RCM and SDoC Solutions

The Electrical Equipment Safety System (EESS) is Australia’s national scheme for ensuring that electrical products meet safety standards. It applies to in-scope electrical appliances and equipment sold in Australia.

The Regulatory Compliance Mark (RCM) is the symbol displayed on electrical products to indicate compliance with Australian electrical safety and electromagnetic compatibility (EMC) requirements under both EESS and ACMA.

Because the EESS system operates outside New Zealand law, businesses supplying declared articles in New Zealand must have a person accountable under New Zealand law. Therefore, any business applying for EESS registration in New Zealand is required to have at least one director permanently and physically residing in New Zealand.

Important: While the RCM is recognized in Australia, it is not accepted in New Zealand as proof of electrical safety compliance. Products sold in New Zealand must meet local safety requirements, which may involve different testing or certification processes.

The Electrical Equipment Safety Scheme (EESS) uses a risk-based classification system to determine the safety requirements for in-scope electrical equipment. The higher the level, the stricter the safety and certification requirements:

• Risk Level 1 – electrical equipment that is classified low risk or unknown risk and is any in-scope electrical equipment not classified as Risk Level 3 or Risk Level 2.
• Risk Level 2 – electrical equipment that is classified as medium risk and is defined in the AS/NZS 4417.2. A list of the current Level 2 equipment.
• Risk Level 3 – electrical equipment that is classified as high risk and is defined in the AS/NZS 4417.2. A list of the current Level 3 equipment.

The higher the level, the stricter the safety and certification requirements.

It depends on whether the product is “Declared” or “Non-declared” based on its safety risk:

• Declared Articles: These are higher-risk products that must have approval before they can be sold. To get approval, the product must be tested by an accredited lab and verified as compliant with specific safety standards by NSW Fair Trading or an approved body.
• Non-declared Articles: These do not require formal approval before sale. However, they are still legally required to be safe and must comply with the minimum safety standard AS/NZS 3820.

Under the Electricity (Safety) Regulations 2010, WorkSafe New Zealand has the legal authority to “declare” specific electrical fittings or appliances as having higher safety risks. The definitions are as follows:

• Declared Medium Risk Articles (Reg 83): These are low voltage or extra-low voltage fittings or appliances that WorkSafe has officially declared as Medium Risk. Suppliers of these products must provide a Supplier Declaration of Conformity (SDoC) to prove safety before sale.
• Declared High Risk Articles (Reg 84): These are products declared by WorkSafe as High Risk. Because of their higher danger potential, they must be formally approved or certified by a recognized body before they can be legally sold or offered for sale in New Zealand.

In short, “Declared” means the regulator has specifically identified that product type as requiring extra safety oversight beyond the standard requirements.

According to WorkSafe New Zealand, “a declared medium-risk article may not be sold, supplied, or offered for sale unless the supplier (being a New Zealand manufacturer or importer) has made a Supplier Declaration of Conformity (SDoC) for the article.”

This means that only a New Zealand-based manufacturer or importer can legally sign the NZ’s safety SDoC.

No, internal factory reports or reports from non-accredited laboratories are not accepted. Regulatory authorities in Australia (e.g., NSW Fair Trading) and New Zealand (WorkSafe NZ) enforce strict accreditation requirements. To obtain a certificate, especially for Level 3 / High Risk products, you must provide a full test report issued by an independent, third-party accredited laboratory.

The test report must be endorsed by one of the following recognized accreditation frameworks:

• ILAC-MRA Signatory Bodies: The report must bear the ILAC-MRA mark on the cover. This includes laboratories accredited by bodies such as CNAS (China), NATA (Australia), or A2LA (USA), provided their scope of accreditation covers the relevant standards.
• IECEE CB Scheme: A valid CB Test Certificate must be provided along with its corresponding CB Test Report (which must include Australian/New Zealand National Deviations).

Legal Note: Under New Zealand’s Electricity (Safety) Regulations 2010 (Regulation 81) and Australian EESS rules, reports without these endorsements do not constitute “conclusive evidence” of compliance. Using non-accredited reports can lead to the rejection of your application, mandatory product recalls, and significant legal penalties.

While Medium Risk (Level 2) products do not strictly require a certificate prior to sale, the law mandates that suppliers maintain a Compliance Folder containing evidence that meets the same rigorous standards.

Under the EESS (Australia) and Electricity Safety Regulations (New Zealand), you must be able to produce a valid test report within 10 working days upon request from regulators. To mitigate legal risks, avoid potential product recalls, and ensure seamless entry into major retail channels, we strongly recommend that Level 2 products also be supported by test reports endorsed by ILAC-MRA (e.g., CNAS) or the IECEE CB Scheme. Relying on non-accredited reports leaves the supplier fully liable for any compliance failures or safety incidents.

A Compliance Folder is a comprehensive technical file proving that your electrical equipment meets AU/NZ safety standards. According to the EESS framework, maintaining a Compliance Folder is Mandatory for Level 2 products, while it is Highly Recommended for Level 1 and Level 3 products. Even where not strictly mandatory, having this folder is essential for fulfilling your legal obligation to supply “electrically safe” equipment.

The folder must include:

• Product Description: Brand/model, circuit diagrams, design drawings, technical specifications, and internal/external color photographs.
• User Documentation: Operating and installation instructions, as well as final artwork for safety labels and ratings.
• Evidence of Compliance: A list of relevant standards, a critical component list, and detailed test reports.
• Evaluator Details: Information regarding the technical competence, qualifications, and accreditation details of the parties that conducted the tests and assessment.

Not necessarily. While most products require AS/NZS standards, reports based on International (IEC), European (EN), or US (UL) standards are accepted if they are recognized as equivalent in the regulations. For instance, UL 2271 and IEC 60320.2.2 are accepted in certain contexts.

Regardless of the standard, the report must be a full technical document from an accredited 3rd party laboratory endorsed by bodies like ILAC-MRA (e.g., CNAS), the IECEE CB Scheme, or NATA/IANZ. Final acceptance is subject to the regulator’s discretion, so you must verify if the specific standard for your product allows these alternatives.

Not necessarily. While both countries share many standards, they operate under different regulatory frameworks and testing requirements. A common misconception is that Australian approval automatically covers the New Zealand market; however, compliance in one country does not guarantee legal sale in the other. Each product must be verified against specific New Zealand requirements to avoid non-compliance.

For example, the regulatory scope varies significantly between the two countries. In New Zealand, WorkSafe can “declare” certain low-voltage or extra-low-voltage (ELV) appliances as high- or medium-risk, requiring strict certification or a Supplier Declaration of Conformity (SDoC). In contrast, these same ELV products are often considered “out of scope” in Australia and face fewer restrictions. Therefore, a product that is unregulated in Australia may still require formal approval in NZ.

No. While high- and medium-risk products are specifically declared under regulations to require an SDoC, some products that are not declared risk articles may still require documentation during installation.

For these products, a licensed electrician must provide and complete the Electrical Certificate of Compliance & Electrical Safety Certificate when installing the product. This ensures that even non-declared products meet safety requirements and are compliant with New Zealand regulations.