RCM Compliance for Selling Electronics on Amazon Australia: EESS Levels, Registration and ACMA Labelling

To sell household electrical products on Amazon Australia you need the Regulatory Compliance Mark (RCM) on the equipment, and for medium and high risk equipment you also need registration on the national EESS register by an Australian or New Zealand based Registered Responsible Supplier. RCM marking is mandatory at Levels 1, 2 and 3; registration is voluntary at Level 1 and mandatory at Levels 2 and 3. This is general information, not legal advice; confirm with the regulator or a compliance consultant.

What are EESS, ERAC and the RCM?

EESS is the Electrical Equipment Safety System. It classifies household electrical equipment into levels 1, 2 and 3, with proportional evidence-of-compliance and seller-registration requirements. ERAC's members oversee the scheme, and the RCM is a trade mark of the ERAC members. Our RCM glossary entry gives the short definition.

EESS regulates Queensland, Victoria, Western Australia and Tasmania; South Australia, the Northern Territory and the ACT were transitioning; New South Wales does not participate and keeps declared and non-declared articles. That page is undated and jurisdiction status may have changed, so check the current position with your state regulator before you sell into New South Wales.

The old ERAC registration database was replaced by the EESS Platform from 14 October 2024. Guides that still tell you to register at equipment.erac.gov.au are out of date.

Which of my products are in scope, and at what level?

Level 1 is any in-scope equipment that is not Level 2 or 3; Level 2 is medium risk and Level 3 is high risk, both as defined in AS/NZS 4417.2. The Level 2 and 3 lists are in a PDF linked from that page and the latest edition of AS/NZS 4417.2.

The table combines the registration and marking rules with the records the Responsible Supplier must keep.

There is no single consumer-friendly list of every in-scope product. Typical Amazon categories include power supplies and chargers, extension leads, heaters, kitchen appliances and lighting. Do not rely on these examples: check the level lists, and if the product is not obviously covered, ask a regulator or a compliance consultant. Registering Level 2 or 3 equipment as Level 1 is not permitted and could result in penalties.

Who is the Responsible Supplier, and can I be one?

A Responsible Supplier is a legally identifiable Australian or New Zealand entity or person who manufactures or imports in-scope electrical equipment, the first supplier in the chain. The registrant must be an Australian or New Zealand legal entity with an ABN, or a New Zealand IRD number.

Overseas companies cannot register directly. They must either sell through a local Responsible Supplier or set up a local legal entity. If you are an Australian business with an ABN importing your own stock, you are usually the importer and so the Responsible Supplier. See importer of record on Amazon Australia and our ABN guide.

The Responsible Supplier must:

1. Make a Responsible Supplier Declaration confirming the equipment is electrically safe and meets the relevant standards.
2. Mark the equipment with the RCM.
3. Pay the annual registration fee and keep records, through a single Authorised Officer.
4. For Levels 2 and 3, make Equipment Declarations, which can be delegated to an Authorised Representative.

(source for all four: https://www.eess.gov.au/responsible-supplier/manufacturers-and-importers-responsible-suppliers/)

What if I only resell electrical goods bought from someone else?

Second and later suppliers, which include wholesalers, retailers and online sellers, must source the equipment from a Registered Responsible Supplier, ensure Level 2 and 3 equipment is registered, and ensure it is marked with the RCM. The page does not name marketplaces, but an Amazon seller who resells to Australian buyers fits the description of an online seller.

If you are a wholesale or retail-arbitrage seller, ask your supplier for the registration details of the Responsible Supplier and check them on the public register, not just for a PDF certificate. See Amazon Australia wholesale for how that model works.

What does Level 3 certification involve?

Level 3 equipment needs a valid and current Certificate of Conformity issued by a recognised certifier and listed on the National Register. Registration can be for 1, 2 or 5 years but cannot outlast the certificate, and fees for the unused part of a longer term are not refunded. Level 3 equipment offered for sale must be registered by a Responsible Supplier.

Certification fees and timelines depend on the certifier and the product, so none are quoted here. Blooprint does not do product testing, certification or legal work; certification comes from a recognised certifier.

How does ACMA labelling fit in?

ACMA regulates products with electromagnetic compatibility, radiocommunications, telecommunications and electromagnetic energy requirements, and use of the RCM on those products is governed by ACMA arrangements. Suppliers of products that must be labelled under an ACMA labelling notice must register as a Responsible Supplier on the EESS Registration Database.

Registration for ACMA purposes only has no fee and does not require you to enter product details. ACMA's levels do not correlate directly with EESS levels. An agent cannot act as an intermediary to let others use the trade mark.

Bluetooth speakers, Wi-Fi gadgets, smart plugs and wireless chargers are the sort of products that raise both ACMA and EESS questions. Check ACMA's labelling pages at acma.gov.au for your product.

What will Amazon ask for on electrical listings?

Amazon's Australian policy pages for Electronics sit inside Seller Central. Amazon also publishes a seller guide on how to list an electronics product. The exact documents Amazon asks for are published by Amazon only inside Seller Central, so check there. Keep the Responsible Supplier registration, the declarations, the Certificate of Conformity for Level 3 and photos of the RCM label ready. Our product safety guide covers the wider duties.

What should I check before I list an electrical product?

Work through this once per product, and again when the factory changes the design or power supply.

1. Decide whether it is in scope. Is it household or personal electrical equipment? Use the level lists linked from the EESS risk-level page.
2. Find the level. If it is on the Level 2 or Level 3 list, treat it as that level. If it is on neither list, it is Level 1 by definition.
3. Identify the Responsible Supplier. That is you, if you import it. Otherwise it is the Australian or New Zealand entity you buy from.
4. Look it up on the register for Levels 2 and 3, and keep a copy of the record.
5. Check the physical mark. The RCM must follow AS/NZS 4417.1. Responsible Suppliers receive that standard on registration, which gives the correct RCM dimensions.
6. Check radio and telecoms. If the product transmits, connects to a network or can interfere with radio, find out whether an ACMA labelling notice applies.
7. Photograph everything and store the declarations with your purchase orders.

A reasonable approach for a first import is to raise the question with your supplier before you order samples, not after the container lands. Stock that arrives unmarked cannot be sold, and relabelling after arrival is a job for the Responsible Supplier, not for an FBA prep centre.

What does it cost, and how long does it take?

No figures are given here. The EESS registration fee depends on the equipment level and the registration term of 1, 2 or 5 years, and certifier charges are set by each certifier. A fee schedule is not reproduced here, so ask the EESS platform for the current fee, and ask your certifier for a written quote and timeline.

FAQ

Is the RCM the same as CE or FCC? No. The RCM is a separate trade mark of the ERAC members and shows compliance with the EESS. A CE or FCC mark does not satisfy Australian marking.

Can I use my overseas manufacturer as the Responsible Supplier? Not if it is an overseas company. Overseas companies cannot register directly and must sell through a local Responsible Supplier or set up a local legal entity.

Is registration needed for Level 1 equipment? No. Registration of Level 1 equipment on the national register is voluntary, but RCM marking is still mandatory at all three levels, so a Level 1 product without the mark cannot be sold.

Does this apply in New South Wales? NSW does not participate in EESS and keeps declared and non-declared articles. Check the NSW position with the state regulator.

Do I have to be a company to register? The registrant must be an Australian or New Zealand legal entity with an ABN, or a New Zealand IRD number. A sole trader with an ABN is a legally identifiable person, but confirm with the regulator.

What if my product also contains a button battery? The button battery rules are separate from the electrical rules and both can apply to the same product, for example a remote-controlled light; see button battery standards for Amazon sellers.

Next steps

Start from the Australia hub, list your electrical ASINs with their EESS level and any ACMA labelling duty, and confirm the Responsible Supplier for each. For help keeping listings and Seller Central notices in order, see Amazon listing management in Australia. Blooprint is an Amazon SPN verified partner working with Australian sellers remotely from Bengaluru.