Before shipping an RCM-marked product to Australia or New Zealand, check the Responsible Supplier, exact model, required registration, rating label, market-specific marking, packaging and instructions. In Australia, EESS Level 1 equipment registration is voluntary, while Level 2 and Level 3 registration is mandatory. Under ACMA rules, the compliance label must normally be at least 3 mm high. In New Zealand, some radio products use RCM while A1, A2 and A3 radio transmitters use R-NZ. These details need to match the actual product being shipped, not only the sample or paperwork.

Check the Responsible Supplier Before You Approve the Label

For electrical equipment covered by the Electrical Equipment Safety System (EESS), the Responsible Supplier is not automatically the overseas factory.

The Responsible Supplier must be a qualifying Australian or New Zealand legal entity. EESS requires the entity to hold an Australian Business Number (ABN) or New Zealand Inland Revenue Department (IRD) number and complete the required supplier registration.^[1]

This should be confirmed before the factory prints the final rating labels and retail packaging.

For example, a factory may manufacture a charger for several Australian importers. One importer already having a registered RCM product does not automatically cover another buyer's order. EESS states that different companies importing overseas-manufactured equipment may each need to register as a Responsible Supplier and, where required, separately register the equipment.^[2]

Before production, buyers should have these details available:

• Responsible Supplier legal name;
• applicable supplier registration information;
• brand and exact model;
• product type and technical version;
• destination market;
• equipment registration where required;
• applicable test report, certificate or other compliance evidence;
• final approved rating-label artwork.

Do not treat these as the same thing:

Item	What It Confirms
Responsible Supplier registration	Who takes responsibility under the applicable supplier scheme
Equipment registration	Whether a defined product is registered where registration is required or voluntarily completed
Test report or certificate	Technical evidence for the product and stated scope
RCM	The compliance mark used under the applicable regulatory arrangement

A supplier appearing in a database does not automatically mean every model sold by that supplier is registered or covered by the same technical evidence.

If supplier identity also needs to be checked before an order is approved, a Factory Evaluation can review the declared site, available supplier information and visible operating evidence. This is separate from RCM registration and product-specific compliance records.

Use the EESS Risk Level to Know What Must Be Registered

Australia uses the RCM under both ACMA and EESS, but these are separate regulatory systems.

ACMA covers areas including electromagnetic compatibility, radio and telecommunications. EESS covers the safety of in-scope electrical equipment. One product may fall under ACMA, EESS, or both.

ACMA allows suppliers whose products are subject only to ACMA requirements to register using the “ACMA only” option. That registration does not replace EESS requirements when the product is also in-scope electrical equipment.^[3]

For EESS, buyers need to know the product's risk level:

EESS Level	Equipment Registration	Main Evidence	RCM
Level 1	Voluntary	Evidence of compliance is mandatory	Mandatory
Level 2	Mandatory	Evidence of compliance + Compliance Folder	Mandatory
Level 3	Mandatory	Evidence of compliance + valid Certificate of Conformity	Mandatory

The distinction is important when searching the EESS database. Level 1 equipment does not have to be individually registered, so the absence of a Level 1 model from the equipment register does not by itself show a problem. Level 2 and Level 3 equipment must be registered.^[2]

For Level 2 and Level 3 products, buyers should compare the equipment record with the actual order. Useful comparison points include:

• Responsible Supplier;
• brand or trade name;
• exact model;
• product description;
• electrical ratings where applicable;
• certificate information where required;
• the model printed on the production goods.

A factory description such as “20 W charger” is not enough. The order should use an exact model and approved technical specification so that the paperwork and physical goods can be matched.

Match the New Zealand Supplier Record to the Exact Product

New Zealand Radio Spectrum Management (RSM) also requires suppliers of covered products to register. Suppliers receive a supplier number through the Electrical Regulatory Authorities Council (ERAC) system. Suppliers of radio transmitters also need the applicable licence to supply radio transmitting equipment.^[4]

Supplier registration alone is not enough to identify the product.

RSM requires a product description that allows the supplied product to be linked to the compliance records. Depending on the product, this can include the brand, model, function, modules and accessories.^[5]

If the approved records show AB100 but the factory produces AB100A, our team records the model difference. We do not assume the extra letter either makes the product acceptable or makes it non-compliant. The Responsible Supplier needs to confirm whether the variant is covered.

RSM also requires test reports or other allowed conformity evidence according to the product's conformity level. Its current guidance states that relevant test reports must be kept for 5 years after the supplier stops supplying the product.^[6]

Product changes also need to be checked against the existing records:

Change	What Needs Review
Colour or packaging artwork	Product identity and artwork version
Model suffix	Whether the variant is covered
PCB	Existing technical evidence
Power supply or electrical rating	Test evidence, label and instructions
Wireless module or antenna	Radio and EMC evidence
Plug or cable	Destination-market specification

A technical change should trigger a review. It does not automatically mean the complete product must be retested; that depends on the change and the applicable requirements.

This is the practical difference between Product Testing and Product Inspection. Testing evaluates a defined sample against technical requirements. Product Inspection checks whether mass production still matches the approved product, components, labels and packaging.

Check the Full Rating Label, Not Just the RCM

For ACMA-regulated products, the current compliance-label rules require the label to be legible, visible to the unaided eye and at least 3 mm high. It should normally be durable and placed on an easily accessible product surface. Printing, moulding, etching and engraving are among the permitted application methods.^[7]

The 3 mm rule is an ACMA requirement. It should not be presented as one universal size rule for every RCM application. EESS separately refers to AS/NZS 4417.1 and AS/NZS 4417.2 for its RCM location and dimensional requirements.^[8]

During Product Inspection, our team checks the full rating label against the buyer-approved artwork.

Check	What Should Match
Brand	Approved product and packaging
Model	Specification, compliance reference and production product
RCM	Approved mark, position and appearance
Voltage and frequency	Approved electrical specification
Current, power or output	Approved product version
Plug, cable or adapter	Destination-market requirement
Retail packaging	Product model and market version
Instructions	Product and market version

If production shows the wrong model or electrical rating, the report should describe that exact difference. A useful finding is:

“The production rating label does not match the buyer-approved artwork.”

That is more accurate than stating that the product fails a certificate when the certificate scope has not been technically reviewed.

Match the Same Model Across the Product, Box, Manual and Records

Use one product identity from the compliance file through to the finished carton:

Responsible Supplier → compliance record → approved specification → rating label → product → retail box → instruction manual.

For example, if the unit says AB100 but the box says AB100A, there is already a clear identification mismatch even if the RCM itself looks correct.

Before inspection, buyers should provide the latest approved versions of:

• product specification;
• model and SKU list;
• rating-label artwork;
• packaging artwork;
• instruction manual;
• plug, cable or adapter specification where relevant.

Artwork version numbers are useful here. If the approved label is V3 but production uses V2, our team can record a clear version mismatch instead of trying to decide which factory file is current.

The same rule applies when an important component changes. A replacement PCB, wireless module, antenna, power supply or electrical rating should be reviewed against the existing compliance evidence before the old product file is reused.

Check Electronic and QR-Code Labels as Working Features

ACMA permits electronic labelling when a product has a built-in display. Product instructions must tell the consumer how to view the electronic label, for example during start-up or through a system-information or help menu.^[7]

If electronic labelling is part of the buyer-approved requirement, our team can check whether:

• the electronic mark can be opened;
• the expected RCM is displayed;
• the access steps match the approved instructions;
• the label remains available during normal product operation.

RSM also permits electronic labelling under its conditions for products with a built-in display. Its guidance states that accompanying documentation must explain how the mark is applied and that the mark should be difficult to delete, modify or prevent from displaying.^[9]

If barcode or QR-code verification is included in the inspection scope, 100% of the checked codes must scan successfully. Our team checks whether the print is clear, whether the code can be scanned, and whether the scanned information or destination matches the approved requirement. Any unreadable or incorrect code should be recorded, corrected and rechecked.

Use IPI, DPI or FRI Based on When the Label Risk Can Be Caught

Inspection Stage	Production Status	Useful RCM Check
IPI	About 5%–10% produced	Confirm the early product version, component setup and first label artwork
DPI	About 30%–50% produced	Check whether the same label and product version are being used during mass production
FRI	100% produced and at least 80% packed	Check the finished product, label, box, accessories and instructions together

A Initial Production Inspection is useful when the product or rating label is new. Finding the wrong artwork when only 5%–10% has been produced is easier to deal with than finding the same error across the finished order.

A During Production Inspection checks the order while approximately 30%–50% has been produced. It can be used to confirm whether earlier corrections have actually entered mass production.

For the final market version, Final Random Inspection is normally the most useful stage because production is complete and at least 80% is packed. The product, retail box and instructions can be checked together.

Where random sampling is used, sample size should come from the agreed inspection plan rather than a fixed percentage. ISO 2859-1:2026 provides the current AQL-indexed sampling system for inspection by attributes.^[10]

A sampled FRI does not mean every unit has been checked. If a buyer requires one specific marking or label point to be checked on every unit, that requirement should be defined separately in the inspection scope.

Apply Australia's 3 mm, QR-Code and Package-Label Rules Correctly

Under ACMA rules, the normal compliance label must be at least 3 mm high. ACMA also permits a QR code or similar mechanism as the compliance label when it links to a webpage that prominently displays the RCM.^[7]

This QR-code option is an ACMA rule. It should not be applied automatically to every EESS product.

If an ACMA product cannot practically carry a surface label and does not use electronic labelling, ACMA requires the label on both:

• the product packaging; and
• the consumer product documents, such as instructions or warranties.

The label on the packaging must be clearly visible and cover an area greater than 1% of that packaging surface. The supplier must also keep records explaining why the product was not surface-labelled and where the label was placed instead.^[7]

EESS uses a different process for exceptional marking. Its guidance says the RCM should generally be on the external surface near the model identification. Where normal marking is not possible, the Responsible Supplier may need to request an alternative arrangement from the regulator.^[8]

During inspection, our team therefore follows the buyer-approved labelling method rather than assuming that any RCM printed on a carton is automatically acceptable.

Check Whether New Zealand Needs RCM or R-NZ

New Zealand RSM uses different marks according to the product's conformity category.

RSM Category	Marking
Level 1 EMC	RCM may be used; if used, the required compliance documentation applies
Level 1 radio	RCM required
Level 2	RCM required
Level 3	RCM required
A1 radio transmitter	R-NZ required
A2 radio transmitter	R-NZ required
A3 radio transmitter	R-NZ required

RSM states that Levels 1, 2 and 3 mainly cover EMC products plus a smaller group of radio products harmonised with Australia. A1, A2 and A3 apply to most other radio products supplied in New Zealand.^[6]

This is important for Wi-Fi, Bluetooth and other wireless products. An Australian product using the RCM should not automatically have the same label copied to the New Zealand version.

Under current RSM rules, an RCM or R-NZ mark must be legible, durable and at least 3 mm high. Where direct product marking is not practical, the rules allow specified alternative locations such as outer packaging, instructions or product guarantee or certificates.^[9]

Electrical safety is a separate issue. WorkSafe states that certain declared electrical articles have additional certification requirements. For certified declared products covered by those requirements, a unique certification marking is required for that certification purpose; the RCM does not replace it.^[11]

WorkSafe also requires electrical and electronic equipment covered by that guidance to be marked for operation at New Zealand supply voltage: 230 V, 400 V, or a voltage range that includes the applicable voltage.^[11]

Review These 10 Points Before Shipment

No.	Check	What the Buyer Should Confirm
1	Destination	Australia, New Zealand or both
2	Responsible Supplier	Correct legal entity and supplier record
3	Regulatory route	ACMA, EESS, RSM, NZ electrical safety, or more than one
4	Equipment registration	Required registration exists where applicable
5	Exact model	Production model matches the approved records
6	Technical version	No unexplained PCB, power-supply, radio-module or rating change
7	Rating label	Latest approved artwork is used
8	Market mark	Correct RCM, R-NZ or approved alternative method
9	Packaging and manual	Same model and market version as the product
10	Inspection evidence	Differences are clearly recorded with photos

Our team can check these physical points against the agreed inspection scope. Product Inspection does not issue the RCM, register the Responsible Supplier or replace electrical safety, EMC or radio laboratory testing. Where technical evidence is required, it should be reviewed separately from the factory inspection findings.

Finally

Before shipment, keep the RCM review tied to measurable checks. Under EESS, Level 1 equipment registration is voluntary while Level 2 and Level 3 registration is mandatory. ACMA requires its compliance label to be at least 3 mm high, and its package-labelling route requires the label to cover more than 1% of the relevant packaging surface. New Zealand RSM uses R-NZ for A1, A2 and A3 radio transmitters. For inspection timing, IPI is normally arranged at 5%–10% production, DPI at 30%–50%, and FRI when production is 100% complete and at least 80% packed. Any barcode or QR-code check included in the scope requires 100% scan success on checked samples.