Major RCM policy adjustments rolled out from late 2025 to 2026 covering safety standard migration, EESS charging reform, IoT cybersecurity independent regulation & device risk boundary clarification.

Change 1: IT/AV Safety Standard Migration (Not Full Forced Replacement)

AS/NZS 60950.1 transition deadline: Jan 5, 2026. Rules clarified:

·Newly designed products launched post Jan 5, 2026 must adopt AS/NZS 62368.1:2022 for safety testing.

·Mass-produced goods with valid CoC certificate issued before Jan 5, 2026 may continue sales under AS/NZS 60950.1 until the 5-year CoC expiry date without retesting.

·CoC certificates issued pre-transition retain full 5-year validity, no early expiration due to standard upgrade. Only newly added models must follow the latest standard.

Core test logic difference: 60950.1 prevents known hazards; 62368.1 identifies all energy hazard sources (electricity, heat, machinery, radiation) with targeted protection design.Supporting standard upgrades: AS/NZS CISPR 32:2023 updated EMC limit; AS/NZS 4665.2:2022 tightened no-load power consumption for power adapters. Old-version test reports are gradually rejected by EESS in 2026.

  Change 2: Revised EESS Charging System (Debunk Per-unit Annual Fee Misinformation)

New tariff table effective Jul 1, 2025 with two separated official charges:

·Annual ABN Entity Fee: AUD 231.91 per year, all products under one ABN share one yearly fee (no per-product multiplication). Only Australian responsible suppliers pay this fee; New Zealand IRD entities have no equivalent annual charge.

·One-off Product Registration Fee (valid for selected term): 1-year AUD 86.91 / 2-year AUD 173.83 / 5-year AUD 434.56. No recurring annual product fee. Overdue payment freezes EESS account, recoverable after arrears settlement without permanent registration cancellation.

  Change 3: Tiered Certificate Validity Rules

·Third-party safety CoC fixed 5-year validity for Level 3 high-risk goods; EESS registration maximum term cannot exceed remaining CoC validity period.

·Level 3 only supports optional 1/2/5-year registration terms; Level 2 medium-risk registration has no fixed expiry date, permanently valid with unchanged hardware, active ABN & unupdated applicable standards.Level 3 Critical Reminder: Launch CoC renewal testing minimum 6 months before expiry; overdue suspension leads to nationwide product delisting. Supplementary delta testing required if ACMA updates applicable standards during validity window.

  Change 4: Independent IoT Cybersecurity Regulation (Separate from RCM Testing)

Australia Smart Device Cybersecurity Rules officially effective Mar 4, 2026, independent of RCM/EMC/EESS systems with separate test & filing requirements:

·Mandatory 3 baseline security requirements: Ban universal default passwords, encrypted firmware update channels, clear user data privacy statements.

·Compliance testing needs dedicated IoT security labs with separate quotation & report, cannot be bundled into standard RCM testing budget. Customs & market supervision conduct independent security document inspection, EESS registration does not verify cybersecurity files.

·Exemptions: Fully offline non-networked smart devices; mass-produced inventory launched before Mar 4, 2026 enjoy transition exemption.

  Change 5: Mobile Phone & Tablet Exemption from Level 3 EESS Registration

Smartphones & tablets are excluded from EESS high-risk equipment list under 2026 Smart Device Act exemption clause, classified as Level 1 low-voltage goods only requiring EMC & RF DoC self-declaration without paid safety registration. Matching AC wall adapters alone fall into Level 3 mandatory registration scope. No official EESS supplementary registration notices for mobile devices exist on government systems.

  Change 6: Clear Boundary Between Regulated & Unregulated Goods

ACMA released clear judgment criteria in late 2025:

·Mains 230V AC powered goods mostly require safety testing & EESS registration.

·Pure battery low-voltage goods may escape safety registration; exception: Low-voltage goods with wireless transmitters still enforce EMC & RF testing with complete test reports reserved for ACMA random audit, false DoC triggers cargo return & fines.

  Change 7: Strengthened RCM Mark & Plug Compliance Inspection (2026 Strict Enforcement)

·Mark rules unchanged with stricter inspection: Minimum height 3mm, equal-proportion triangle, permanent printing only. Tiny goods may print logo on package with full ABN/Supplier Code stated in manual. Rated voltage/frequency marking mandatory on nameplate.

·Plug Mandate: Goods sold in Australia must adopt AS/NZS 3112 Type I flat three-pin plug. Separately sold adapters without independent EESS registration lead to full cargo detention at customs. Qualified registered isolated adapters are permitted for matching sales.

Additional Easily Overlooked Compliance Points

·Australia EESS registration cannot cover New Zealand sales: NZ requires local IRD responsible entity & separate R-NZ label; EMC/safety/RF test reports are mutually recognized without duplicate testing, only extra NZ administrative fees apply.

·EESS product transfer filing mandatory when replacing Australian ABN proxy; goods are non-compliant during review transition period.

·RF testing cannot only reference AS/NZS 4268: Separate dedicated standards for 6GHz Wi-Fi, 5G cellular, UWB & RFID to avoid test item omission & report rejection.

·Lab Qualification Check First: Domestic labs must hold CNAS + ILAC mutual recognition or direct NATA accreditation; CNAS-only reports are invalid for EESS submission.

·7-year full document archiving legal obligation covers all test reports, DoC, registration receipts & hardware change records; missing files result in audit failure.

·Level 1 self-declaration is not a blank form: Complete raw EMC/RF test data must be reserved for official random inspection, untested self-declaration is illegal.

Reference Cost & Lead Time (CNY)

·Level 1 low-voltage wireless (Bluetooth/Wi-Fi): ¥10,000–¥25,000; extra ¥20,000+ for 5G cellular modules

·Level 2 medium-risk with safety test: ¥20,000–¥50,000, higher for high-power energy storage & heating equipment

·Level 3 high-risk full package + EESS registration: Starting from ¥40,000; energy storage/charging piles cost ¥60,000–¥80,000

Lead Time Reference: Wired Level 2/3: 4–6 weeks; Bluetooth/Wi-Fi wireless: 6–8 weeks; 5G/IoT with cybersecurity assessment: 8–10 weeks; Q4 peak season adds extra 2 weeks lab backlog. Level 3 CoC renewal needs 6-month advance planning before expiry.

BlueAsia Compliance Consultant: +86 13534225140 (Benson)