RCM compliance review
RCM compliance review
If your product is covered by the EESS or the ACMA's requirements, meeting them is not optional — and once you do, you must mark the product with the RCM. Applying that mark without evidence behind it is unlawful. This review tells you in writing whether yours is genuinely supported, before a regulator, a retailer or an acquirer asks the question for you.
The RCM is not optional
If your product falls under the EESS or the ACMA's requirements, you have to meet those requirements. That is not a choice. And once you hold proof that the product complies, you have to mark it with the RCM before you sell it in Australia.
Nobody issues you the RCM. You apply it yourself. In doing so you are telling the regulator, your customer and the market two things: that the product meets every requirement that applies to it, and that you hold the evidence to prove it.
Applying the RCM without that evidence is unlawful. It is not a paperwork slip. It is a false claim of compliance, and the supplier who made it is the one who answers for it.
This is why RCM problems are so common and so hard to spot. The mark on a product with a complete, current evidence file looks exactly the same as the mark on a product whose test report expired two years ago, was written against a superseded standard, or covers a different model. You cannot tell by looking. Neither can your customer. A regulator, an auditor or a retailer's compliance team can.
What the review covers
- Scope. Is the product in scope of the EESS, and of which ACMA arrangements? Intended use drives this, and it is where most disagreements start.
- Risk classification. Level 1, 2 or 3, determined against the equipment classification rather than an assumption.
- Safety evidence. Test reports and certificates checked for currency, scope, standard edition, and whether the model tested is the model you supply.
- EMC and radio evidence. Emissions, and radio and RF exposure evidence where the product transmits.
- Registration status. Responsible Supplier registration, and equipment registration for Level 2 and Level 3 items.
- Records and declarations. The compliance records and declaration of conformity you are required to hold and produce on request.
- The mark itself. RCM artwork, size, legibility, permanence and placement against AS/NZS 4417.1 and AS/NZS 4417.2.
- Supporting information. Rating markings, warnings, and the instructions supplied with the product.
What you receive
A written review report setting out each finding, whether it is a clear non-conformity or a matter of interpretation, the exposure it creates, and a prioritised remediation plan. Where testing or certification is needed to close a gap, the report scopes it so you can decide before committing.
Common questions
Frequently asked questions
We already apply the RCM. Why would we need a review?
Because applying the mark is the claim, not the proof. The RCM says you hold evidence that the product meets every electrical safety, EMC and telecommunications requirement that applies to it, and that you are registered where registration is required. The mark itself proves none of that. If the evidence is missing, expired or written for a different model, the mark is unlawful — and it looks exactly the same as a compliant one. A review establishes whether yours would hold up.
What do you actually look at?
Scope and risk classification, the safety and EMC evidence behind the claim and whether it was issued against the standard edition currently in force, supplier and equipment registration status, the compliance records and declaration of conformity, and the RCM artwork itself — size, legibility, permanence and placement against AS/NZS 4417.1 and AS/NZS 4417.2. Then the rating markings and the instructions.
What do we get at the end?
A written report: what is compliant, what is not, what is arguable, and a prioritised list of what to fix first. Where a finding is a judgement call rather than a clear failure, we say so and explain the reasoning, so you can decide with your eyes open rather than inherit our opinion as fact.
When is the right time to do this?
Before launch is cheapest. The other common triggers are a retailer or tender asking for evidence, acquiring a product range or a business, taking over a portfolio someone else built, changing a supplier or factory, a standard being superseded, or a competitor product in your category being recalled.
Want to learn more?
Speak to a Chartered Professional Engineer about your product, your target market and the approval pathway that actually applies to it.
Talk to an engineer
Is your RCM actually supported?
Send us the product and whatever evidence you hold. We will tell you what stands up, what does not, and what to fix first.