Did the RCM replace the older Australian marks (C-Tick, A-Tick)?

Yes. The Regulatory Compliance Mark replaced the older C-Tick (electromagnetic compatibility) and A-Tick (radiocommunications) symbols from 1 March 2013, with a transitional period that closed on 1 March 2016. Since that date, only the RCM is accepted to signal conformity for products falling under the three regimes administered by the ACMA and under the Electrical Equipment Safety System (EESS). Stock units still carrying the older mark may stay on the market until depletion, but no new production can use them.

Is a test report required for a Level 1 product?

Not necessarily. Under the Labelling Notice, a Level 1 product (low interference risk) requires a minimal file: product identification, registered Australian supplier identification, technical description, and signed declaration of conformity. Test evidence is not mandatory in the file kept by the supplier, but the applicable AS/NZS standards must have been considered during design. For Levels 2 and 3, a test report from a competent laboratory becomes mandatory.

What is the Supplier Code Number (SCN) and who needs one?

The Supplier Code Number is a unique identifier registered on the national database (suppliers.acma.gov.au for radio and EMC regimes, separate EESS database for electrical safety). It must be obtained by the supplier established in Australia who places the product on the market, that is the local manufacturer, the importer, or an Australian authorised representative. A foreign manufacturer cannot obtain an SCN directly and must work through an Australian-established entity. The SCN sits in the compliance file but does not need to appear on the product itself.

Is the RCM accepted in New Zealand?

Yes, through the Trans-Tasman Mutual Recognition Arrangement (TTMRA) signed in 1998. A product legally placed on the Australian market under the RCM can, in the vast majority of cases, be placed on the New Zealand market without additional registration. New Zealand oversight is exercised by Radio Spectrum Management (RSM) for the radio side and by WorkSafe NZ / Energy Safety for electrical safety. Some exceptions remain, notably equipment governed by purely national New Zealand standards.

How does the RCM differ from the CE mark?

Three main differences. First, the RCM is a single visual mark covering radio, EMC, and electrical safety simultaneously, where the CE procedure stacks distinct directives (LVD, EMC, RED) under a single mark. Second, the Australian system requires mandatory supplier registration in a public database (SCN), which has no European equivalent. Third, electrical safety in Australia falls under the EESS managed at state level (Queensland, Victoria, New South Wales), not at federal level, which has no counterpart in the European architecture.

Do tests need to be redone when moving from CE to RCM?

Partly. The AS/NZS CISPR standards mirror the international CISPR family, and EMC tests run under EN 55032 / EN 55035 are generally accepted under AS/NZS CISPR 32 and AS/NZS CISPR 35. For radio, the requirements in AS/NZS 4268 and the ACMA Class Licences can diverge from the European RED on specific bands (notably ISM bands and authorised power levels). For electrical safety, AS/NZS 62368.1 is harmonised with IEC 62368-1, which makes the transposition direct. A gap audit identifies the tests to complete before building the RCM file.

What are the penalties for affixing the RCM without registration?

The ACMA can issue formal warnings, administrative fines (infringement notices), and pursue criminal proceedings under the Radiocommunications Act 1992 and Telecommunications Act 1997. Sanctions vary with severity and recurrence. On the EESS side, the States can order market withdrawal, fine the registered supplier, and prohibit future commercialisation. Observed practice favours rapid remediation over immediate sanction, provided the supplier cooperates.

Does the RCM need to be placed in a specific location on the product?

The RCM must be visible, legible, and indelible, applied to the product itself wherever technically possible. When product size does not allow it, the mark can appear on the packaging or in accompanying documentation. The logo proportion must be preserved (height-to-width ratio defined in the Labelling Notice), with a typical minimum height of 3 mm. Colour is not prescribed as long as contrast with the background remains sufficient. Digital labelling (e-label) is admitted for products lacking adequate physical surface, under conditions.

ACMA and RCM: product compliance for Australia and New Zealand

Author Hugues Orgitello Last updated 26 May 2026

Guide · ACMA / RCM

The Regulatory Compliance Mark (RCM) is, unlike the European CE marking which covers one or several discrete directives under a common symbol, a single visual mark that attests simultaneously to compliance with three Australian regulatory regimes: radio (Radiocommunications Act 1992), electromagnetic compatibility (Radiocommunications (Electromagnetic Compatibility) Standard 2017), and electrical safety (Electrical Equipment Safety System). Affixed in Australia under the supervision of the Australian Communications and Media Authority (ACMA), it benefits from direct recognition in New Zealand through the Trans-Tasman Mutual Recognition Arrangement (TTMRA), turning the Australia + New Zealand pair into a single compliance market for most electronic products. This guide describes its scope, the compliance levels, the Supplier Code Number mechanism, and the common pitfalls a European manufacturer encounters when transposing a CE file to the RCM.

Institutional architecture: ACMA, EESS, RSM

The Australian system rests on a split of competence between a federal agency and the State authorities. That split has no direct equivalent in the European Union and explains a share of the friction during transposition.

The ACMA, federal authority for radio and EMC

The Australian Communications and Media Authority is the federal agency formed in 2005 from the merger of the Australian Communications Authority and the Australian Broadcasting Authority. It administers the Radiocommunications Act 1992 and the Telecommunications Act 1997, the two acts that cover radio spectrum, emission licensing, and electromagnetic compatibility. The ACMA publishes:

the Class Licences that define the conditions of use for licence-exempt bands (ISM, LPWAN, Wi-Fi, BLE),
the technical standards applicable to radio equipment (often by reference to AS/NZS 4268 and equivalent ETSI standards),
the Radiocommunications (Electromagnetic Compatibility) Standard 2017, the EMC reference text for non-radio products,
the Radiocommunications Labelling (Electromagnetic Compatibility) Notice 2017, which defines the RCM, the compliance levels, and the labelling obligations.

The ACMA is the entry point for everything radio and EMC. It maintains the public supplier database (suppliers.acma.gov.au) and exercises market surveillance powers, including sampling and independent lab testing.

The EESS, electrical safety at State level

Electrical safety falls under a distinct system: the Electrical Equipment Safety System (EESS), jointly administered by the State regulators (Queensland, Victoria, New South Wales, Tasmania, South Australia, and the Australian Capital Territory, with Western Australia and the Northern Territory operating closely related but slightly separate regimes). The EESS has operated since 2013 under the umbrella of the Electrical Regulatory Authorities Council (ERAC).

The EESS principle:

Electrical equipment is classified into two categories: Declared (equipment posing significant risk, listed in AS/NZS 4417.2) and Non-Declared (other equipment within the equivalent low-voltage scope).
For Declared electrical equipment, the Australian supplier must be registered in the national EESS database and the product itself must be registered, with the test report and certificate of conformity to the applicable safety standard on file (AS/NZS 62368.1, AS/NZS 60335, AS/NZS 61010, etc.).
For Non-Declared equipment, the declaration of conformity still applies but per-product registration is not systematic.

The RCM on a Declared product signals that the supplier is properly registered in the EESS database and that the product is recorded there. Missing EESS registration is one of the most frequent blocking issues for foreign manufacturers who focus only on the ACMA side.

Radio Spectrum Management (RSM) in New Zealand

On the New Zealand side, the authority equivalent to the ACMA is Radio Spectrum Management (RSM), part of the Ministry of Business, Innovation and Employment (MBIE). RSM administers the Radiocommunications Act 1989 (NZ) and publishes the General User Radio Licences (GURL), the functional equivalents of the Australian Class Licences. Electrical safety is the remit of Energy Safety (under WorkSafe NZ) and relies on the same AS/NZS standards as Australia.

The TTMRA ensures that a product legally commercialised in Australia can be commercialised in New Zealand without further national registration in the majority of cases. That mutual recognition is the practical backbone of treating AU + NZ as a single market.

The three regimes covered by the RCM

The RCM, unlike a CE mark that may apply to a single isolated directive, is intrinsically multi-regime. Once affixed, it attests to compliance with the three pillars below.

Radio regime: Radiocommunications Act 1992

Any product that intentionally emits radio waves (Wi-Fi, BLE, cellular, LPWAN, active RFID) must, under the Radiocommunications Act 1992, either hold an individual licence or fall under a Class Licence published by the ACMA. The most common Class Licences for consumer and industrial electronics:

Low Interference Potential Devices (LIPD) Class Licence, for common ISM equipment (Wi-Fi, BLE, LoRa, Sigfox),
Cellular Mobile Telecommunications Devices Class Licence for cellular modules,
Citizen Band Radio Stations Class Licence for CB communications.

The applicable technical standard is primarily AS/NZS 4268 Radio equipment and systems, Short range devices, Limits and methods of measurement, which largely transposes ETSI requirements from EN 300 328 (2.4 GHz band), EN 300 220 (sub-GHz bands), and EN 301 893 (5 GHz). Cellular radio uses band-specific standards, generally referencing 3GPP.

EMC regime: EMC Standard 2017

The electromagnetic compatibility of non-radio products is governed by the Radiocommunications (Electromagnetic Compatibility) Standard 2017, which designates the applicable AS/NZS CISPR standards by product category:

AS/NZS CISPR 32 for multimedia equipment (emission),
AS/NZS CISPR 35 for multimedia equipment (immunity),
AS/NZS CISPR 11 for industrial, scientific, and medical equipment,
AS/NZS CISPR 14 for household appliances and electrical tools,
AS/NZS CISPR 15 for lighting equipment.

These standards reflect the international CISPR versions with minor national additions or amendments. A test report compliant with EN 55032 / EN 55035 (the European harmonised versions of CISPR 32 / CISPR 35) is accepted under AS/NZS CISPR 32 / AS/NZS CISPR 35 in the vast majority of cases, subject to checking the applicable edition.

Electrical safety regime: EESS and AS/NZS

The electrical safety of a mains-powered product (or a product whose source can generate electrical risk) falls under the EESS and the corresponding AS/NZS standards. For consumer and professional electronics, the pivot standard is AS/NZS 62368.1 Audio/video, information and communication technology equipment, Safety requirements, harmonised with IEC 62368-1. Depending on product category, other standards apply:

AS/NZS 60335 for household appliances,
AS/NZS 61010 for measurement, laboratory, and process automation equipment,
AS/NZS 60598 for luminaires.

A product with a complete IEC 62368-1 file (CB Scheme through IECEE) can generally obtain AS/NZS 62368.1 transposition with minimal effort, provided the National Differences listed in the standard annex are covered.

Compliance Levels 1, 2, 3

The Radiocommunications Labelling (Electromagnetic Compatibility) Notice 2017 defines three compliance levels based on interference risk and product criticality. Each level imposes a different compliance file.

Level	Risk	Required documentation
Level 1	Low	Technical product description, supplier identification, model identification, internal declaration of conformity, log of standards considered. No test report mandatory in the kept file, but the applicable AS/NZS standard must have been considered.
Level 2	Medium	All Level 1 content, plus a test report from an accredited or competent laboratory demonstrating conformity to applicable AS/NZS standards. The declaration of conformity must reference the report.
Level 3	High	All Level 2 content, plus an extended technical file (compliance folder) including risk analysis, change history, internal audit reports. For some products, ACMA notification is required before market placement.

Level classification depends on product type and the applicable standard. For instance, a common multimedia product typically falls under Level 2 (CISPR 32 report required). A radio transmitter on a sensitive band (cellular, emergency frequency) falls under Level 3. Per-category details are annexed to the Labelling Notice.

File retention

The registered Australian supplier must retain the file (Declaration of Conformity, test reports, technical description, foreign manufacturer identification) for a typical period of five years after the last market placement, and make it available to the ACMA on request within a reasonable timeframe (typically ten business days).

The Supplier Code Number (SCN)

The cornerstone of the Australian system, the Supplier Code Number is a unique identifier for the supplier established in Australia. It is mandatory for any product falling under the three regimes covered by the RCM.

Who may hold an SCN

The SCN is granted to a legal entity established in Australia:

The Australian manufacturer, where one exists,
The Australian importer, when the manufacturer is foreign,
An Australian authorised representative designated by the foreign manufacturer through a written mandate.

A manufacturer established in France, Germany, or the United States cannot obtain an SCN directly: it must rely on an importer or appoint a local representative. That representative carries the registered supplier's responsibilities: file retention, cooperation with authorities, market withdrawal where required.

Two databases: ACMA on one side, EESS on the other

Two databases coexist and must be considered separately:

suppliers.acma.gov.au: the public ACMA database for radio and EMC regimes. Registration is free and done online. Once validated, the SCN is issued and remains valid as long as the entity exists and supplies products on the Australian market.
National EESS database: managed by the ERAC for electrical safety. Supplier registration is a separate step, followed by per-product registration for Declared equipment. Annual fees apply (amounts vary by State and are not detailed here).

A supplier of a product spanning all three regimes (for example a mains-powered IoT device with a Wi-Fi module) must therefore register in both systems, and the RCM affixed presupposes both registrations are valid.

Consequence for a European manufacturer

A French manufacturer typically chooses between appointing a local distributor that holds the SCNs on its behalf (simplest path when the commercial relationship is stable), or appointing a specialised representative (compliance representative) when distribution flows through multiple channels. The choice is not neutral: in case of product fault, the entity holding the SCN is the ACMA's or EESS's interlocutor and bears the direct financial consequences.

The RCM mark itself

The graphical form of the RCM is set by the Labelling Notice. It consists of a stylised triangle with a tick, accompanied by the text "RCM" and using a specific height-to-width ratio. Affixation rules:

Visibility and legibility: the mark must be readable to the naked eye without optical aid.
Indelibility: it must withstand normal cleaning and the intended use of the product.
Position: on the product itself wherever possible. If product size does not allow it (miniature components, modules for integration), it may appear on the packaging or accompanying documents.
Minimum height: typically 3 mm, adjustable proportionally to product size.
No adjoined identifier: unlike most international marks, the RCM does not carry the laboratory number or the supplier's SCN. The SCN belongs in the internal file, not on the mark.

Digital labelling (e-label) is admitted for products whose surface does not allow satisfactory physical marking, provided the user can access the mark easily and persistently (through the user interface, a configuration menu, etc.).

Compliance folder contents

The compliance folder is the Australian equivalent of the European technical file. It does not need to be lodged with the ACMA (except at Level 3 with notification) but must be available on request. For a Level 2 product, the typical contents:

Product identification: trade name, model reference, serial numbers or range, photos.
Technical description: functional block diagram, operating principles, intended use conditions.
Supplier identification: legal name, address, ACMA SCN, and where applicable EESS SCN and EESS product registration.
List of applied AS/NZS standards: with their editions (for example AS/NZS CISPR 32:2015, AS/NZS 4268:2017).
Test reports: full reports issued by a competent laboratory (ideally NATA-accredited or ILAC-MRA recognised).
Declaration of Conformity: signed by the registered supplier, dated, referencing the standards and reports.
Internal procedures: production control, traceability, product change management.

For a Level 3 product, add: formal risk analysis, internal audit history, and the archived ACMA notification where applicable.

TTMRA, the New Zealand extension

The Trans-Tasman Mutual Recognition Arrangement, signed in 1998 between the Australian and New Zealand governments, is a mutual recognition convention built on a simple principle: a product legally placed on one country's market may be placed on the other's market without further registration, subject to explicitly listed exceptions.

Practical effect on the RCM regimes

For the three regimes covered by the RCM:

Radio: a product compliant with the ACMA Class Licences can be used in New Zealand under the equivalent General User Radio Licences published by RSM. ISM, LPWAN, and Wi-Fi bands are subject to harmonised general licences in both countries. A few specific bands (cellular allocation, public safety frequencies) may diverge and warrant case-by-case verification.
EMC: the AS/NZS CISPR standards are jointly published by Standards Australia and Standards New Zealand. An EMC report produced for Australia is valid for New Zealand without transposition.
Electrical safety: AS/NZS 62368.1, AS/NZS 60335, AS/NZS 61010 are likewise joint. New Zealand oversight is exercised by Energy Safety (WorkSafe NZ), which recognises the Australian EESS status for Declared equipment, subject to complementary registration in specific cases.

TTMRA exceptions

A few exceptions persist: some equipment connected directly to the incumbent operator's network (Chorus in NZ, Telstra in AU) may require local approval, equipment governed by purely national standards remains subject to the destination country's procedure, and language requirements (notice in New Zealand English, sometimes Maori for certain sectors) remain each jurisdiction's prerogative. For most industrial and consumer electronics, the RCM + TTMRA pair covers the AU + NZ market.

RCM, CE, FCC: structural comparison

To position the RCM in the international regulatory map, the comparison with the two main Western regimes (European CE, American FCC) is useful.

Criterion	RCM (AU + NZ)	CE (EU / EEA)	FCC (US)
Scope covered by the mark	Radio + EMC + electrical safety simultaneously	One or several directives, depending on the product	Radio + EMC (Part 15); safety via UL/CSA separately
Authority	ACMA (federal, radio + EMC) + ERAC/EESS (States, safety)	European Commission + national market surveillance authorities	FCC (federal)
Prior supplier registration	Yes (mandatory SCN)	No	No (except FCC ID for intentional radiators)
Notified body / third party	Not generally required (supplier-assisted self-declaration)	Yes for some regimes (machinery, PPE cat. III, medical devices)	TCB for intentional radiators (Part 22, 24, 27, and some Part 15)
Regional recognition	TTMRA with New Zealand	Single market across 27 States + EEA	No equivalent mutual recognition
Visual mark	Stylised triangle with tick	"CE" logo	No unified mark; "FCC" text + ID
Reference standards	AS/NZS CISPR, AS/NZS 4268, AS/NZS 62368.1	EN harmonised (CISPR, ETSI, IEC)	ANSI C63.4, 47 CFR Part 15
Market surveillance	ACMA, State authorities, RSM / Energy Safety in NZ	National authorities (DGCCRF in France, BNetzA in Germany, etc.)	FCC enforcement bureau
Technical file	Compliance folder, typical five-year retention	CE technical file, typical ten-year retention	Records, typical two-year retention after end of manufacture

See CE vs FCC: EMC for the detail of EMC differences between the two main Western regimes, and EU + US dual certification for the combined test plan strategy.

Standard process for an RCM market placement

For a European manufacturer starting from an existing CE file and targeting Australia + New Zealand, the rational sequence:

Identify the applicable regimes for the product: radio only? EMC only? Electrical safety (mains-powered or battery-operated above the extra-low voltage threshold)?
Appoint an Australian supplier (distributor, importer, or compliance representative) who will hold the SCNs.
Audit the existing CE file against the applicable AS/NZS standards: identify tests already covered (typically EMC and IEC 62368-1 safety) and those needing transposition or completion (AS/NZS 4268 radio, AS/NZS National Differences).
Complete missing tests at a NATA-accredited or ILAC-MRA recognised laboratory.
Register the Australian supplier on suppliers.acma.gov.au (radio and EMC regimes) and where applicable on the EESS database (electrical safety).
Register Declared products in the EESS database when the category requires it.
Draft the Declaration of Conformity signed by the registered supplier, citing AS/NZS standards and test reports.
Build the full compliance folder and retain it at the registered supplier for a typical period of five years.
Affix the RCM on the product (or packaging if product surface does not allow it), respecting the graphical rules of the Labelling Notice.
Check TTMRA coverage for New Zealand: in most cases, no further step is needed; document any exceptions where they exist.
Maintain compliance over the lifecycle: monitor Class Licence and AS/NZS standard updates, refresh the file on product change.

See Certification timeline for fitting this sequence into a global product schedule.

Common pitfalls

A few recurring errors show up in files from European manufacturers discovering the Australian system.

Conflating RCM and CE. The two marks cover partly overlapping but distinct perimeters. A complete CE file is never sufficient without a transposition audit to AS/NZS standards and SCN registration.
Skipping Australian supplier registration. Affixing the RCM without a valid SCN is liable to ACMA formal warnings and, in some cases, prosecution. It is one of the most frequent non-conformities flagged by market surveillance.
Missing EESS registration. For a Declared mains-powered product, ACMA registration alone is not enough: the EESS is a separate State-administered system with its own database and its own fees. A product carrying the RCM without valid EESS registration for a Declared item breaches each State's legislation.
Citing EN instead of AS/NZS in the Declaration of Conformity. The RCM DoC must cite the applicable AS/NZS standards, not the European EN standards, even where the technical content is identical. A DoC citing only EN 55032 without mention of AS/NZS CISPR 32 is formally non-compliant.
Wrong mark position. Affixing the RCM on packaging when there was space on the product itself is a recurring market surveillance finding. The hierarchy stands: product first, packaging second, documents as last resort.
Assuming automatic TTMRA coverage. For the vast majority of products, yes. But some cellular radio bands, some network-connected equipment, and some national sectors (smart meters, railway equipment) require case-by-case verification with RSM or the relevant New Zealand sectoral authority.
Ignoring radio band divergence. AS/NZS 4268 and the ACMA Class Licences can diverge from the European RED on authorised power levels, DFS usage in 5 GHz, and some sub-GHz bands. A LoRa device configured for EU868 cannot be commercialised as-is in Australia, which uses AU915.

Key takeaways

The RCM is a single mark attesting to compliance with three Australian regimes: radio (Radiocommunications Act 1992), EMC (EMC Standard 2017), and electrical safety (EESS at State level).
The ACMA is the federal authority for radio and EMC. Electrical safety is administered by the State regulators under the ERAC umbrella through the EESS system.
The Supplier Code Number is mandatory and is only granted to an entity established in Australia (local manufacturer, importer, or authorised representative).
Levels 1, 2, 3 under the Labelling Notice define the compliance file contents, from minimal record to extended compliance folder with ACMA notification.
The AS/NZS CISPR, AS/NZS 4268, AS/NZS 62368.1 families are the usual references, largely harmonised with CISPR, ETSI, and IEC.
The TTMRA extends recognition to New Zealand for the vast majority of products, turning the AU + NZ pair into a single compliance market.
The RCM is not equivalent to CE: perimeter, supplier registration, and institutional architecture all differ. Transposition requires a gap audit, not a label swap.

To place the RCM within the broader regulatory map, see CE marking, CE scope, CE technical file, FCC, RED, EU + US dual certification, Certification timeline, and the Glossary for definitions.

Sources & references

Regulatory Compliance Mark (RCM) , Australian Communications and Media Authority (ACMA) www.acma.gov.au/regulatory-compliance-mark-rcm
Equipment rules and compliance , ACMA www.acma.gov.au/equipment-rules-and-compliance
Electrical Equipment Safety System (EESS) , Electrical Regulatory Authorities Council (ERAC) www.eess.gov.au/
Radio Spectrum Management New Zealand , Ministry of Business, Innovation and Employment (NZ) www.rsm.govt.nz/
Radiocommunications Act 1992 (Cth) , Federal Register of Legislation (Australia) www.legislation.gov.au/Series/C2004A04372
Trans-Tasman Mutual Recognition Arrangement (TTMRA) , Australian Government, Department of Industry www.industry.gov.au/regulations-and-standards/trans-tasman-mutual-recognition-arrangement