As of 1 March 2026, every solar battery STC claim has to come with geotagged, timestamped photos of the install's labelling. The Clean Energy Regulator is now running AI over the photos and failing claims that don't meet AS/NZS 5033 / 5139 / 4777.1 / 3000 — the four standards that govern solar and battery labelling in Australia.
That's a problem for a lot of installers because — in CER's own words — "non-compliant labelling is the most common reason for solar battery installations to not meet Australian standards." Number one. More common than wiring faults, mounting issues, or missing isolators.
If you've been buying printed labels off Amazon or a generic signage shop, there's a good chance some of them won't pass the new photo evidence checks. Here's what every label has to be — and why engraved labels are quietly exempt from one of the trickiest requirements in the whole spec.
What the CEC's labelling guide actually requires
The CEC's Advice on Labelling document (Version 2, June 2023) consolidates the rules from AS/NZS 5033, 5139, 4777.1 and 3000. Every label on a PV or battery system has to be:
- Sufficiently durable — designed to last as long as the system itself.
- Made of appropriate materials for the location — outdoor labels need to handle weather, indoor labels can be lighter.
- Fixed in a durable manner — adhesive, mechanical, or both, depending on the surface.
- In English.
- Legible at viewing distance — minimum 5mm uppercase / 4mm lowercase per metre of viewing distance, with stricter rules for warning labels (covered below).
- Indelible — the markings can't fade, smudge, or wear off over the system's life.
- Visible — labels stuffed inside cupboards or hidden behind cable looms don't count.
- UV resistant if exposed to direct sunlight — this is where it gets interesting (see below).
The UV resistance test — and the engraving exception most installers don't know about
If a label is exposed to direct sunlight, the spec says it has to pass IEC 60068-2-5:2018. That's a 720-hour open-flame carbon-arc UV chamber test with intermittent water spray, run at 63°C with 50% humidity. It simulates roughly two years of accelerated outdoor weathering.
A lot of printed labels will not pass that test. Cheap inkjet output fades in months. Even some thermal-transfer prints chalk and crack within a year of full-sun exposure.
But here's the bit at the bottom of section 3.1.1 of the CEC document, that we suspect a lot of installers haven't read:
EXCEPTION — This requirement does not apply to markings that are physically engraved, embossed or etched with durable markings.
Engraved, embossed, or etched markings are exempt from the UV chamber test. Not because the standard is being soft on them — because the marking is the material. There's no ink, toner, or printed surface that can fade. The text is cut into the substrate. As long as the substrate itself is durable for the location (UV-stable traffolyte, anodised aluminium, stainless steel, etc.), the label is compliant by virtue of how it's made.
That's a real practical advantage. With engraved traffolyte:
- You don't need to chase test reports from the supplier proving they passed IEC 60068-2-5.
- The "indelible" requirement is met automatically — you can't accidentally rub off something that's cut into the plastic.
- Twenty-year outdoor service life is the norm, not the exception.
Sizing rules — the ones inspectors actually check
The general rule is 5mm uppercase / 4mm lowercase per metre of viewing distance. But several specific labels have minimums spelled out:
- "WARNING: HAZARDOUS d.c VOLTAGE" — minimum 10mm letters (AS/NZS 5033 §5.5.1.2).
- "WARNING: PV STRING DISCONNECTION POINT" — minimum 10mm letters (AS/NZS 5033 §5.5.2.2).
- Green "PV" reflector sign — minimum 100mm diameter (AS/NZS 5033 §5.4).
- Green "ES" (energy storage) reflector sign — minimum 100mm diameter (AS/NZS 5139 §7.3). Must include the UN number for the battery chemistry — e.g. UN3480 for LiFePO4.
- "Danger, Risk of Battery Explosion" — minimum 175 × 175 mm (AS/NZS 5139 §7.8).
Colours that pass inspection
The CEC document is unambiguous on colour:
- General information — white background, black lettering.
- Essential safety information — yellow background, black lettering. AS/NZS 5033 also requires a warning symbol.
- Emergency-personnel signs — red background, white lettering.
- PPE signs (per AS/NZS 5139) — blue background, white lettering.
- Special signs (PV / ES reflective) — green retro-reflective, with prescribed text.
Get any of these wrong and your photo will fail the new CER assessment.
The one part engraved labels don't replace today: retro-reflective PV / ES signs
Be honest about this. The 100mm green "PV" and "ES" labels under AS/NZS 5033 / 5139 must be retro-reflective — they need to bounce light back at a torch in a dark roof void or behind a meter box. That's a different material from engraved traffolyte. Engraved labels cover every other tag on the install, but the reflective discs need a retro-reflective substrate.
That said — we're actively working on adding retro-reflective PV / ES discs to our range so installers can get the full compliant kit from one supplier instead of splitting orders across two suppliers. We'll update this post when it ships.
For now, an inspector with a torch will spot a non-reflective green "PV" disc immediately, so don't try to substitute. Order the reflective discs separately until we have them in stock.
What CER is photographing as of 1 March 2026
The new Solar Battery Photo Guide calls out three photo locations every battery STC claim must cover:
- Outside the meter box — including the green reflective ES disc with the UN battery chemistry number, and any PV disc if applicable.
- Switchboard and inside the meter box cover — including the "WARNING / MULTIPLE MODE INVERTER CONNECTED / NEUTRAL AND EARTH CIRCUITS MAY BE LIVE" label, the emergency shutdown procedure, and any back-up supply / backed-up circuits labelling.
- The battery itself, front and sides — chemistry warning, fire-fighting instructions, isolator labels.
The photos must be geotagged and timestamped. CER explicitly says the warning label about the multiple-mode inverter is "commonly missing or placed in the wrong location." If your install isn't compliant, that's a failed STC claim — and a return trip to site to fix it.
How to make sure your install passes
Three practical things:
- Use engraved labels for everything except the reflective PV / ES discs. They're inherently UV-compliant, indelible, and durable for the system's life. No test reports needed.
- Get the sizing right. The 10mm-letter warning labels and the 175×175mm battery explosion sign are the ones inspectors most often flag. If your label maker doesn't enforce minimum sizes, your eye is the only check.
- Take the photos before you leave site. CER wants geotagged + timestamped — don't try to shoot them later from your van.
Designing compliant labels with RBZ 3D
Our online label designer includes templates pre-set to AS/NZS sizing and colour conventions — switchboard tags, pump and motor labels, cable tags, selector switches, push-button plates, valve tags, and a Solar PV tag. Everything is laser-engraved on UV-stable traffolyte (white/black, yellow/black, red/white, green/white, blue/white, and more), so it falls under the engraving exemption from the UV chamber test.
Retro-reflective PV / ES discs are on our roadmap — actively in development so you'll be able to order the full compliant kit from us in one go rather than splitting suppliers. Until that ships, source the reflective discs separately and let us know if you'd like to be told when they're available.
If you've got a job coming up and want to talk through what's needed, drop us a quote request — we can spec the full label kit for your specific install.
References
- Clean Energy Council — Advice on Labelling (Version 2, June 2023)
- Clean Energy Regulator — Solar Battery Photo Guide (January 2026, effective 1 March 2026)
- AS/NZS 5033 — Installation and safety requirements for photovoltaic (PV) arrays
- AS/NZS 5139 — Electrical installations: Safety of battery systems
- AS/NZS 4777.1 — Grid connection of energy systems via inverters
- AS/NZS 3000 — Wiring rules
This article summarises publicly available regulatory guidance and is not a substitute for professional advice. Confirm requirements for your specific install with your inspector and the relevant network service provider.