CHOOSING
THE
CORRECT STANDARD

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4. COMPLIANCE WITH
AUSTRALIAN EMC REGULATIONS

4.1 Compliance with the EMC Framework (Regulations)

The Australian regulations are based on the manufacturers declaration of conformity (DoC). Technical compliance with internationally harmonised standards will be the sole criteria for market access. Once compliance is established, a DoC is prepared and placed in a Compliance Folder. The C-Tick is then affixed to the product prior to marketing. There is no need to submit products or any documentation to the SMA for testing or certification, prior to marketing.

The DoC must have a sound and justifiable basis and it must be able to withstand scientific and judicial scrutiny. A NATA test report has national and international recognition and it will be used as a benchmark by the ACA in any audit. The ACA will always be satisfied with a bon fides NATA report or a report from a body that has an MRA with NATA. In the event that a product's compliance is called into question, the SMA will accept a NATA test report as final in any determination. Where the declaration of conformity is based on non-NATA testing, then the supplier may be required to bear the cost of testing at a NATA test laboratory. The test samples and the NATA test laboratory will be nominated by the SMA. The choice of a competent (NATA) test house that is registered for the specific standard in question will minimise these risks. Remember that many test houses have limited scopes of NATA registrations.

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APPENDIX A :

NATA ACCREDITATIONS - AUSTRALIAN EMC REQUIREMENTS
Industrial, Scientific, Medical	CISPR11	AS/NZS2064
Spark Ignition Engines	CISPR12	AS/NZS2557	pending
TV/Radio/Audio	CISPR 13	AS/NZS1053
Appliances, Motors, Tools, similar	CISPR14	AS/NZS1044
Luminaires, Lighting	CISPR15	AS/NZS4051
Microwave Ovens	CISPR19 (& CISPR 11)	AS/NZS4052 (& AS/NZS 2064)	N/A
ITE	CISPR22	AS/NZS3548
Generic Emissions	EN50081-1	AS/NZS4251.1
Generic Immunity	EN50082-1	AS/NZS4252.1	*
TV/Radio Immunity	CISPR20	AS/NZS4053	pending
Immunity to Electrostatic Discharge	IEC1000-4-2/EN61000-4-2 (IEC 801-2)	no Australian equivalent
Immunity to Radiated Immunity	IEC1000-4-3/EN61000-4-3 (IEC 801-3)	no Australian equivalent	*
Immunity to Electrical Fast Transients	IEC1000-4-4/EN61000-4-4 (IEC 801-4)	no Australian Equivalent

* NATA registration imminent.

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COMPETENT BODY

IEC/ISOGuide 39

NATA Rules for Inspection Bodies

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4.2 Advantages of Using NATA (Accredited) Testing

Testing by an accredited NATA or MRA partner laboratory is the safest way of proving compliance. A NATA endorsed report is acceptable by the ACA and most of Australia's trading partners including the EU countries. A NATA report can only be issued by a laboratory performing the test, if that laboratory is NATA registered for the specific standard applicable to the device. Accredited testing will minimise the risks should a dispute arise with the regulatory agencies. Non-accredited testing should be avoided as there is no guarantee of the reliability or the accuracy of the results. The use of non accredited testing is cheaper, but in practice it is rejected by regulators.

NATA accredited facilities meet the requirements of ISO/Guide 25, demanding full calibration traceability of measurement equipment to the national standards at the National Measurement Laboratories (NML) of the CSIRO, and thereby to international standards. Calibration traceability is essential for the acceptance and recognition of test reports. NATA accredited test houses have been thoroughly evaluated by NATA and accredited as meeting internationally recognised standards for good laboratory practice, the availability of the necessary test facilities, an adequate level of technical competence and the appropriate quality management systems. A NATA endorsed report gives the highest confidence in technical competency and in the reliability of the test results.

NATA has a mutual recognition agreement with the Testing Multilateral Agreement Group of the European Co-operation for Accreditation of Laboratories (EAL). NATA endorsed reports are acceptable as technical grounds for making a Declaration of Conformity by the following international bodies:

* EUROPE NAMES, STALAG, DANK, SWEDE, SIGNAL COFRAC, RELE, ICLAB, FINAS, NA, SAS

* AUSTRALIA NATA, AUSTEL

* USA NVLAP, A2LA. FCC Listed for Parts 15 and 18

* HONG KONG HOKLAS

* NEW ZEALAND TELARC Also listed with Ministry of Commerce

Similarly, reports which carry the endorsement of one of those international bodies are recognised as having equal status with NATA reports.

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4.3 Risks of Non-NATA (Non-Accredited) Testing

If non-NATA testing is used, there is often an unacceptable risk of non-compliance and the possibility of interference occurring. The supplier is accepting total responsibility for EMC compliance by not using NATA accredited testing. If, for any reason, a product is found to be non-compliant, the supplier and the individual making the declaration, may be exposed to criminal sanctions or civil and legal liability. The use of NATA testing provides the best possible protection to the person signing the declaration of conformity since it means that the supplier has exercised due diligence and this may be used as a defence in any legal dispute.

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4.4 Which Route to Compliance - TCF or Standards ?

The most common means of Compliance with the EMC framework is by testing against the CISPR/SMA standards. In a some cases, a Technical Construction File (TCF) can be prepared and submitted to an SMA recognised Competent Body for assessment. The TCF route is intended to be used when the product is too large or impossible to test, or when there are a large number of variants of a basic model. Some other cases represent a very small number of products and will not concern most suppliers under the current scope of the Australian EMC Framework.

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