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RED: six standards lose citation on 15 November

News · Upcoming deadline

The list of harmonised standards under the RED directive, carried by Implementing Decision (EU) 2022/2191, has not been amended since 9 December 2025. The deadlines now approaching therefore all come from the three decisions adopted during 2025, and the first falls on 15 November 2026: six references stop conferring presumption of conformity that day.

In short:

  • Six standards leave the citation on 15 November 2026, under Decision (EU) 2025/893.
  • Two further withdrawal waves are already scheduled, on 14 February 2027 and 11 June 2027.
  • No RED decision has been published during 2026 to date.
  • A withdrawal does not make a product non-compliant: it removes the presumption, not the ability to demonstrate compliance another way.

The three decisions carrying the deadlines

Section titled “The three decisions carrying the deadlines”
DecisionDateContentWithdrawals
(EU) 2025/89315 May 202514 standards cited for the first time, 6 successors, 9 citations carrying restrictions6 standards on 15 November 2026, 1 on 15 May 2028
(EU) 2025/174113 August 2025EN 301 489-28 V2.1.1 cited with restrictions, 6 successors6 standards on 14 February 2027
(EU) 2025/24999 December 2025EN 303 659 and EN 305 550-6 cited, 3 successors3 standards on 11 June 2027

The pattern is always the same: a standard is replaced by its successor, and the older version keeps its value through a transition period, usually eighteen months. It is the end of that period that arrives in November.

The most common misreading treats a withdrawal as a ban. It is not. On 15 November 2026:

  • A product already placed on the market stays compliant and distributable, with no new test campaign.
  • An EU Declaration of Conformity citing a withdrawn standard does, however, stop benefiting from the presumption for units placed on the market after that date.
  • The manufacturer keeps the right to demonstrate compliance with the essential requirements by other means, but the burden of proof falls entirely on them, and in practice that route involves a notified body.

The exposure therefore sits with products still in development whose test campaign was run early, against the version due to be withdrawn.

  1. Re-read the EU Declaration of Conformity for each active reference and list the ETSI standards cited, with their full version number of the form V2.2.3.
  2. Compare those versions against the annexes to Decision (EU) 2025/893, then against 2025/1741 and 2025/2499 for the later deadlines.
  3. For each affected reference, work out whether the successor requires additional testing or only a documentation update. In most cases an ETSI revision leaves the limits unchanged but alters test conditions or uncertainties.
  4. Schedule campaigns ahead of the deadline rather than after it: laboratory availability tightens as cessation dates approach.

Sources & references

  1. Implementing Decision (EU) 2025/893 of 14 May 2025 , EUR-Lex eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ%3AL_202500893
  2. Implementing Decision (EU) 2025/2499 of 9 December 2025 , EUR-Lex eur-lex.europa.eu/eli/dec_impl/2025/2499/oj/eng
  3. Implementing Decision (EU) 2022/2191, the RED base act , EUR-Lex eur-lex.europa.eu/eli/dec_impl/2022/2191/oj/eng
  4. Radio equipment, harmonised standards , European Commission single-market-economy.ec.europa.eu/single-market/goods/european-standards/harmonised-standards/radio-equipment_en