Did the RCM replace the C-Tick and A-Tick?

Yes. The Regulatory Compliance Mark replaced the C-Tick (EMC and radio) and A-Tick (telecommunications) from 1 March 2013, with a transition that ended on 1 March 2016. It is now the single mark for the ACMA regimes and for electrical safety under the Electrical Equipment Safety System (EESS).

Who can register and label a product for Australia?

The Australian manufacturer or the importer. Under the Radiocommunications Equipment (General) Rules 2021 the label must be applied by the person who manufactured the device in Australia or who imported it (an agent or an authorised person overseas may physically apply it on their behalf), and that person must first be registered on the national database with an ABN and an Australian address. On the electrical safety side, the EESS states that overseas companies and Australian "agents" cannot be the Responsible Supplier: only the Australian or New Zealand manufacturer or importer can.

Is there still a Supplier Code Number?

Not in the current instruments. Registration is on the national database, the EESS Registration Database run for the electrical safety regulators, which the ACMA designated for its regimes and which was replaced by the EESS Platform on 14 October 2024. The platform gives each Responsible Supplier an identifier of the form E1234. The old Supplier Code Number belongs to the C-Tick era.

Does a battery-powered product need an EMC test report?

Usually not. Under the Radiocommunications Labelling (Electromagnetic Compatibility) Notice 2017, a medium risk device (compliance level 2) is one containing a switch mode power supply, a microprocessor, a transistor switching circuit or similar, but a battery-powered device is not medium risk unless the ACMA declares it to be. Battery-powered devices are therefore low risk (level 1) by default: they must still comply with the applicable standard and the supplier keeps a description (and a declaration of conformity if it applies the RCM), but no test report is required.

Can an FCC grant replace a test report for Australian radio compliance?

For some devices. For a general compliance level 2 device under the 2021 Equipment Rules, the importer may rely on any of three documents: a written FCC authority for the device to operate in the United States (with a statement of any changes made where US rules conflict with the Australian standard), a test report, or the manufacturer's performance specifications. Short range devices covered by the Short Range Equipment Standard are level 1 and need only a description.

Can the RCM be shown on a screen or by QR code?

Yes. A device with a built-in display may show the RCM electronically if the display can always show it, the documentation explains how, and it is difficult to prevent it being displayed. Since an amendment to the 2021 Rules, the label may also be a QR code linking to a website that displays the RCM prominently. Otherwise the RCM must be at least 3 mm high, durable and permanently applied to the device.

How long must compliance records be kept?

Five years, in English, on paper or electronically. The EMC notice counts the 5 years from the last date a device of that kind is first supplied in Australia, so in practice from the end of supply of the model. The 2021 Rules (radio and EME) count from first supply of the device and apply each obligation across the whole period a kind of equipment is supplied. The records are the declaration of conformity, the description, the test report or other document, and where relevant a variant statement and the agency agreement if an agent keeps them.

Does an Australian approval cover New Zealand?

In large part. The Trans-Tasman Mutual Recognition Arrangement, in force since 1998, lets goods that may lawfully be sold in one country be sold in the other, with exclusions. New Zealand runs its own radio compliance notices through Radio Spectrum Management, and the Australian 2021 Rules exempt from the labelling prohibitions devices imported from New Zealand that comply with the New Zealand labelling notices (section 54B, not for EME applicable devices). The EESS accepts New Zealand entities with an IRD number as Responsible Suppliers.

ACMA and RCM: Australia and New Zealand compliance

Hugues Orgitello updated 7 Oct 2026 10 min read

The Regulatory Compliance Mark looks like one approval, but behind it sit five separate obligations: radio, EMC, human exposure to radio frequency energy (EME), telecommunications, and electrical safety. The first three are set by ACMA instruments, telecommunications by the Telecommunications Act, and electrical safety by state regulators through the EESS. Most English-language guides still describe the RCM with vocabulary from before 2021: a "Supplier Code Number", agents holding registrations for foreign manufacturers, test reports for everything. The current instruments are more precise, and sometimes more lenient. A battery-powered product is low risk for EMC unless the ACMA says otherwise. An FCC grant can stand in for a radio test report. The RCM can be a QR code. And on the safety side, the EESS refuses agents outright. This guide rebuilds the RCM from the instruments themselves.

TL;DR: Only an Australian manufacturer or importer (or a New Zealand one, for EESS) can register on the national database and label with the RCM. EMC has three risk levels: battery-powered and simple devices are level 1, devices with a microprocessor or switch mode supply are level 2 (test report or technical construction file), Group 2 ISM equipment is level 3 (accredited report). Radio short range devices are level 1; other radio devices may rely on an FCC grant. Records are kept in English for 5 years after the model is last supplied. For mains equipment, the EESS sets its own risk levels 1 to 3, with Level 3 needing a certificate of conformity and product registration.

The instruments behind the mark

Regime	Instrument	Regulator
Radio (general standards, e.g. short range devices)	Radiocommunications Act 1992; Radiocommunications Equipment (General) Rules 2021, Schedule 5; class licences such as the Low Interference Potential Devices Class Licence 2025	ACMA
EMC	Radiocommunications (Electromagnetic Compatibility) Standard 2017; Radiocommunications Labelling (Electromagnetic Compatibility) Notice 2017	ACMA
EME (human exposure)	Equipment Rules 2021, Schedule 4, referencing the ARPANSA radiofrequency standard (2021)	ACMA
Telecommunications (equipment connected to telecom networks)	Telecommunications Act 1997 and its labelling instrument, with AS/CA standards	ACMA
Electrical safety	State and territory electrical safety laws applying the EESS; AS/NZS 4417 for the RCM	State regulators through ERAC
Labelling and registration	Equipment Rules 2021, Schedule 2 (RCM) and Schedule 3 (labelling), Part 9 (national database)	ACMA

The Equipment Rules 2021 consolidated the older labelling notices for radio and EME; the EMC labelling notice of 2017 still applies to EMC. The latest compilation of the Rules is dated 16 January 2026.

Who can label: manufacturer or importer, not an agent

The 2021 Rules put the labelling duty on the person who manufactured the device in Australia or who imported it. An agent, or a person overseas authorised by the importer, may physically apply the label, but the legal duty stays with the importer (Schedule 3, clauses 3 and 4). Before labelling, that person must:

be registered on the national database, with an ABN, a name (ACN or registered business name), an Australian address and a contact person, and update any change within 30 days (section 58);
hold a declaration of conformity in the ACMA form. For an imported device, either the importer makes it, or the foreign manufacturer makes it and the importer obtains a copy (Schedule 3, clause 9);
hold the documents required by the device's compliance level (clause 10).

On the electrical safety side the EESS is blunter: only the Australian or New Zealand manufacturer or importer, "the first person or business in Australia or New Zealand who receives the equipment for on-sale", can be the Responsible Supplier. Overseas companies and Australian agents cannot. A Responsible Supplier needs an ABN or a New Zealand IRD number, renews its registration every year, and receives an identifier of the form E1234.

The national database is the EESS Registration Database, designated by the ACMA for its own regimes since the 2008 EMC notice, and replaced by the EESS Platform on 14 October 2024. One registration therefore serves the ACMA and the EESS. The "Supplier Code Number" found in older guides does not appear in the current instruments.

EMC: three levels, set by what is inside

Level	Device	What the supplier must hold
1, low risk	Neither medium nor high risk, which includes battery-powered devices unless the ACMA declares otherwise	Description of the device; labelling is optional, and a declaration of conformity is needed if the RCM is applied; records still required
2, medium risk	Contains a switch mode power supply, a transistor switching circuit, a microprocessor, a commutator, a slip-ring motor, or an electronic device operating in switching or non-linear mode	Test report from a testing body, or a technical construction file
3, high risk	Group 2 ISM equipment as defined in AS/NZS CISPR 11	Accredited test report from an accredited testing body (NATA or an MRA partner), or a technical construction file

Two consequences follow. First, a battery-powered gadget with a microprocessor is still level 1 for EMC under section 1.8(2), because the battery exemption overrides the component list. Second, almost every mains-powered electronic product is level 2, and a report from any competent testing body suffices: accreditation is required only at level 3. The applicable EMC standards are listed in the EMC Standard 2017, mostly AS/NZS CISPR editions of the international CISPR standards (AS/NZS CISPR 32, AS/NZS CISPR 14, AS/NZS CISPR 15, AS/NZS CISPR 11).

Radio and EME: two more level systems

Level	Definition (Equipment Rules 2021, Schedule 3)	Documents
General compliance level 1	Devices for which the Short Range Equipment Standard or the Intelligent Transport Systems Standard is prescribed	Description of the device
General compliance level 2	Any other device with a general standard	Description, plus one of: written FCC authority to operate in the US (with a statement of changes where US law conflicts with the Australian standard), a test report, or the manufacturer's performance specifications
EME compliance level 1	Devices for which the ARPANSA RPS S-1 advisory note says no exposure evaluation is required	Description
EME compliance level 2	Other EME devices normally used more than 20 cm from the body	Description and test report
EME compliance level 3	EME devices used within 20 cm of the body	Description and a test report from an accredited testing body

A Wi-Fi and Bluetooth module is usually general level 1 (short range) and, in a handheld product, EME level 3. A cellular phone is at least EME level 3, and as customer equipment also falls under the telecommunications regime. The FCC route is the one detail European teams rarely know: for a general level 2 device, an FCC authorisation is an accepted compliance document under clause 10(2)(a).

The Low Interference Potential Devices Class Licence 2025 replaced the 2015 class licence on 1 October 2025. It authorises the use of short range devices and added arrangements including RLAN transmitters in 6425 to 6585 MHz and digital modulation transmitters in 5150 to 5250 MHz. Australian LoRaWAN deployments use the AU915 channel plan in 915 to 928 MHz, not the European 868 MHz band.

The label

Rule	Requirement	Equipment Rules 2021
Form	The RCM, or a QR code (or similar) linking to a website that displays the RCM prominently	Schedule 3, clause 5(1)
Placement	On the device surface, readily accessible to the user	Clause 5(2)
Durability	Durable, and permanent or hard to remove	Clause 5(3), 5(4)
Size	At least 3 mm high	Clause 5(5)
Packaging	Only if labelling the device is impossible or impractical; then on the packaging, occupying more than 1% of its external surface and clearly visible, and on the accompanying documentation, with a written record of why	Clause 5(6), 5(7), 14(3)
Screen	Allowed for devices with a built-in display that can always show the RCM, with instructions in the documentation	Clause 6
Wireless microphones	Devices able to operate in 694 to 820 MHz carry an extra statement that they must not be used in that band	Clause 5(1A)

The RCM does not carry a supplier or certificate number, and the EESS confirms that certificate numbers no longer need to be marked on equipment.

Records

Under Schedule 3, clause 14, the labeller keeps the declaration of conformity, the description, the test report or other document, any packaging-label justification, any variant statement, and the agency agreement if an agent keeps the records. Records are kept in English, may be copies or electronic, and must be kept until 5 years after the device is first supplied. The EMC notice (section 5.2) states the same rule for a model supplied repeatedly: 5 years after the last date a device of that kind is first supplied in Australia, which in practice means 5 years after the model stops being supplied. A variant needs a written statement identifying the original device, describing the differences and giving a technical rationale for compliance.

Electrical safety: the EESS levels

The EESS applies to in-scope electrical equipment: rated above 50 V AC or 120 V DC and below 1000 V AC or 1500 V DC, and intended for household, personal or similar use, whatever the marketing says.

EESS level	Registration	Evidence
Level 0 (not in scope, e.g. 5, 12 or 25 V equipment)	Not part of EESS registration	Outside the EESS levels
Level 1	Voluntary	Compliance folder with evidence of conformity to the full AS or AS/NZS standard
Level 2	Mandatory, by the Responsible Supplier	Compliance folder with a valid test report to the full standard
Level 3	Mandatory, with registration fee	Certificate of conformity from a recognised certifier, listed on the EESS Platform; registration for 1, 2 or 5 years

Which equipment is level 2 or 3 is defined in the EESS in-scope equipment definitions, not by the supplier. A Responsible Supplier may apply the RCM to level 2 or 3 equipment only after the equipment is registered. A low voltage power supply feeding your product is often the in-scope part: the 5 V device is level 0, its mains adapter is not.

New Zealand

The Trans-Tasman Mutual Recognition Arrangement, in force since 1998, allows goods that can lawfully be sold in one country to be sold in the other, with exclusions. In practice:

Radio: New Zealand applies its own notices through Radio Spectrum Management. The Australian Rules exempt from the Australian labelling prohibitions devices imported from New Zealand that comply with the New Zealand Radio Standards Notice and Compliance Notice, except EME applicable devices (section 54B).
Electrical safety: the EESS is shared, and a New Zealand manufacturer or importer with an IRD number can be the Responsible Supplier.
Standards: most EMC and safety standards are joint AS/NZS publications.

Claims the instruments contradict

Common claim	What the instrument says
"A foreign manufacturer gets a Supplier Code Number through an Australian agent"	Registration is on the national database by the Australian manufacturer or importer; the EESS rejects overseas companies and agents as Responsible Suppliers
"Every product needs a test report"	EMC level 1 (including battery-powered devices) and radio general level 1 need none
"Battery devices with a microprocessor are EMC level 2"	Section 1.8(2): battery-powered devices are not medium risk unless declared by the ACMA
"Level 3 means radio transmitters on sensitive bands"	EMC level 3 is Group 2 ISM equipment; EME level 3 is devices used within 20 cm of the body
"The RCM must be physically printed on the product"	A built-in display or a QR code linking to the RCM is permitted
"The RCM covers radio, EMC and safety"	It also signals EME and telecommunications compliance where those apply

RCM, CE and FCC compared

Criterion	RCM (AU)	CE (EU)	FCC (US)
Who is responsible	Australian manufacturer or importer	Manufacturer, or importer for non-EU manufacturers	Grantee, or responsible party for SDoC
Registration before sale	Yes, national database	No general registration	FCC ID for certified devices
Third party	Accredited report for EMC level 3 and EME level 3; EESS certificate for level 3 safety	Notified body for some products	TCB certification for most radio
Electronic label	Screen or QR code	Limited	E-label allowed for devices with a screen
Record retention	5 years after the model is last supplied	10 years after placing on the market	Defined per rule part

Step-by-step

Identify the regimes: radio, EMC, EME, telecommunications, electrical safety (in-scope mains equipment).
Decide who imports: the Australian importer (or your Australian subsidiary) is the one who registers and labels.
Register on the national database (EESS Platform) and keep the details current.
Set each compliance level: EMC 1 to 3, radio general 1 or 2, EME 1 to 3, EESS 0 to 3.
Collect the documents: description, test reports or FCC grant as allowed, technical construction file where chosen, EESS certificate for level 3.
Sign the declaration of conformity in the ACMA form, by the importer or the foreign manufacturer with a copy to the importer.
Register EESS level 2 and 3 equipment before applying the RCM.
Label: RCM at least 3 mm high, or screen or QR code.
Keep records in English for 5 years after the model is last supplied.

See Certification timeline for fitting this into a product schedule.

Frequently asked questions

Did the RCM replace the C-Tick and A-Tick?: Yes. The Regulatory Compliance Mark replaced the C-Tick (EMC and radio) and A-Tick (telecommunications) from 1 March 2013, with a transition that ended on 1 March 2016. It is now the single mark for the ACMA regimes and for electrical safety under the Electrical Equipment Safety System (EESS).
Who can register and label a product for Australia?: The Australian manufacturer or the importer. Under the Radiocommunications Equipment (General) Rules 2021 the label must be applied by the person who manufactured the device in Australia or who imported it (an agent or an authorised person overseas may physically apply it on their behalf), and that person must first be registered on the national database with an ABN and an Australian address. On the electrical safety side, the EESS states that overseas companies and Australian "agents" cannot be the Responsible Supplier: only the Australian or New Zealand manufacturer or importer can.
Is there still a Supplier Code Number?: Not in the current instruments. Registration is on the national database, the EESS Registration Database run for the electrical safety regulators, which the ACMA designated for its regimes and which was replaced by the EESS Platform on 14 October 2024. The platform gives each Responsible Supplier an identifier of the form E1234. The old Supplier Code Number belongs to the C-Tick era.
Does a battery-powered product need an EMC test report?: Usually not. Under the Radiocommunications Labelling (Electromagnetic Compatibility) Notice 2017, a medium risk device (compliance level 2) is one containing a switch mode power supply, a microprocessor, a transistor switching circuit or similar, but a battery-powered device is not medium risk unless the ACMA declares it to be. Battery-powered devices are therefore low risk (level 1) by default: they must still comply with the applicable standard and the supplier keeps a description (and a declaration of conformity if it applies the RCM), but no test report is required.
Can an FCC grant replace a test report for Australian radio compliance?: For some devices. For a general compliance level 2 device under the 2021 Equipment Rules, the importer may rely on any of three documents: a written FCC authority for the device to operate in the United States (with a statement of any changes made where US rules conflict with the Australian standard), a test report, or the manufacturer's performance specifications. Short range devices covered by the Short Range Equipment Standard are level 1 and need only a description.
Can the RCM be shown on a screen or by QR code?: Yes. A device with a built-in display may show the RCM electronically if the display can always show it, the documentation explains how, and it is difficult to prevent it being displayed. Since an amendment to the 2021 Rules, the label may also be a QR code linking to a website that displays the RCM prominently. Otherwise the RCM must be at least 3 mm high, durable and permanently applied to the device.
How long must compliance records be kept?: Five years, in English, on paper or electronically. The EMC notice counts the 5 years from the last date a device of that kind is first supplied in Australia, so in practice from the end of supply of the model. The 2021 Rules (radio and EME) count from first supply of the device and apply each obligation across the whole period a kind of equipment is supplied. The records are the declaration of conformity, the description, the test report or other document, and where relevant a variant statement and the agency agreement if an agent keeps them.
Does an Australian approval cover New Zealand?: In large part. The Trans-Tasman Mutual Recognition Arrangement, in force since 1998, lets goods that may lawfully be sold in one country be sold in the other, with exclusions. New Zealand runs its own radio compliance notices through Radio Spectrum Management, and the Australian 2021 Rules exempt from the labelling prohibitions devices imported from New Zealand that comply with the New Zealand labelling notices (section 54B, not for EME applicable devices). The EESS accepts New Zealand entities with an IRD number as Responsible Suppliers.