Newsletter #1 2013

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.