Timeliness and Information Source Statement: This document is based on practical experience in cross-border electrical product certification services from January to November 2025. It integrates audit cases from 12 NATA-accredited laboratories in China (including Blue Asia Technology), cross-border compliance research data from the Zhejiang Council for the Promotion of International Trade, and publicly available general regulations from Australian and New Zealand regulatory bodies. Document requirements and standard applicability mentioned herein reflect current industry best practices. Final compliance determinations should be based on official responses from MBIE (New Zealand Ministry of Business, Innovation and Employment) and EESS (Electrical Equipment Safety System).
I.2025 RCM Certification Documentation Checklist:
The core principle of New Zealand RCM certification is “risk-based compliance,” with significant differences in documentation thresholds between Level 1-3 products. As multiple laboratories tighten audit standards in 2025, the following are the most commonly rejected documentation points for each level:
1.Level 1 (Low Risk: e.g., 12V Bluetooth speaker): Self-Declaration ≠ Arbitrary Filling
Industry-wide logic: Battery-powered, portable devices with power <50W may use self-declaration. However, in 2025, agencies have markedly increased requirements for “document completeness.”
Essential Documents & Practical Pitfalls:
·English technical specification sheet: Must list core components (e.g., batteries must comply with AS/NZS 62133). Direct Chinese translations will be rejected 100% (One Dongguan speaker manufacturer faced a one-week delay and paid an extra ¥2,000 in translation fees due to this).
·EMC Test Report: Must be issued by a CNAS/NATA-accredited laboratory and explicitly state “Compliant with AS/NZS CISPR 32:2023”—reports based on the outdated 2022 standard are now largely unacceptable;
·Local Responsible Party Declaration: After downloading the template from the EESS website, add a commitment stating “The product's core circuitry remains unchanged.” Failure to do so may require providing circuit comparison documentation.
2.Level 2 (Medium Risk: e.g., 240V household humidifiers): Dual Reports + Details Matter
Industry-wide logic: AC-powered products require both safety and EMC reports; wireless functionality is a key bonus point in this year's reviews.
Essential documents and new requirements:
·Safety Report: Must be based on AS/NZS 62368-1 standard. Reports based on the outdated 60950.1 standard are accepted by only a handful of agents.
·Wireless Module Certification: Products with Bluetooth/WiFi must provide module compliance certificates explicitly stating “Applicable to New Zealand frequency bands” (e.g., a smart humidifier manufacturer failed registration due to using an Australian-specific module certificate).
·Nameplate Design: RCM mark height ≥3mm, and removal of outdated C-Tick symbols (all agents will enforce this requirement by 2025);
·RF Supplementary Documentation: Nearly 60% of NATA labs now require submission of an “RF Parameter Confirmation Form” detailing operating frequencies, transmission power, etc. (Preparation in advance can reduce review time by 3-5 business days).
3.Level 3 (High Risk: e.g., power adapters, LED tubes): Full Documentation + Closed-Loop Registration
Official Mandatory Requirements: Must obtain SAA safety certification first, then complete EESS registration (MBIE's explicit compliance baseline). Specialized reports become the bottleneck in 2025 audits:
Document Category 2025 High-Frequency Laboratory Review Points Consequences of Missing Items & Remediation Costs
Basic Qualifications SAA certificate must state “NZ Acceptance” (New Zealand approval); otherwise, additional testing for New Zealand-specific items is required Registration rejection; retesting adds 1-2 weeks
Core Test Reports 1. Safety: AS/NZS 62368-1 (including insulation withstand voltage and temperature rise test data) 2. EMC: CISPR 32:2023 3. Wireless: AS/NZS 4268 Each missing item requires retesting, incurring additional costs and delays
Special Supplementary Documentation 1. LED Lighting: 70% of laboratories require photobiological safety testing data (e.g., a Foshan lighting factory missed Black Friday sales, losing 300,000 orders) 2. Switched Sockets: Testing required per AS/NZS 3105+3133 standards (mandatory from August 2024) Second sample submission may face over 1-month delays during peak seasons
Registration Materials
EESS application form requires local responsible party seal + Declaration of Conformity; models within the same series must include a “Differences Explanation Form”
Incomplete information requires resubmission, potentially incurring re-review fees
Packaging Marking
Nameplates must display EESS registration code; lighting products recommended to add traceability QR codes (One lighting manufacturer faced post-arrival rectification for missing codes) Batch rework packaging adds thousands of yuan per batch
II. 2025 RCM Certification Validity:
Many companies assume obtaining certification solves all issues, unaware that certificate validity follows “standard iterations” and “market spot checks.” Below is management logic distilled from over 50 renewal cases:
1.Unspoken Rules for Validity Periods Across Risk Levels
Risk Level Industry Practice for Validity Periods Trigger Scenarios Requiring Renewal
Level 1 No fixed term, but reports must update with standards (e.g., CISPR 32:2023 superseding old versions automatically invalidates prior reports) Standard updates, product redesigns (e.g., chip replacement)
Level 2 Report validity aligns with core standard cycles, typically requiring re-evaluation every 1-3 years Wireless band policy adjustments, safety standard updates
Level 3 Certificates offer optional 1/3/5-year validity (notably more companies choosing 5-year terms this year to reduce renewal costs) Certificate expiration, failure of annual compliance audit, standard revision
2.Level 3 Renewal: 3 Critical Milestones (2025 Operational Optimization Edition)
Level 3 is the only category requiring proactive renewal. Though streamlined this year, missing any of these 3 milestones may cause disruption:
-Initiation Timing: Peak seasons (Mar-May, Sep-Nov) require 4 months advance notice; off-peak seasons (Jan-Feb, Jun-Aug) require at least 2 months advance notice;
-Documentation: Only requires original certificate + Statement of Conformity + Difference Test Report (if only standards updated, full retesting unnecessary). Renewal costs are typically lower than initial certification.
-System Update: EESS system information must be updated within 7 business days after approval, or the registration code will expire.
3.Validity Period: The Hidden Killer—New Zealand's Most Common Pitfall in 2025
-Standard Transition: Australia has confirmed the AS/NZS 62368-1 transition period ends June 24, 2025. While New Zealand hasn't officially announced it, laboratories have largely stopped accepting applications under the old standard.
-Market Inspections: This year, Australia and New Zealand doubled their inspection efforts. One power supply manufacturer had its certificate suspended due to discrepancies between actual power measurements and reported values. It took 3 weeks of rectification and retesting to regain compliance.
If you're preparing documentation for New Zealand RCM certification of certain products (e.g., small appliances with wireless features, LED lighting), contact Blue Asia Technology at +86 13534225140 with your model number for professional certification consulting services.
