Radio Equipment Directive (RED): An Essential Guide

The Radio Equipment Directive (RED) sets requirements for the safety, electromagnetic compatibility and use of the radio spectrum of radio equipment placed in the EU market. It covers devices with some sort of wireless communication capability, including WiFi, LTE, 5G, Bluetooth and GPS.

It has also been updated to cover USB standards for chargers, user data privacy protection, and software compatibility.

In this guide, we explain what importers and manufacturers must know about the Radio Equipment Directive – including standards, labelling, documentation, and testing requirements.

What is the Radio Equipment Directive (RED)?

The Radio Equipment Directive is a CE marking directive that regulates the placement of radio equipment on the EU market, and sets requirements for the health, safety, electromagnetic compatibility, and use of the radio spectrum. The Radio Equipment Directive also provides the basis for further regulation covering aspects such as:

• Protection of personal data
• Protection against fraud
• Interoperability
• Access to emergency services
• Compliance of combined radio software and equipment

Product scope

The Radio Equipment Directive covers radio equipment, which the directive defines as an electronic product that either intentionally emits and receives radio waves, or include an accessory permitting the intentional emission and reception of radio waves for communicative purposes.

While the Radio Equipment Directive covers a broad range of products, it also exempts some equipment. We list them below.

Product examples

The directive covers most of radio equipment, including the following products:

• Mobile phones
• Laptops
• Radars
• Broadcasting devices
• Fitness devices
• Smartwatches
• Routers
• Radio transceivers
• Devices with Wi-Fi, Bluetooth, or GPS capabilities

Exemptions

Annex I of the Radio Equipment Directive lists products not covered by the directive, such as:

• Radio equipment used by radio amateurs
• Marine equipment
• Aviation equipment for airborne use
• Custom-built evaluation kits

Harmonised Standards

Harmonised standards generally provide a presumption of conformity with requirements of directives such as the Radio Equipment Directive, and you can find them on this website.

In practice, this means that by testing your product against the requirements of relevant harmonised standards, you can show product’s compliance with the requirements of the Radio Equipment Directive.

Technically, it might be possible to utilise a different solution to prove conformity, but using harmonised standards is usually the most straightforward way to comply with the directive’s requirements.

Examples

We list here several examples of standards harmonised under the Radio Equipment Directive:

a. EN 55035 – Electromagnetic compatibility of multimedia equipment – Immunity requirements

b. EN 300 433 V2.1.1 – Citizens’ Band (CB) radio equipment; Harmonised Standard covering the essential requirements of article 3.2 of the Directive 2014/53/EU

c. EN 301 357 V2.1.1 – Cordless audio devices in the range 25 MHz to 2 000 MHz; Harmonised Standard covering the essential requirements of article 3.2 of Directive 2014/53/EU

d. EN 301 908-15 V15.1.1 – IMT cellular networks; Harmonised Standard for access to radio spectrum; Part 15: Evolved Universal Terrestrial Radio Access (E-UTRA FDD) Repeaters

e. EN 303 204 V3.1.1 – Fixed Short Range Devices (SRD) in data networks; Radio equipment to be used in the 870 MHz to 876 MHz frequency range with power levels ranging up to 500 mW e.r.p.; Harmonised Standard for access to the radio spectrum

f. EN 303 348 V1.2.1 – Audio frequency induction loop drivers up to 45 amperes in the frequency range 10 Hz to 9 kHz; Harmonised Standard for access to radio spectrum

Essential Requirements

Article 3 of the Radio Equipment Directive lists essential requirements for radio equipment. We list here just a few of those requirements.

The construction of radio equipment should ensure:

a. The protection of the health and safety of humans, pets, and property

b. Sufficient electromagnetic compatibility

c. Effective and efficient use of the radio spectrum to avoid dangerous interference

Additionally, some classes of radio equipment must also comply with requirements such as the following:

a. It is equipped with an accessible and operational USB Type-C receptacle

b. It includes safeguards to protect the user’s personal data and privacy

c. It includes features that ensure access to emergency services

Conformity Assessment Procedure

Per Article 17, radio equipment manufacturers must carry out a conformity assessment to ensure they meet the essential requirements set in Article 3. They can perform one of the following conformity assessment procedures where the manufacturer has used harmonised standards:

a. Module A (internal production control as outlined in Annex II)

b. Module B + C (EU-type examination, and conformity to type based on internal production control as found in Annex III)

c. Module H (conformity based on full quality assurance, which is detailed in Annex IV)

If the manufacturer has not used harmonised standards – because, for instance, they do not exist for specific products – then it can only use the conformity assessments outlined in modules B and C, or module H.

Some of the requirements might be different, according to the procedure. We briefly summarise this in the table below.

Requirements	Module A	Module B+C	Module H
When can this conformity assessment procedure be used?	a. Harmonised standards where applied	a. Harmonised standards where applied, or b. Harmonised standards where applied were not applied (or only applied in part), or c. Harmonised standards do not exist	a. Harmonised standards where applied, or b. Harmonised standards where applied were not applied (or only applied in part), or c. Harmonised standards do not exist
Labelling	a. CE marking b. Traceability information c. Pictogram and information concerning USB Type-C charging (if any)	a. CE marking b. Traceability information c. Pictogram and information concerning USB Type-C charging (if any)	a. CE marking b. Identification number of the notified body c. Traceability information d. Pictogram and information concerning USB Type-C charging (if any)
Documentation	a. Declaration of conformity b. Technical documentation c. Instructions	a. Declaration of Conformity b. Technical documentation c. Supporting evidence (e.g., test results) d. EU-type examination certificate e. Instructions	a. Declaration of conformity b. Technical documentation c. Quality system documentation d. Test reports e. Inspection reports f. Notified body reports g. Instructions
Notified body	Not required	Required	Required
Testing	Not specified, but generally required	Required	Required

Documentation

The Radio Equipment Directive requires manufacturers to provide the authorities with various relevant documentation upon request, to prove their products’ conformity with the directive.

Declaration of Conformity

The Declaration of Conformity accompanying the radio equipment should contain the following information:

a. Type, batch, or serial number

b. Manufacturer’s name and address

c. Object of declaration permitting traceability; may include a colour image

d. Statement declaring conformity with the Radio Equipment Directive, and where applicable, other EU legislations

e. References to relevant harmonised standards or technical specifications used, with identification number and version, and where applicable, issue date

f. Where applicable, a statement declaring the notified body’s performance of intervention and issuance of EU-type certificate

g. Where applicable, descriptions of components, accessories, and software permitting the device to operate is intended

h. A ‘signed for and on behalf of’ statement with the place and date of issue

Simplified DoC

The Radio Equipment Directive requires manufacturers to either provide a full copy of the declaration of conformity, or a simplified version of it, with each radio equipment.

A simplified declaration of conformity contains only two statements:

a. A sentence providing the manufacturer’s name and a declaration that the radio equipment types comply with the Radio Equipment Directive’s requirements.

b. The internet address to obtain the full text of the Declaration of Conformity.

Technical Documentation

The technical documentation should include relevant data or details used by the radio equipment manufacturer to ensure compliance, as set out in Annex V:

a. General product description, including photographs, software or firmware versions, user information, and installation instructions

b. Concept designs, manufacturing drawings and schemes of components, circuits, and sub-assemblies

c. Descriptions and explanations of those designs, drawings, and schemes

d. List of applied harmonised standards or descriptions of adopted solutions

e. A copy of the EU declaration of conformity

f. A copy of the EU-type examination certificate (if the conformity assessment modules B and C were carried out) and its annexes

g. Results of design calculations and examinations performed

h. Test reports.

Instructions

The Radio Equipment Directive requires manufacturers to provide clear and understandable instructions for the product’s usage, which should include:

a. Required product information (e.g., description of accessories and components) to use it as intended

b. Frequency bands

c. Maximum radio-frequency power transmitted in those frequency bands

d. Information regarding specifications of the radio equipment’s charging capabilities

e. Identification of Member States or geographical areas with restrictions on service or authorisation of use

Test Report

If your radio equipment passes lab testing, you receive a test report detailing your product’s compliance with the Radio Equipment Directive.

Modules B, and H explicitly mention that manufacturers must provide test reports as part of their required documentation. However, even if you follow the conformity assessment set by Module A, in practice you might need to prove that your product is compliant with relevant requirements, and thus provide a test report.

EU-type examination certificate

Module B requires the manufacturer to apply for a notified body to carry out an EU-type examination. After the notified body performs the examination, it issues an EU-type examination certificate if the product type meets the Radio Equipment Directive’s requirements.

The EU-type examination certificate should contain the following:

• Manufacturer’s name and address
• The examination’s conclusions
• Aspects of essential requirements covered by the examination
• Conditions for validity (if any)
• Necessary data for identifying the assessed type

Labelling requirements

The Radio Equipment Directive requires importers and manufacturers to ensure that relevant products are adequately labelled.

CE Marking

A CE marking indicates the conformity of the radio equipment with the requirements of relevant EU harmonisation legislation (e.g. the Radio Equipment Directive). There are certain rules to which the manufacturer must adhere regarding the affixation of the CE marking. For example, the CE marking should be:

a. Affixed clearly, obviously, and permanently into the radio equipment or its data plate, unless this is not possible.

b. Clearly affixed to the equipment’s packaging.

Identification number

The conformity assessment set by Module H requires the manufacturer to affix the notified body identification number to each piece of radio equipment.

The identification number of the notified body (that performed the conformity assessment procedure) should immediately follow the CE marking.

Traceability Information

Manufacturers should ensure that their radio equipment carry the following traceability information:

a. Product identity (e.g., batch, serial number, type)

b. Manufacturer identity (e.g., name, registered trade name or trademark, and postal address)

When the size or nature of the radio equipment does not permit the placement of such information, manufacturers should place it either on the packaging, or in an accompanying document. The contact details should be provided in an easily-understood language.

USB Type-C labelling requirements

Pictogram in left: Should be used if a charging device is included with the radio equipment. Pictogram in the right: Should be used if a charging device is not included with the radio equipment.

According to Directive (EU) 2022/2380 amending the Radio Equipment Directive, there are specific labelling requirements for radio equipment and charging devices equipped with a USB Type C receptacle, which includes:

• handheld mobile phones
• tablets
• digital cameras
• headphones
• headsets

Specifically, covered radio equipment should bear a pictogram indicating whether it includes, or does not include, a charging device.

If a USB Type-C charging device is included, it should bear a label with the following format:

---

XX – YY

W

USB PD

---

a. “XX” and “YY” should be replaced by the minimum power and maximum power, respectively, required to charge the radio equipment.

b. The abbreviation “USB PD” (USB Power Delivery) should be indicated if the radio equipment supports that charging communication protocol.

The label should remain obvious and readable, even if there are variations in its colour, line thickness, and more. You can find more information on Annex Ia of the directive.

Lab Testing

Generally speaking, importers and manufacturers need to have your radio equipment tested to prove its compliance with the Radio Equipment Directive’s requirements. When your products pass testing, you receive a test report that proves your radio equipment’s compliance with the requirements of the directive.

Methods of measurement

We list here a few methods of measurements that might be relevant for the Radio Equipment Directive:

a. EN 303 084 V2.1.1 – Ground Based Augmentation System (GBAS) VHF ground-air Data Broadcast (VDB); Technical characteristics and methods of measurement for ground-based equipment; Harmonised Standard covering the essential requirements of article 3.2 of the Directive 2014/53/EU

b. EN 301 841-3 V2.1.1 – VHF air-ground Digital Link (VDL) Mode 2; Technical characteristics and methods of measurement for ground-based equipment; Part 3: Harmonised Standard covering the essential requirements of article 3.2 of the Directive 2014/53/EU

c. VHF air-ground Digital Link (VDL) Mode 4 radio equipment; Technical characteristics and methods of measurement for ground-based equipment; Part 5: Harmonised Standard covering the essential requirements of article 3.2 of the Directive 2014/53/EU

Lab testing companies

Here, we list a few companies that offer to test against the Radio Equipment Directive’s requirements:

• Intertek
• SGS
• F2Labs
• Eurofins
• Element

Notified bodies

We list below several companies in the EU that offer notified body services for the Radio Equipment Directive:

• TÜV SÜD Product Service GmbH – Germany
• SGS FIMKO OY – Finland
• ENTE CERTIFICAZIONE MACCHINE SRL – Italy
• Kiwa Nederland B.V. – Netherlands
• NEMKO Group AS – Norway

Compliance Risks

Electronic products manufactured outside the European Union are not exclusively designed to comply with EU regulations such as the Radio Equipment Directive (RED). On the contrary, many electronics manufacturers outside the EU are not aware of RED and its requirements.

Ensuring compliance with the Radio Equipment Directive requires a hands-on approach that takes the following steps into consideration:

• Confirm relevant EN standards
• Create the Declaration of Conformity
• Create the technical documentation
• Create user instructions
• Book third-party lab testing

It’s rare to find suppliers in outside the EU that can provide pre-existing test reports and other mandatory documents. This doesn’t necessarily mean that a supplier lacks the capability to manufacture products according to the requirements outlined in the Radio Equipment Directive.

What it does mean, however, is that you can never take for granted that a certain product is compliant – and even if so is the case, you still need to create label files and documentation.

FAQ

How does the RED relate to the Low Voltage Directive?

The Low Voltage Directive does not apply to products that fall under the scope of the Radio Equipment Directive. However, the Radio Equipment Directive refers to the essential requirements of the Low Voltage Directive.

Specifically, Article 3 of the RED states that radio equipment should be manufactured to ensure the safety of humans, animals, and property, and include the requirements set out by the Low Voltage Directive.

There is an important difference though. While the Low Voltage Directive only applies to products that have an input or output voltage of 50 to 1000 V for AC and 75 to 1500 V for DC, no voltage limits apply to products that fall under the scope of the Radio Equipment Directive.

As, according to our research, standards that are harmonised under the Low Voltage Directive are not harmonised under the Radio Equipment Directive, our understanding is that in in order to comply with the requirements set by the Low Voltage Directive, you should refers to standards that are harmonised under this directive.

How does the RED relate to the EMC Directive?

The EMC Directive does not apply to radio equipment that is covered by the Radio Equipment Directive. However, the Radio Equipment Directive refers to the essential requirements of the EMC Directive.

In particular, Article 3 of the RED states that radio equipment should be manufactured with the objective of ensuring an adequate level of electromagnetic compatibility, as set in the EMC Directive.

As for the Low Voltage Directive, we couldn’t find any evidence that standards that are harmonised under the EMC Directive are also harmonised under the Radio Equipment Directive (except for EN 55035, which seems to be harmonised under both directives).

Thus, we understand that if you want to comply with the levels of of electromagnetic compatibility set by the EMC Directive, you should comply with standards that are harmonised under this directive (except for EN 55035, as said).

What is the difference between the Radio Equipment Directive and R&TTE?

The Radio and Telecommunications Terminal Equipment Directive (R&TTE) is a former EU directive that covers safety and electromagnetic compatibility aspects of radio equipment. In 2016, the Radio Equipment Directive came into force, replacing the R&TTE Directive. Even though both directives broadly cover the same aspects, there are some major differences between the two:

1. Radio equipment covered by the Radio Equipment Directive is not subjected to the Low Voltage Directive and EMC Directive.

The reason is that the Radio Equipment Directive covers safety and electromagnetic compatibility aspects, by referring to the essential requirements of the Low Voltage – but with no voltage limit, and EMC Directive, respectively.

2. The Radio Equipment Directive requires an “efficient” use of the radio spectrum.

3. The R&TTE Directive used to cover wired telecommunication terminals, but these products are now under the scope of the Low Voltage and EMC Directives.

4. Custom built evaluation kits are explicitly excluded from the scope of the Radio Equipment Directive.

5. Radio sound and radio TV receive-only equipment falls under the scope of the Radio Equipment Directive, while it was not covered by the R&TTE Directive.

6. Radio equipment operating at frequencies below 9 kHz is covered by the Radio Equipment Directive, while it was not covered by the R&TTE Directive.