Robson Sent: Friday, February 20, 2009 10:47 AM To: pmerguerian2...@yahoo.com; EMC-PSTC@LISTSERV.IEEE.ORG; Dan Roman Subject: RE: Australia C-Tick and safety requirements Peter, I have been researching this issue also. Can you tell me what Australian document says that C-tick marked ITE (non-Telco) equipment must comply (and/or be tested to) with AS/NZS 60950? The Telecommunications Labelling (Customer Equipment and Customer Cabling) Notice 2001 definitely calls out AS/NZS 60950 for Telco equipment. The Radiocommunications Labeling (EMC) Notice 2008 which covers ITE does not call out AS/NZS 60950. You also wrote "does not require a safety approval from a state authority". Do mean AS/NZS 60950 testing must be done at an approved lab and then cite AS/NZS 60950 on the Declaration of Conformity? Regards, Jim Robson ________________________________ From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of peter merguerian Sent: Friday, February 20, 2009 7:43 AM To: EMC-PSTC@LISTSERV.IEEE.ORG; Dan Roman Subject: Re: Australia C-Tick and safety requirements For safety, this is not a perscribed equipment and therefore does not require a safety approval from a state authority However, the product must still comply with the Australia safety requirements in AS/NZS 60950.1. This standard is harmonized with IEC60950-1 so if you comply with the standard and its' Austrlia devioations, you're good to go. Peter Merguerian --- On Fri, 2/20/09, Dan Roman <dan.ro...@dialogic.com> wrote: From: Dan Roman <dan.ro...@dialogic.com> Subject: Australia C-Tick and safety requirements To: "EMC-PSTC@LISTSERV.IEEE.ORG" <EMC-PSTC@LISTSERV.IEEE.ORG> Date: Friday, February 20, 2009, 7:23 AM Hello all, I’m passing along two questions for a friend that I cannot answer because they are outside of my product area of expertise. The product in question is a passive line filter for use with a PC. It contains overvoltage and line filtering components (some coils, caps, and MOVs). 1. Does the C-Tick mark for non-telecom equipment require both EMC and safety declarations? I know that for the telecom equipment my company produces, the ACA requires telecom, safety, and EMC (A-tick and C-tick) but I don’t know if the safety portion is a telecom specific requirement or not. If the answer is the C-Tick is for EMC only, are there other requirements for safety or other marks that would apply to this product in Australia? I am sure there must be. 2. Does a passive device like this fall under EMC requirements? CISPR 22/EN55022 don’t specify a lower frequency limit exempting products, so this passive line filter connected to a 50 Hz supply would appear to need testing. Everything I deal with has clocks in excess of 1 GHz these days so this question never came up where I work! It is always interesting getting questions outside of your normal day to day experience. -- Dan Roman, N.C.E. 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