RCM, ACMA labelling and the EESS: bringing radio and electrical equipment to market in Australia

Who this is for: anyone who puts radio or electrical equipment on the Australian market without buying it through Australian distribution — an importer bringing in a container of routers, a manufacturer selling direct from overseas, a systems integrator private-labelling a gateway, an installer who found a cheaper access point on an overseas marketplace. It explains what the RCM actually certifies, which rules sit behind it, who is legally the supplier, and what has to exist before the first unit is sold.

1. One mark, two regulators

The small tick-in-a-triangle on the label of almost every electronic product sold in Australia is the Regulatory Compliance Mark, the RCM. It is one mark, but it is not one rule. It tells the buyer that the supplier has declared the product compliant with every arrangement that applies to it, and there are two families of arrangement behind it.

The first belongs to the Australian Communications and Media Authority. The ACMA regulates anything that connects to a telecommunications network, anything that transmits or receives radio, anything electrical that can interfere with radio (electromagnetic compatibility, EMC), and the electromagnetic energy people are exposed to from transmitters (EME). Those are four separate instruments with one shared process: check which rules apply, show the product complies, sign a declaration and keep the evidence, register as a responsible supplier on the national database, then label.

The second belongs to the state and territory electrical safety regulators. Their concern is electric shock and fire, not interference, and their vehicle is the Electrical Equipment Safety System, the EESS, which classifies mains-powered household-type equipment into three risk levels with escalating requirements, and runs the same national database the ACMA uses for registration.

A 4G router with a plug pack in the box touches both. The router is radio, telecommunications and EMC — the ACMA's side. The plug pack is a power supply — the EESS's side, and at its highest risk level. The RCM on each is the same symbol; what stands behind it is not.

2. Are you the supplier?

Everything in this guide attaches to the supplier, and the ACMA's definition is wider than most people expect. A manufacturer makes a product for sale in Australia. An importer brings a product into Australia for sale — the ACMA's own examples include Amazon and Etsy sellers. An agent is someone in Australia acting on behalf of a manufacturer or importer. If you are the first Australian party in the chain, the obligations are yours, whether you sell one unit or a thousand.

Two consequences follow. A reseller buying from an Australian distributor is not the supplier — the distributor took on the obligations when it imported, which is why a router bought from a distributor's channel already carries the RCM and a registered supplier stands behind it. And an overseas manufacturer cannot be the supplier at all: the responsible supplier has to be an Australian (or, under the EESS, an Australian or New Zealand) legal entity with an ABN and an Australian address. A manufacturer without one needs someone here to take the role. Under the ACMA arrangements that can be an agent registered as an authorised representative; under the EESS there are no agents — the registered responsible supplier is the importer or local manufacturer, full stop. That distinction shapes the service arrangements at the end of this guide.

3. The ACMA side: four arrangements, one process

Two things the table does not say. First, one product usually sits under several arrangements at once — a cellular router with Wi-Fi is telecommunications, radiocommunications, EMC and, if its antennas are integral, EME. Second, a passive antenna is none of these: it has no transmitter, no receiver and no electronics, so the ACMA's labelling arrangements attach to the radio it is connected to, not to the antenna. What matters for the antenna is that the combination stays within the transmitter's authorised limits, which is a licensing question rather than a labelling one.

The ACMA is also not standing still. The telecommunications notice was remade in 2025, and in July 2026 the ACMA opened a further consultation on customer equipment regulation, proposing among other things a longer record-keeping period. Nothing in this guide changes the five steps, but the instrument names and periods behind them should be re-checked against the ACMA's Know what you must do as a supplier pages before you build a compliance folder.

The five steps

Step 1 — check the rules. Identify every arrangement that applies and the applicable standards under each. For a radio product this means the standard for its band and technology (a 4G module, a 2.4/5 GHz Wi-Fi radio and a 915 MHz LoRa radio each have their own), plus EMC, plus telecommunications if it connects to a network, plus EME if the antenna is integral.

Step 2 — show the product complies. The ACMA arrangements grade products into three compliance levels by the risk of harm or interference, and the level sets the evidence. At the lowest level a description of the product and the supplier's own declaration are enough; at the middle level you need a test report showing compliance with the applicable standard; at the highest level the test report has to come from an accredited testing body. Overseas test reports to the harmonised international standards are routinely acceptable — the question is whether the standard the report cites is one the Australian arrangement recognises, and whether the report is complete for the configuration you are actually selling (the antenna gain a module was tested with is a common gap).

Step 3 — sign and keep records. You must not supply without a signed Declaration of Conformity. The ACMA publishes the form (C02) and you may use your own format provided it carries the same content, but whoever signs it has to have seen the evidence and agree that the records show compliance — it is a personal attestation, not a formality. The records — the DoC, the test reports, the description, any agency agreement — must be kept for the period the arrangement specifies after you stop supplying the product, and produced on request. Electronic records are fine.

Step 4 — register as a responsible supplier. Registration is on the national database, the EESS platform, before the label goes on. For a supplier whose products fall only under the ACMA arrangements, registration is free; you give an Australian address and a contact, and the registration is public. An agent registering on behalf of an overseas manufacturer registers as an authorised representative and must be nominated by that manufacturer.

Step 5 — label. Only once steps 1 to 4 are complete. The RCM goes on the surface of the product; where that is impractical it may go on the packaging or the documents, and a product with a built-in display may show it electronically. It must be at least 3 mm high, can be printed, moulded, etched or engraved, and a QR-code form of the label is also permitted. The older A-Tick and C-Tick have not been allowed on newly supplied equipment since 2016 and are no longer protected marks; if you inherit stock that carries them, get advice before selling it.

What non-compliance costs

The arrangements carry penalty provisions expressed in Commonwealth penalty units: up to 500 units for supplying a non-compliant or unlabelled radiocommunications or EMC product, up to 100 for a telecommunications product (120 for connecting an unlabelled one to a network without permission), and 30 for failing to keep records. The ACMA's usual first response is an agreement to comply or a formal warning, but the exposure is real, and the record-keeping penalty is the one that catches otherwise compliant suppliers who bought a compliant product and kept nothing.

4. The EESS side: mains power, three levels, one responsible supplier

What is in scope

The EESS applies to in-scope electrical equipment: low-voltage equipment rated above 50 V AC or 120 V ripple-free DC and below 1,000 V AC or 1,500 V DC, that is designed or marketed as suitable for household, personal or similar use. Whether it is also marketed for commercial or industrial use is irrelevant — a plug pack sold to businesses is still in scope if it is the kind of thing a household would use. Equipment that only ever runs on extra-low voltage is not in scope in itself: a 48 V PoE camera, a 12 V router, a 24 V gateway are outside the EESS. The mains adaptor that powers them is inside it.

The three levels are set by a published classification of equipment types, aligned to AS/NZS 4417.2, and the requirements step up with the level:

The entry that matters most to anyone in networking or radio is power supply or charger — a device giving an output not exceeding 50 V AC or 120 V ripple-free DC for household-type equipment — which is Level 3. The plug pack for a router, the adaptor for an access point, the charger for a handheld radio: each needs a Certificate of Conformity to the relevant standard (the AS/NZS 61558 series for general supplies, AS/NZS 62368.1 for supplies for IT, audio and video equipment, AS/NZS 60335.2.29 for battery chargers, per the EESS's own bulletin on the subject), registration against your supplier record, and the RCM. Power-line communication adaptors that plug into a socket are Level 3 as well. The router itself, running from that adaptor, is not in scope; the adaptor carries the compliance for both.

The responsible supplier

Under the EESS the responsible supplier is the person or entity that manufactures in-scope equipment in, or imports it into, Australia or New Zealand, and it must be a legally identifiable Australian or New Zealand entity holding an ABN or an IRD number. Registration is on the EESS database and renewed annually; it carries a fee, and Level 2 and 3 equipment registrations carry their own fees and terms — the current schedule is on eess.gov.au and changes, so it is not reproduced here. At registration the supplier makes the Responsible Supplier's Declaration that everything it supplies is electrically safe and meets the relevant standards, and it receives a copy of AS/NZS 4417.1 with the correct dimensions for the RCM. The compliance folder — the evidence behind the declaration — must be kept for five years after the equipment's registration ends.

Agents are not permitted under the EESS. That single sentence is the reason an overseas manufacturer of, say, a range of plug packs or PoE injectors cannot simply appoint a representative the way it can for the ACMA arrangements: someone in Australia has to import the equipment as the responsible supplier and stand behind the declaration.

Which states

The EESS was built to be national, and its database and the RCM already are. The intergovernmental agreement on its governance has been signed by Queensland, Victoria, Western Australia and Tasmania; the Electrical Regulatory Authorities Council reports South Australia, the Northern Territory and the ACT transitioning to it, and New South Wales retaining its own declared and non-declared article classifications with complementary requirements. In practice the compliance work is the same wherever you sell — the standards, the certificates for high-risk items and the RCM are recognised across jurisdictions — but the legal footing differs, and a product sold nationally should be prepared as if every jurisdiction were an EESS jurisdiction.

5. Product by product

6. A worked example: two hundred routers for a fleet

An integrator wins a contract to fit 200 vehicles with a cellular router, and the manufacturer's Australian distributor cannot supply the exact variant. The integrator decides to import direct. Here is the sequence, in the order it has to happen.

First, the integrator confirms it is the supplier — it is the importer — and that it holds an ABN and an Australian address. Second, it identifies the arrangements: radiocommunications (a 4G module and Wi-Fi), telecommunications (customer equipment connecting to a carrier network), EMC, and EME if the antennas are integral (they are external SMA connections here, so EME falls away, but the licensing side still requires the antenna gain to stay within the module's authorised limits). Third, it obtains the manufacturer's test reports and checks each against the standard the Australian arrangement calls up, in the configuration being sold; where a report is missing or was done to a superseded standard, it commissions a test — from an accredited body if the compliance level requires it. Fourth, it signs a Declaration of Conformity per arrangement and opens a compliance folder. Fifth, it registers on the national database as the responsible supplier. Sixth, it labels — in this case on the product and in the packaging, since the routers ship in bulk trays.

Then the plug packs. They arrive in the same carton, and they are Level 3 under the EESS. The integrator checks whether the manufacturer's adaptor already holds an Australian Certificate of Conformity under a registered responsible supplier — many do, because the same adaptor is sold with other products — and if so, it can buy those through that channel or arrange for the certificate holder to supply them. If not, the adaptor needs its own certificate from a recognised certifier, its own registration for one, two or five years, and the RCM, and the integrator's EESS registration moves from free (ACMA only) to fee-bearing. The alternative that avoids all of it is to power the routers from the vehicle's DC supply, which is what most fleet installs do anyway.

Realistic timing for a product with complete test reports and an adaptor that already holds a certificate is two to four weeks from first assessment to ship-ready. Missing test reports add the laboratory's lead time; a Level 3 certificate for a new adaptor adds the certifier's.

7. What goes wrong

The failures we see are rarely a product that could not comply. They are a supplier who did not know they were one — the marketplace seller, the integrator who "just bought a few" — and a compliance folder that does not exist. Test reports for a different variant or a different antenna. A DoC signed by someone who never saw the evidence. An adaptor assumed to be covered because the router was. A-Tick stock from a decade ago. Registration skipped because the label was already on the product when it landed. Records discarded when the product was discontinued, three years before the retention period ran out. None of these is difficult to avoid; all of them are difficult to fix after an ACMA request for records arrives.

Frequently asked questions

The product already has the RCM on it from the manufacturer. Am I done?

No. The mark shows that a registered supplier declared it compliant. If that supplier is not the Australian entity importing your units, the mark is not yours to rely on — you need your own registration, declaration and records, or you need to buy through the party whose registration it is.

Do I need Australian test reports?

Not as such. Reports to the harmonised international standards from a competent laboratory are the normal evidence, and for the highest compliance level the laboratory has to be accredited. What matters is that the report covers the standard the Australian arrangement calls up and the configuration you are selling.

Is a passive antenna a "device" that needs the RCM?

A passive antenna has no transmitter, receiver or electronics, so the ACMA labelling arrangements do not attach to it. Its effect on compliance is through the radio it is connected to — the transmitter's authorised power and gain limits, which is a licensing matter.

My equipment runs on 48 V PoE. Does the EESS apply?

Not to the equipment — extra-low voltage is outside the EESS's scope. The mains-powered switch, injector or adaptor that supplies it is where the EESS applies, and a plug-pack adaptor is Level 3.

We are the manufacturer, based overseas, selling online into Australia. Who is the supplier?

You cannot be. For the ACMA arrangements you can appoint an Australian agent as your authorised representative; for the EESS there are no agents and an Australian or New Zealand entity has to import as the responsible supplier. Most manufacturers solve both with one Australian party that takes the role for the range.

How long do I keep the records?

For the ACMA arrangements, for the period the relevant instrument specifies after you stop supplying the product — and the ACMA is consulting on lengthening it for telecommunications equipment. Under the EESS, the compliance folder is kept for five years after the equipment's registration ends. Keep everything, electronically, for the longer of the two.

What does registration cost?

Registration on the national database for ACMA-only purposes is free. EESS registration as a responsible supplier is annual and fee-bearing, and Level 2 and 3 equipment registrations carry their own fees; the schedule is published on eess.gov.au.

Where to from here

If you would rather not be the supplier at all, the routers, access points, antennas and cables at the Techwave Store arrive through Australian distribution with the RCM in place and a registered supplier behind them — and our guides to designing an IoT network around a 4G/5G router and ACMA licensing for VHF and UHF radio cover what comes after compliance.

Sources, checked 5 September 2026: ACMA — Know what you must do as a supplier, Step 1: check the rules to follow, Step 2: show your product complies, Step 3: sign and keep records, Step 4: register as a responsible supplier, Step 5: label your product, The General Equipment Rules, Proposal to remake the TLN and 8 telecommunications standards, Proposal to update telco customer equipment regulation (July 2026); Federal Register of Legislation — Radiocommunications Equipment (General) Rules 2021 (compilation), Telecommunications (Labelling Notice for Customer Equipment and Customer Cabling) Instrument 2015 (series, no longer in force); EESS — About the EESS, Steps for compliance with EESS, Registration – in-scope electrical equipment, Level 3 equipment, Registration – responsible supplier, ACMA requirements – use of RCM, FAQ, Participating jurisdictions, In-scope electrical equipment and risk levels v4.3 (July 2024), Information bulletin: power supply and battery charger standards; ERAC — Equipment safety in Australia and New Zealand. This guide is general information, not legal advice; instruments, levels and fees change and should be confirmed against the current versions before you rely on them.