Hello all,

Eric's comments below triggered an one thing I forgot to mention in my
earlier mail.

A slight correction to comments/clarification offered by Eric Lifsey:
The Australian EMC Framework (legislation/regulation) does not cover a
product which is has not been sold in Australia.  If an Australia
individual/organisation purchases a product from an overseas supplier FOR
THEIR OWN USE (ie the product is not imported into Australia for sale or as
the result of a order placed with an Australian individual or entity),
there is no requirement to comply with the EMC Framework.

This is to say, the equipment should still comply with the technical
requirements of the applicable EMC standard but there is no need to sign a
DoC or prepare a Compliance Folder for that product as the regulations
hinge on importation for sale.  This is a tricky area and I would advise
caution before rushing off along this path before checking it out
thoroughly first.

Eric is correct in that with out a supply chain, the ACA investigating the
equipment would only be triggered by a complaint regarding the product or
by someone asking why the product does not carry theC-tick etc.  At which
time the user would be expected to pay testing costs to verify the
compliance with the appropriate standard etc. if required by the ACA or not
use/trash the product.

Best regards,
Kevin

> Richard et al,
> 
> I believe what Richard really needs to know is the cost of arranging to
be
> represented by someone in Australia.  The regulatory aspect is certainly
a
> bargain (by not being charged for registering with the ACA) but
contracted
> representation is usually a recurring cost.  Perhaps an Australian
> distributor or some other party can perform the task at a reasonable
cost,
> if they are willing to assume the legal liability.  I checked your
> corporate web page and it doesn't mention any representatives or
> distributors outside the US and EU.
> 
> In our case, we had already established a sales office in Australia.  So
we
> had the sales manager apply for the C-Tick Supplier Code and obtain the
> nicely printed literature supplied by the (at the time) SMA.  We also
> reduced the DoC overhead by creating one massive DoC, listing all
products,
> the ANZ standards, defaulting to Class A for all, which then states that
> the EU DoC is an "informative annex" to the declaration.  Our EU DoCs are
> supplied with each product, while the Framework DoC is only kept at the
> Australia office.  Our compliance "folders" (test data) are available at
> the office via a database served from here in Texas; something we had
> already implemented to support CE marking.
> 
> A comment regarding the issue of accreditation, I'll just quote the
> material at hand (Taken from page 19, Section 6.1 General, of the
> Electromagnetic Compatibility Framework, Information for Suppliers.):
> 
>    "In compiling test data as part of the compliance folder it is
>    recommended that suppliers use results from a NATA accredited
>    laboratory, or MOU partner laboratory.  Test data from other sources
>    carry a higher risk in relation to claims for product conformity."
> 
> So accreditation is "recommended" but certainly not mandatory.  We don't
> have it and we've been audited once already without a problem.
> 
> Another more interesting point to consider.  If I recall correctly, when
a
> product is not handled/retailed in Australia, but only made available
from
> outside Australia directly by mail/catalog/web to the end user, then the
> regulations shift the compliance burden to the user.  I believe the
> implication is that this is not an Australia Customs enforced scheme, but
> one monitored at the point of sale and supply chain.  Having no local
> supplier, nor supply chain, then ACA interest would be triggered by a
> compliant lodged against the product.  I would expect that a series of
> complaints would certainly lead to the ACA having Customs stop shipments
-
> if possible.  Comments?
> 
> Regards,
> Eric Lifsey
> Compliance Engineer/Manager
> National Instruments
> 
> 
> 
> 
> 
> Please respond to rehel...@mmm.com
> 
> To:   "Barry Esmore" <bar...@melbpc.org.au>
> cc:   richard_c...@irisinc.scitex.com, emc-p...@majordomo.ieee.org (bcc:
>       Eric Lifsey/AUS/NIC)
> Subject:  Re: Cost associated with Australian C-tick
> 
> 
> 
> 
> 
> 
> What Barry said is true except the test facility that did the testing
must
> have an accreditation recognized by Australia.........in the U.S., this
is
> either A2LA or NVLAP.
> 
> "Barry Esmore" <bar...@melbpc.org.au> on 04/08/99 12:53:19 AM
> Please respond to "Barry Esmore" <bar...@melbpc.org.au>
> 
> To:   "Richard Cass" <richard_c...@irisinc.scitex.com>
>       "EMC-PSTC (E-mail)" <emc-p...@majordomo.ieee.org>
> cc:    (bcc: Robert E. Heller/US-Corporate/3M/US)
> Subject:  Re: Cost associated with Australian C-tick
> Hello Richard,
> Answers to your questions:
> -   The "APPROXIMATE" cost to register with the ACA (no longer SMA) is
> $zero.
> -   If you have reports to EN55022 it is only a paper work exercise.
> -   You will need an Australian company to sign the DOC and hold the
> compliance folder.
> Hope this helps.
> 
> Regards
> Barry Esmore
> AUS-TICK (Australian Approval Consultants)
> Phone:    + 61 3 9886 1345
> Fax: + 61 3 9884 7272
> Email:    bar...@melbpc.org.au
> ----------
> > From: Richard Cass <richard_c...@irisinc.scitex.com>
> > To: EMC-PSTC (E-mail) <emc-p...@majordomo.ieee.org>
> > Subject: Cost associated with Australian C-tick
> > Date: Thursday, 8 April 1999 6:48
> >
> > Can anyone tell me the APPROXIMATE cost (just need the right number of
> > zeros) if any, in US Dollars, for obtaining the C-Tick mark under the
> > auspices of their EMC Framework?  This would include one time or
> recurring
> > costs.  This would be for ITE equipment.
> > The relevant Australian emissions standard is apparently AS/NZS 3548.
At
> the
> > present time all of our products are verified for European Union
> conformity
> > to the fully equivalent EN55022:1994+A1:1995+A2:1997.  So, in theory,
it
> > should just be a paper work exercise.  I am just trying to find out
what
> the
> > costs are associated with that exercise.  Also, can we as a US based
> > manufacturer submit our application directly to SMA or do we need an
> > intermediary or an in country representative?
> > If anyone in the Australian SMA is on this distribution, I'd be
ecstatic
> to
> > hear from you
> > TIA.
> > Regards,
> > Richard Cass
> > Iris Graphics, Inc.
> > Bedford MA 01730
> > USA
> > 781 2760-5424
> 
> 
> 
> 
> 
> 
> 
> 
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Best regards,
Kevin Richardson

Stanimore Pty Limited
(Technology Requirements Specialists)
Ph:      02-4329-4070    Email: k...@compuserve.com (Internet)
Fax:     02-4328-5639           k...@technologist.com (Alternate Internet)
Int'l +61-2-432x-xxxx           100356,374 (Compuserve)


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