What Must an RCM Declaration of Conformity Contain, and Who Signs It?

Detailed Explanation

The Declaration of Conformity (DoC) is the legal document through which the responsible supplier declares that an electronic product meets the applicable Australian and New Zealand regulatory standards. It does not replace the accredited test report — it references the test report and summarises the compliance status in a standardised form. Together with the test reports, design documentation, and risk assessment, the DoC forms part of the Technical Construction File (TCF): the complete compliance record that the responsible supplier must maintain. For the end-to-end RCM certification process — from standards selection through NATA-accredited testing to ACMA registration — see that page; this page focuses specifically on the DoC and TCF documentation requirements.

Required Contents of an RCM Declaration of Conformity

The ACMA's EMC framework prescribes what a DoC must contain. A compliant DoC includes:

1. Product identification The DoC must clearly identify the product: product name, trade name (if different), model number(s) or type designation, and — where the product is produced in batches — any serial number range or production period the DoC applies to. If the DoC covers a range of models, all model designations must be listed.

2. Responsible supplier identity The name and full address of the responsible supplier — the entity signing the DoC and placing the product on the Australian or New Zealand market. This must be an Australian or New Zealand address. Where a product is imported, this is typically the Australian importer's business name and registered address, not the overseas manufacturer's details.

3. Standards declared against An explicit list of every standard the product has been tested against, identified by:

• Standard number (e.g. AS/NZS CISPR 32)
• Standard title
• Edition year (e.g. ":2015")

Listing standards without edition years, or listing incorrect standards for the product category, are common and consequential errors — the DoC is checked against the specific edition in force at the time of supply. For guidance on which standard applies to your product type — CISPR 32 (multimedia/IT), IEC 61000-6-4 (industrial), CISPR 11 (ISM equipment), or AS/NZS 4268 (short-range devices) — see which Australian EMC standard applies to your product.

4. Reference to the test report The DoC must reference the supporting accredited test report: the test laboratory's name, the report number, and the date the report was issued. The report must have been produced by a NATA-accredited laboratory for the applicable test method. The formal test covers the conducted and radiated emissions paths defined by the applicable CISPR or IEC standard.

5. Place and date of issue The place (city and country) and date the DoC was issued. The date must be on or after the date of the test report the DoC references.

6. Signature block The name, title, and handwritten or electronic signature of the person authorised to sign on behalf of the responsible supplier. The signatory must be authorised to make legal declarations on behalf of the entity — typically a director, compliance manager, or technical director.

The Technical Construction File (TCF)

The DoC is not a standalone document — it is the front page of the Technical Construction File. The TCF is the complete compliance record and must be available for inspection by the ACMA on request for at least 10 years from the date the product was last supplied in Australia.

A complete TCF contains:

• Declaration of Conformity — the signed DoC itself
• Design documentation — circuit schematics, PCB layout files, bill of materials, mechanical drawings of the enclosure
• Accredited test report(s) — the full report from the NATA-accredited laboratory, not just the pass/fail summary page; includes test setup photographs, measurement data, and the laboratory's assessment. If pre-compliance testing records exist, include them as supporting evidence of design intent
• Risk assessment — a documented assessment of the electrical safety hazards and how the design mitigates them (particularly relevant for mains-connected equipment)
• Pre-compliance test records (recommended, not mandatory) — records from internal pre-compliance EMC scanning that support the argument that the design was competently developed before formal testing
• Correspondence with the test laboratory — any clarification letters about the test scope, standards applied, or test exclusions

The 10-year retention period runs from the date the product model was last supplied, not from when it was first supplied. If a product remains on the market for 5 years and then is discontinued, the TCF must be kept for 10 further years — 15 years total from initial supply. This must be factored into business record-keeping systems.

Who Is the Responsible Supplier?

The responsible supplier is the entity that supplies the product for sale in Australia or New Zealand. "Supply" in this context is defined broadly — it includes selling, hiring, exchanging, giving as a gift, and offering for sale. The responsible supplier:

• Must have an Australian or New Zealand address
• Takes legal responsibility for the product's compliance
• Signs the DoC in their own name and against their own address
• Must be able to produce the TCF if the ACMA requests it

For products manufactured in Australia: the manufacturer is typically the responsible supplier.

For imported products: the Australian importer is typically the responsible supplier. An overseas manufacturer does not qualify unless they have a registered Australian or NZ address. Where an overseas manufacturer sells directly to Australian end-users (e.g. via an online store), the entity responsible for compliance is the importer of record — typically the overseas entity's Australian subsidiary or a nominated local distributor.

Where an Australian company contracts a Chinese or other overseas manufacturer to produce a product for the Australian market (an "Own Design Manufacture" arrangement), the Australian company is the responsible supplier even though they did not physically manufacture the product.

ACMA Compliance Labelling Database (Radio Products)

For products containing intentional radio transmitters — BLE, Wi-Fi, LoRa, Zigbee, LTE-M, NB-IoT, or any other radio (see Bluetooth vs Wi-Fi vs LoRa vs Zigbee for a protocol comparison with regulatory notes) — the responsible supplier must register the device in the ACMA's compliance labelling database before the product is supplied. Registration is made via the ACMA's online portal.

Registration is based on the same DoC and test evidence held in the TCF. It links the product to its responsible supplier, the standards declared against, and the accredited test report. The ACMA registration number does not replace the RCM mark on the product — both are required for radio products. Note that any existing ACMA database entry for a radio module incorporated into your product belongs to the module manufacturer and covers only that module; your complete product must be registered separately as a new entry under your name as responsible supplier — see what a pre-certified radio module's ACMA certification covers and what registration the complete product still requires.

When a DoC Must Be Updated

A DoC issued for a specific product and test report version becomes invalid if any of the following change:

• The product's hardware design — any change to the PCB layout, component selection, power supply design, enclosure, or cable configuration that could affect EMC or electrical safety performance requires either a new test or a documented engineering assessment showing the change does not affect compliance. If the assessment concludes that retesting is needed, a new test report and a new DoC must be issued.
• The applicable standard edition — if the ACMA's referenced standard is updated and the new edition applies to new supply of the product, the product must be reassessed against the new edition and a new DoC issued.
• The responsible supplier changes — if the business name, legal entity, or address of the responsible supplier changes, the DoC must be reissued under the new details.

Minor changes (aesthetic, firmware updates that do not affect transmitter parameters, packaging changes) generally do not require a new DoC, but a documented internal review confirming the change does not affect compliance should be added to the TCF.

Practical Examples

DoC for a BLE sensor board: The responsible supplier (the Australian company that designed the product) prepares a DoC identifying the product as "Model SEN-200" against AS/NZS CISPR 32:2015 (the applicable standard for this multimedia-class sensor), referencing test report "EMC-2026-1045" from EMC Technologies (a NATA-accredited lab). The DoC is signed by the company's technical director, dated after the test report date, and filed in the TCF alongside the schematics, BOM, and full lab report.

DoC for an imported industrial controller: An Australian distributor imports a programmable controller from a European manufacturer. The European product has CE marking, and the underlying CISPR 32 test data is shared. The Australian distributor issues an RCM DoC in their own name and Australian address, referencing the same test report but declaring against AS/NZS CISPR 32 (the Australian standard). The test data is identical; only the DoC details change to reflect the Australian responsible supplier and Australian standard designation.

Design Considerations

• Build the TCF in parallel with development, not retrospectively: The TCF requires schematics, BOM, and design files from the development phase. Exporting the design files, recording the decisions made during pre-compliance testing, and maintaining version history during the product's design phase takes minutes; reconstructing them after the product has shipped to customers takes days and introduces uncertainty about which revision was actually tested.
• Keep test reports in their original form: The TCF must contain the full test report from the accredited laboratory, not a summary. Archive the original PDF received from the lab — if the lab's portal access expires or the lab closes, retrieving the original report can be difficult. Back up the report in at least two locations (e.g. company document management system and local archive).
• Name standards with edition years on every DoC: "AS/NZS CISPR 32" and "AS/NZS CISPR 32:2015" are different declarations. The ACMA's enforcement team and any customs authority reviewing the DoC will check the edition against what was in force at the time of supply. Missing edition years create ambiguity that can invalidate the DoC.
• Review the DoC at every hardware revision: A hardware revision log that links each PCB revision to the applicable DoC and test report makes compliance audit responses straightforward. For Zeus Design clients, compliance documentation review is included as part of design sign-off before each PCB revision goes to manufacture.

Common Mistakes

• Issuing the DoC before the test report exists: The DoC date must be on or after the date of the test report it references. A DoC signed before the test was completed is invalid — the test is the evidence; the DoC is the declaration that the evidence supports compliance.
• Listing the overseas manufacturer as the responsible supplier: For imported products, the responsible supplier must have an Australian or New Zealand address. Listing an overseas entity's address on the DoC makes the DoC non-compliant with ACMA requirements.
• Not updating the DoC after a hardware change: The DoC declares that a specific product (named by model number and description) meets specific standards. A hardware revision that changes the PCB or key components is a different product — continuing to supply the revised product under the original DoC is a compliance failure. At minimum, a documented internal review must conclude whether a new test is needed; if it is, a new DoC must be issued after testing.
• Retaining the TCF for fewer than 10 years: The ACMA can request TCF records for up to 10 years after the last supply date, not from the issue date of the DoC. Products with long sales periods mean the TCF must be kept for correspondingly longer total periods. Destroying records on a fixed calendar schedule without accounting for the last-supply date creates audit risk.
• Failing to issue a separate DoC for the Australian market: CE test data can often support an RCM DoC, but a separate DoC must still be prepared: identifying the Australian responsible supplier, referencing the Australian standard designation (e.g. AS/NZS CISPR 32, not EN 55032), with an Australian or NZ address in the supplier field. The CE mark and CE DoC alone do not constitute RCM compliance documentation.