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NATA Accredited Testing...
adding value to your product
A Client Information Bulletin by
Chris Zombolas
Technical Director
EMC Technologies Pty. Ltd.
CONTENTS
INTRODUCTION
As of 1 January 1999 all electrical/electronic devices entering the Australian market, either locally or by import, must comply with the appropriate EMC standard if they fall under the scope of one of the EMC standards mandated by the Australian Communication Authority (ACA). Compliance is by means of Declaration of Conformity (DoC) and suppliers placing products on the Australian market must ensure that each product meets the appropriate EMC standard and be
labeled with the C-tick mark.
This article will discuss the critical advantages afforded by NATA (National Association of Testing Authorities) accredited testing as a rigorous basis for proving compliance with the C-tick and international EMC regulations. It will be shown that testing is the most economical path to compliance for the majority of products and that the application of a NATA accredited test will greatly enhance the value of a product and facilitate its access to lucrative global markets.
ENFORCEMENT OF EMC REGULATIONS
In the event that a product’s compliance is called into question, the ACA will carry out an audit of the relevant compliance folder and may undertake further investigations. The ACA will accept a NATA test report as final in any determination. For
willful violations, penalties may apply to both individuals and companies. Regulations are enforceable under the Radiocommunications Act 1992, the Trade Practices Act 1974, the Telecommunications Act 1997 and the Crimes Act 1914.
A primary offence under the Radiocommunications Act for the supply of a non-standard device may result in the seizure and forfeiture of stock and up to $160,000 criminal penalties. Imprisonment is also possible under the Crimes Act and offences are also committed for breaches of the C-Tick
labeling provisions under Trade Mark and Copyright regulations. Similarly harsh penalties are applicable in most other
countries that have EMC regulations.
The ACA will accept a NATA test report as proof of compliance. The use of NATA testing provides the best possible protection to the person signing the DoC since it can be used as the basis of a “due diligence” defence in any legal action. Where the DoC 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 ACA.
NATA REQUIREMENTS FOR ACCREDITATION OF TEST LABORATORIES
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 must be 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. ISO 9002 alone is not acceptable for accreditation of
laboratories as it does not include the key criteria of technical competence and adequate facilities. NATA accredits laboratories against each EMC standard and a test report may not be endorsed with the NATA logo unless the test house is accredited to the specific standard. NATA
laboratories must also perform on-going proficiency tests in the field of accreditation and are continually assessed and audited against the requirements of IEC/ISO Guide 25.
ADVANTAGES OF USING NATA (ACCREDITED) TESTING
Testing by an accredited NATA or MRA (Mutual Recognition Agreement) partner laboratory is the safest way of proving compliance. A NATA endorsed report is acceptable by the ACA (Australian Communications Authority) and most of Australia’s trading partners including all EU (European Union) countries. 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 generally a little cheaper, but in practice it may be rejected by the regulator. A NATA endorsed test report adds value to your product by providing it with the most credible and internationally accepted compliance status available.
NATA’s Global Recognition
NATA has an MRA with the Testing Multilateral Agreement Group of the European Co-operation for Accreditation of Laboratories (EAL). Reports endorsed by any of the following international bodies are considered equivalent to NATA.
- EUROPE UKAS/NAMAS, STANAG, DANK, SWEDAC, SINAL COFRAC, RELE, ICLAB, FINAS, NA, SAS
- AUSTRALIA NATA
- USA NVLAP, A2LA
- HONG KONG HOKLAS
- NEW ZEALAND IANZ (formerly TELARC)
FACTORS IN SELECTING AN EMC TEST HOUSE
Test Time and Test Costs
The cost of testing is directly proportional to the test time and the use of the test facilities. The number of applicable tests and the nature of the product will impact on the total test time. Devices which are slow to respond or difficult to exercise during the testing require longer test times and are therefore subject to higher test charges. Test house charges in Australia range from A$200-$2000 per test depending on the nature of the test, the technical competence of the test house, the sophistication of the test facilities and the accreditation status.
Appropriate Standards Accreditations
A test house may use NATA or an equivalent endorsement when it is accredited for testing to just one standard. Some NATA accredited test houses have a very limited scope of accreditation, often being accredited to one standard only. Some consultants are NATA accredited as Competent Bodies and Conformity Assessment Bodies (CAB). The NATA (or equivalent) logo often appears in advertising literature giving the perception that the Competent Body or CAB organisation is accredited for testing. A NATA test house with limited accreditation may appear to have wider terms of accreditation than is actually the case. This practise is misleading and results in confusion among those unfamiliar with the vagaries of NATA rules for the use of the NATA logo.
When selecting a Test House, the supplier must be satisfied that the laboratory is NATA accredited to the appropriate standard as well as all the applicable clauses of that standard. A NATA endorsed test report may only be issued by a
laboratory accredited to the specific EMC standard including all the relevant clauses.
Risks of Overseas Testing
The cost of EMC testing in Australia is around 50% of the cost in South East Asia and 50% to 75 % of the cost of testing in European and North American test houses. Testing overseas can be extremely risky. The probability of compliance failure is very high for first time tests, particularly for those products tested against the more stringent residential class B limits.
The initial savings offered by budget testing are quickly erased if a failure occurs as the time required to effect solutions and retest
incurs additional costs well above the initial outlay. The cost of freight, courier fees, phones and faxes will result in further escalation of the costs.
The supplier is advised to select an Australian test house that allows you to attend the testing. This ensures that the testing proceeds smoothly and allows you to assist in overcoming compliance problems should they occur. In general, budget testing is non-accredited and should be avoided.
QUESTIONS TO ASK THE TEST HOUSE
- Are you a NATA accredited Test House?
Some consultants are NATA accredited Competent Bodies or Conformity Assessment Bodies (CAB). The role of the consultant is to review
documentation and they must not perform testing unless they are specifically accredited by NATA.
- What is the Scope of the NATA Accreditation?
Will I get an unconditional NATA endorsed test report.? Does the test house have specific accreditation for the appropriate test standards that my product must satisfy to earn compliance? For example, a test house accredited by NATA for EMI testing to CISPR 22/AS3548 cannot issue a NATA endorsed report for testing AS1044/CISPR 14 or to any other standard not covered by the terms of the accreditation.
- Does the Scope of accreditation cover the complete standard?
An accreditation for a particular standard may limit the frequency range or exclude some of the clauses in that standard. A limited accreditation may mean that it may not be possible to establish compliance with the complete standard
- Is the Testing Subcontracted to another Test House
Does the test house have an in-house test capability or will your test be subcontracted to another test house? Double handling such as this will inevitably inflate test costs, delay report generation and inevitably frustrate the flow of correspondence required if a failure and fix are required.
- NATA Test Report
Will a NATA endorsed report be provided? Is there a surcharge for a NATA report? How many copies of the final report will I be entitled to receive?
- Test House Expertise
How experienced are the staff actually engaged in performing the tests? The experience and proficiency of the test house personnel will directly impact on the test duration and on the accuracy of the test. The use of automated and sophisticated compliance test equipment and test procedures enables greater efficiency in testing time and test costs.
- Design Review
Does the quoted price include a desk/design review prior to the testing program? The probability of test failure is very high for first time testing of most products. A brief desk/design review by an experienced EMC test house can quickly identify potential trouble spots and help to minimise potential test failures, and thereby minimise test time and testing costs.
- What Happens if my product fails the EMC Tests?
What is the test house policy if my product fails the compliance test? Does testing proceed to conclusion followed by the issue of a non-compliant report? Does the test house automatically perform simple diagnostic tests once a non-compliance has been recorded? A little time spent on fault investigations at this stage can save one pass through the test house. Does the test house supply spectrum plots of EMI measurements? Spectrum plots of different test configurations are of enormous help in the diagnosis and rectification of an EMI failure. If your product fails the test, what are the additional costs for a retest? Does the original fee apply again?
- Witnessing the Test
What is the test house policy on allowing you to witness the testing of your product? Is it permitted? If so, is there an surcharge? Witnessing testing provides a valuable insight into the EMC testing process and provides hands-on training that is not generally available. The future value of this experience in new product design strategies is generally accepted as invaluable.
- EMC Consultation
Does the test house provide a consultation service to assist in achieving compliance? What are the levels of experience and qualifications of the consultant? Your company can benefit enormously from the test house experience gained from thousands of tests and fixes. The cost of the consultation charge is slight in comparison to the cost of the many man-hours that your company’s engineers will have to devote to rectifying EMI fixes that are essentially routine for an experienced test house technical team.
CONCLUSION
Most countries have government regulations that mandate compliance with EMC standards before products can be legally marketed. Selecting an experienced EMC Test House accredited to test to all of the ACA standards, and that is also a Competent Body, will provide you with a valuable partner who can offer all the expertise required in dealing with the complexities of regulatory approvals, standards and specifications.
The use of non-accredited testing, whether in Australia or overseas, may expose you to unnecessary risks. The use of NATA accredited testing is the lowest risk approach to EMC compliance and will also facilitate global acceptance of your product. NATA reports are accepted by Competent Bodies and may be also used in the preparation of a TCF (Technical Construction File). NATA test reports add value to your product and are your product’s passport through trade barriers into lucrative overseas markets.
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Compliance Deadline Information
NEW LEGAL REQUIREMENTS FOR
MANUFACTURERS, IMPORTERS AND SUPPLIERS OF ELECTRICAL/ELECTRONIC EQUIPMENT
As from 1 January 1999, ALL products under the scope of the ACA standards, must comply with the appropriate Australian Standard and may no longer be marketed without the C-Tick label. Marketing of a non-compliant product with a label is also illegal. Make sure your product meets the Standard.
Importers, manufacturers and suppliers of electrical/electronic equipment, and their customers need to be aware of Regulations which have been in force since 1 January 1997 to control Electromagnetic Interference (EMI).
Electrical equipment sold after this date must comply with appropriate Australian Standards for interference which limit electromagnetic radiation from electrical/electronic devices. Pre-existing models on the market may continue to be sold until 1 January 1999 without compliance. The selling of non-compliant equipment is illegal after 1/1/99.
What is EMI?
EMI is the unintended radiofrequency emissions from electrical and electronic products, which have the potential to interfere with the operation of other products. Common examples of EMI are computers, hair dryers or vacuum cleaners interfering with television / radio reception or telephones. EMI may also manifest itself with domestic appliances such as refrigerators or electric ovens interfering with personal computers. While some EMI is a nuisance it can be dangerous if it interferes with critical functions of industry plant, aircraft control systems, motor vehicles or medical equipment. The ElectroMagnetic Compatibility (EMC) framework has been put into place to reduce the disturbances caused by EMI.
What is EMC?
ElectroMagnetic Compatibility (EMC) refers to the ability of an electrical or electronic device or system to function satisfactorily in its environment without introducing intolerable electromagnetic interference to other devices in that environment. Most electrical equipment is required to be compliant to the appropriate EMC standard and should be
labeled with the C-Tick mark.
What is a C-Tick mark?
The C-Tick mark is a compliance trademark registered to ACA by the Trademark Office and indicates compliance with the EMC framework. It may be used by the ACA to trace the supplier of the equipment.
What do I have to do?
The regulations are aimed at suppliers, importers and manufacturers of electrical/electronic devices (including PC assemblers), who offer products for sale on the Australian market.
If you are a supplier you must:
- Determine whether your products meet the appropriate Australian
EMC Standard or its international equivalent. You will need to have products tested to determine whether they meet the standard.
- Prepare a Compliance folder for each product that complies, including –
- A description of the device, brochures or specification sheets
- EMC test reports original or certified copies.
- A signed Declaration of Conformity stating that the product complies with the Standard. It must be signed by an Australian citizen or resident who is in a position to represent the company. This is your legal statement that the product complies.
- Apply to the ACA, to use the C-Tick mark. The C-Tick mark is a trademark registered to the ACA by the Trademark Office and indicates compliance with the Standard.
- After receiving the supplier code, label the product with the C-Tick
mark. The labeling
of new products became compulsory from 1 January 1997. It will be compulsory for all products including existing products after 1 January 1999.
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EMC Compliance Seminars
Test House? TCF? Competent Body?
What does C-tick mean for you?
What are your obligations?
Be informed!
The Government regulations on Interference for ALL electrical/electronic products will be enforced from the
1st January 1999 when the two year transition period ends. All non-compliant products including existing
products must be removed from the market and not offered for sale. Severe penalties may
apply.
Following the success of seminars in Melbourne and Sydney, EMC Technologies Pty Ltd is providing a half day information seminars
on the guidelines and responsibilities involved in the manufacture, importing, supplying or selling of electrical products.
Mr David Brumfield from the Australian Communications Authority (ACA)
will be guest speaker to ensure that the most up to date information is provided.
This half day seminar will inform you of all your options for C-tick compliance.
A DETAILED SCHEDULE
FROM A PREVIOUS SEMINAR
IS AVAILABLE FOR YOUR INSPECTION.... |
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