Michael said:
If I wanted to build a battery-powered device (eg. an LED torch) and sell it
in Australia, are there any regulations/standards I would need to follow?
Interesting reading some of the other points of view. Here are mine:
1. The EMC Framework is very comprehensive in scope and not many products are
excluded from the framework. It would be safe to say there are no exceptions
for consumer products.
2. Compliance level 1 does allow for low risk apparatus to be supplied on the
basis of a declaration and without testing. The device does not need to be
labelled if it is a low risk device as defined in the labelling notice, see 7
(3) of
http://www.aca.gov.au/aca_home/legislation/radcomm/notices/emclabel2001.rtf
3. The definition of a low risk device appears in the above document. That
is:
/quote
low-risk device means a device:
(a) the operation of which has a low interference impact
on other devices using the radiofrequency spectrum; and
(b) that contains any of the following items:
(i) manually operated switches;
(ii) simple relays;
(iii) brushless squirrel cage induction motors;
(iv) conventional AC/AC transformers;
(v) resistive elements (for instance, heating elements).
/end quote
When practically applying this definition the words "any of the following..."
in sub-part (b) should be treated as if it said "only the following..."
So if a product has anything other than just the above parts it will be a
'medium risk' device and it must be labelled and supported by some form of
technical evidence.
4. Note that AC/AC transformers are low risk devices only when by themselves.
AC/DC power adaptors or supplies are not 'low risk' as defined since they
contain semi-conductors (rectifier diodes, etc).
5. The LED torch the original poster asked about would be a medium risk device
as it contains semi-conductors. The Standard applying to luminaires (AS/NZS
CISPR 15) includes battery powered apparatus in its scope but the tests for
radiated emissions (magnetic field) apply only if the operating frequency is
100 Hz or greater.
In my opinion, it may slip through the cracks as there are no specified
requirements. The ACA auditor may have a different personal opinion as to
whether they device escapes the test/labelling requirement and may, for
instance, expect the device to comply with another standard. Get written
advice from the ACA State Manager in the relevant State.
6. With respect to audio and similar products, these do not fall within the
'low risk' category as practically applied by the ACA. As they contain
semi-conductors they are outside the definition of low risk devices. From
personal experience, simple devices such as 78xx/79xx based supply regulators
have failed the conducted emissions tests due to the regulator not being
properly bypassed (small cap at the input).
Simple devices that should be low risk do fail and they fail more often than I
for one expect. Very poor construction and very poor design is usually the
reason.
7. From what I have been told, and from experience, the ACA aims to audit each
company thats has registered to use the compliance mark(s) on a rotational
basis. It is not a random process as our market is small enough to not
require the process be randomised. The auditors follow a checklist that lists
what a 'compliant' folder must contain. They also record the details of any
samples sited, the report numbers of applicable reports and any inadequate
procedural matters relating to the labelling notice (eg. record retention).
8. These audits are paper based and no additional product testing is
involved - but this can be ordered if irregularities are exposed or suspected.
Proper technical enforcement is really complaints driven. A
maker/distributor/import dobs in a competitor and this triggers firstly a
paper audit and a technical audit if necessary.
I know of several companies that have thought the EMC regulations should
not apply to them as they have been building xxxxx product for xxxxx years
without
complaints or problems. In some cases that is fair enough as it is a simple
product and low risk. For others it comes as a shock to find their simple
device needs a test report or worse still it needs substantial change as it
may be non-compliant. An ACA audit is the wrong time to find out as they can
hand out on-the-spot fines (albeit at the auditor's discretion).
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