C-Tick/RCM for EV components.

Technical discussion on converting internal combustion to electric
TooQik
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Post by TooQik » Tue, 13 Aug 2013, 17:29

Cheers for the feedback James and Johny.

I didn't think $2200 was a bad price either. As Richo pointed out though, you'd want to make sure that you passed first time or repeated testing would make it expensive.

The fact that the ACMA feedback I received says the C-Tick/RCM is not required for a personal use conversion though is a relief. Image

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acmotor
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Post by acmotor » Tue, 13 Aug 2013, 17:31

Just being devil's advocate. Image
EV conversion check lists for tests will become longer.
EMC testing
IP ratings testing
Brake testing
Mechanical Engineer's approvals
Electrical Engineer's approvals
Victoria will require ASC/ESC systems
next you will be required to perform a crash test. Image

Maybe the 'vintage car' loophole can be used for conversions ?
Best stay under the radar while we can.

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Post by celectric » Tue, 13 Aug 2013, 20:11

TooQik wrote:If anyone is interested, I can post the reply I received if it's not in breach of any forum rules.
Yes please, I would like to see exactly what they have said, rather than having us all base our speculation on your interpretation.

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Post by TooQik » Tue, 13 Aug 2013, 20:36

As requested, the reply I received from the ACMA....

Assuming your electric vehicle does not incorporate any radiocommunications transmitters or telecommunications interfaces then the following would be applicable to your situation.

The ACMA’s compliance labelling requirements, which in the case of an electric vehicle would be the C-Tick or the regulatory compliance mark (the RCM) label similar to the following, only apply to devices that are “supplied” to the Australian market.

Image   N12345     Image

Note: The Australian based importers and/or manufacturers supplier code number (“N12345”) may be replaced with their Australian Company Number (ACN), Australian Business Number (ABN), Australian Registered Business Number (ARBN), Australian business name and address, personal name and address in Australia or an Australian registered trademark. There is no need to include any other information with the RCM symbol.

The C-Tick or the RCM symbol must be at least 3mm high and the supplier code number must be at least 1mm in height.


The manufacture of, in this case, a device subject to the electromagnetic compliance and labelling regime in Australia for “personal use” (i.e. not for supply to any others) falls outside the labelling requirements of the ‘Radiocommunications Labelling (Electromagnetic Compatibility) Notice 2008’ (the Notice) which can be downloaded here;

http://www.comlaw.gov.au/Details/F2013C00117

The compliance labelling requirements are, in part, aimed at importers who supply products to the Australian market and are required to show these devices are compliant with the applicable standards by labelling them with the appropriate compliance mark, in this case the C-Tick or the RCM.

If a person manufactures a device in Australia for “personal use” and does not, or will not in the future, supply said device to anyone else, provided the device does not cause interference*, the device does not require a C-Tick or an RCM compliance label and may be used in Australia by the person who manufactured the device.

*Section 197 of the Radiocommunications Act 1992 (the Act) prohibits a person from knowingly or recklessly causing substantial interference to radiocommunications.

Please also note that for the purposes of the ACMA's compliance and labelling arrangements the term "supply", as defined in the Act, has a very broad meaning and includes supply where no money or payment of any kind has occurred. I should advise that the loan of a device by an importer may constitute supply.

If the person who manufactured said device supplies it to anyone in the future, by any means including giving it away, then the ACMA’s compliance and labelling requirements will be applicable to the person who manufactured said device as they would then be deemed to be a supplier of goods to the Australian market.


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Richo
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Post by Richo » Tue, 13 Aug 2013, 20:41

As a side thought:

I can buy a whole stack of off the shelf chargers, batteries, solar panels, displays, computers that are EMC shove them all in a box and everybody is happy.

Shove some wheels on it and push it on the road and now it needs it's own EMC testing.

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Post by Richo » Tue, 13 Aug 2013, 20:48

Yeah I'm satisfied with their response.

I do agree that NCOP14 is NOT clear and should say "intentional RF devices" such as ....
Or a disclaimer suggesting road compliance does not infer RF compliance.

But in all reality is there to bring to your attention that the 1000W TV transmitter in your EV may not be ok even though it is road worthy.
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Post by Tritium_James » Tue, 13 Aug 2013, 22:19

Richo wrote:I can buy a whole stack of off the shelf chargers, batteries, solar panels, displays, computers that are EMC shove them all in a box and everybody is happy.


Not if you then sell that box. You are then the supplier of that product, and it needs to be C-Tick (now RCM) marked, which will involve EMC testing the whole box.

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Post by celectric » Wed, 14 Aug 2013, 00:20

The definition of "supplier" seems awfully restrictive. This basically kills the market for second-hand conversions. And what if you lend your car to your mum to do her shopping?

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Post by acmotor » Wed, 14 Aug 2013, 18:28

Guys, isn't there a need for some common sense in this debate ?

Are we to have EV conversions canned because beurocrats with no electrical or electronic knowledge and wouldn't know RFI from KFC, set up regulations ? OK, extreme, but you get the point.

I'm certain that if you can do an EV conversion then you can test for yourself if there is an RFI issue without the need for a $2,000 test and $500,000 worth of test gear.
You would comply with 'Section 197 of the Radiocommunications Act 1992 (the Act) prohibits a person from knowingly or recklessly causing substantial interference to radiocommunications.'

As for selling a converted EV i.e. becoming a 'supplier'. Firstly, it is not very sucessful, fact.
Secondly, there are other safety and service issues that totaly are more important than C-tick. IMHO

TooQik, I am wondering why is this C-tick so important ? Do you plan to do commercial conversions ?
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Richo
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Post by Richo » Wed, 14 Aug 2013, 20:51

No it is a check box on the NCOP14 form that is causing problems.
And the details relating to it are not clear.

I don't remember discussions on adding this to NCOP14.
So this must be one of the last additions by the ppl over East.

I believe the "intent" for NCOP14 was directed at RFID, keyless entry etc to have appropriate approvals.
That is the common sense.

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Post by Richo » Wed, 14 Aug 2013, 21:07

Richo wrote:I can buy a whole stack of off the shelf chargers, batteries, solar panels, displays, computers that are EMC shove them all in a box and everybody is happy.

Tritium_James wrote: Not if you then sell that box. You are then the supplier of that product, and it needs to be C-Tick (now RCM) marked, which will involve EMC testing the whole box.


Do you expect all the ebikes to undergo EMC testing? - Oops there goes that sector...

At what point does connecting complaint parts require retesting as a whole?
I Sell a battery connected to a charger does that need retesting?
What about a Monitor connected to a PC does that need retesting?
Or perhaps a DVD player I added to my car does the whole car need retesting?
Perhaps a Tritium Motor controller in an EV - does the whole car need retesting?
And if so what would be the point of testing it in the first place?
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Post by TooQik » Wed, 14 Aug 2013, 21:10

acmotor wrote:TooQik, I am wondering why is this C-tick so important ? Do you plan to do commercial conversions ?
I was simply looking for input from anyone who had knowledge to help me ensure any conversion I do would pass the last check item on the NCOP14 document:

4.4 Do all RF devices comply with ACMA requirements and are they appropriately labelled?

I have no intention of doing commercial conversions.

I'm happy that the reply I received from the ACMA clarifies that for a personal use conversion I won't be in breach of any ACMA requirements and should pass the last check item without the need to pay to have the vehicle tested.

As for the can of worms this topic has seemingly opened up, I apologise as this was not my intention.

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Post by Johny » Wed, 14 Aug 2013, 21:36

They are referring to devices that are intended to radiate RF. Since it is quite unlikely that anyone has added telemetry to their EV (and will certainly know if they have), tick the box!

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Post by Richo » Fri, 16 Aug 2013, 20:54

Just tick it Image

You can put the 1kW illegal TV transmitter back in after the conversion Image
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Post by TooQik » Sun, 18 Aug 2013, 00:44

Richo wrote:You can put the 1kW illegal TV transmitter back in after the conversion Image
There go my hopes of getting channel 7 to sponsor my build Image

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