Monthly Archives: February 2013

[:en]

The RCM Mark

As many of you are aware, there are changes coming to the RCM marking system in Australia. Today (March 1, 2013) AS/NZS 4417.2:2012 comes into effect. AS/NZS 4417.2 is the standard which specifies the requirements of the RCM mark and its placement on electrical and electronic products. In this latest edition, the classification of electrical products has changed from a system of non-declared and declared articles into a 3 tier risk classification, where level 3 is the highest risk and level 1 is the lowest risk. There are different requirements for each level of risk. Please note that the company registering for RCM has to be based in either Australia or New Zealand. This means that overseas manufacturers are not able to register for RCM. The importer in Australia or New Zealand must register for RCM and will be known as the “Responsible Supplier”. We suggest you get in touch with your importer and make sure they are familiar with the new regulations.

The EESS

The EESS is the new regulatory system which is designed to be used with the RCM mark. At this stage only Queensland has the legislation in place for the new system (from today March 1, 2013) and New South Wales has declared they will not be using the new system. We are not certain when the other States and territories will be introducing the legislation. There is substantial uncertainty about how the new system will work out for importers, but there is no cause for concern. For the high risk items, you will still need an SAA certificate and we are working with ERAC to ensure we can upload the certificate details to the national RCM database. This will enable your importer to register the high risk items and there is a transition period to ensure they have time to do so. It does not require any action from overseas certificate holders or manufacturers or laboratories.

Questions

We are sure you will have a lot of questions about the EESS and the new RCM system. Remember, the SAA certificate will be required as normal. The RCM system has been changed and has shifted the responsibility to the importer. The importer will be responsible for paying the new system fees and ensuring the product is correctly tested and marked, but they will need the SAA certificate from you, exactly as they do now. If you have any questions, please contact me and I will try and answer as best as I can.[:]

[:en]

Multi-function Products

There are more and more products being developed with multiple functions. It is vital that ALL functions of any equipment are tested and reported. Please think carefully about what needs to be tested or inquire with us before testing commences to make sure the application goes smoothly when we receive it.

RCM Changes

We have had a meeting with the ERAC secretariat and we will report fully what the new requirements are in the next newsletter. There are many changes, but there is no reason to panic as there is an adequate transition period.

Application Forms

In Section 7 on the application form – please complete all the test report details and the Declaration section. It is a legal requirement of the SAA certification scheme, that the client declare the product complies to the Australian/NZ Standard. Forms that have not been completed correctly will be returned.

Payment of Application Fees

When transferring funds into our account, please ensure you cover the costs of all the transfer fees and transfer Australian Dollars. Once the transfer to complete please forward a remittance advice showing details of the payment. The remittance should clearly state your company name (including branch) and the invoice number or project reference number you are paying.[:]

KUNG HEI FAT CHOY!

Our best wishes to our clients for the New Year!

The New RCM System

There is a large amount of confusion regarding the new RCM system which is being introduced progressively into all States of Australia and New Zealand except New South Wales. At this stage, Queensland is the only State which will have the new system in place on March 1 2013. As far as we are aware no other State or New Zealand has the legislation in place for the new system.

What has not changed and will not change?

• Items currently known as Declared Articles will still require a Certificate of Approval under the new system.
• A Certificate of Approval or Certificate of Suitability may still be applied for and issued to a company or individual outside of Australia and New Zealand. This means Chinese manufacturers may still hold the SAA Approval in their name.
• All in-scope electrical products must comply with the relevant safety standard, just as they always have done. In-scope is defined in the RCM standard and basically applies to any product which is hooked up to the electricity grid in Australia or NZ.

What will change?

• Under the new RCM rules, the company applying to register for RCM must be an Australian or NZ company with a physical local address which is where their company operates. Chinese companies may no longer apply for RCM registration.
• SAA must register all certificates of approval on the RCM database. However, as we are under New South Wales jurisdiction, we are not sure at this stage if we will be required to do so. We plan to act in good faith and register your certificates on the RCM database as soon as it is available and we can be sure that the information is secure as per the new RCM rules.
• Products will in the future be split into 3 risk categories – levels 1, 2 and 3. Level 3 products will likely be the same as declared articles and will require a certificate of approval.
• All products from all 3 levels will require a technical construction file with a test report and other documents depending on the level of the product. This will need to be held by the importer, so the importer in future will require a copy of the test reports.
• There are Government fees for each high risk product which must be paid annually by the importer. These products must all be registered on the RCM database. This work can be done by an authorised consultant on behalf of the Responsible Supplier which is the company which has registered for the RCM mark in Australia or NZ.

When will it change?

We are really unsure. The following statement appears on the ERAC (Electrical Regulators) website:
“Clarification on the proposed Electrical Equipment Safety Scheme
It is apparent that a number of suppliers of electrical appliances and other industry participants are concerned about the proposed introduction of a new scheme that will regulate the supply of electrical goods in Australia.
Please note that no changes have been made to the current system of certification in place for the safe and legal supply of electrical goods. This means that the existing requirements remain in place. Suppliers can continue to seek advice from regulatory authorities in any state as to their obligations. There are no changes to the current system that are to be made in the immediate future.
It is important to note, that the proposed national scheme is not supported by all jurisdictions. NSW does not support the proposed scheme and is not participating. The proposed scheme is dependant on participating jurisdictions enacting the appropriate legislative amendments. Until such time, the existing requirements for suppliers remain in place.”
Source: http://www.erac.gov.au/
Further to the above statement, we have written to the Queensland regulator requesting clarification on what they will require. As soon as we get a response, we will inform you.