Certification test plan: template and checklist

Hugues Orgitello updated 7 Oct 2026 19 min read

A certification test plan is the internal document that turns a target (CE under the RED, FCC, ISED, UKCA, PTCRB) into a campaign a laboratory can run and an inspector can retrace. No regulation prescribes its format, but several texts dictate what it must pin down: the cited edition of each harmonised standard, the firmware versions that affect compliance (RED Annex V), the operating mode, configuration and performance criteria that go into the EMC report (EN 61000-6-1 and EN 61000-6-2, clauses 4 and 5), the measurement procedure and the test lab status for FCC data (47 CFR 15.31 and 2.948). This template is built from those texts, as they stand on 7 October 2026. It gives no durations, unit counts or costs: none of the texts sets them, and they belong in the lab quote.

TL;DR:

• Write down the edition, not the standard number. Under the EMC Directive the cited generic editions are still EN 61000-6-1:2007 and EN 61000-6-2:2005; under the LVD, EN 62368-1:2014 + AC:2015; under the RED, EN 300 328 V2.2.2 and the EN 301 489 specific parts (EN 301 489-1 itself is not in the list).
• The generic EMC standards say immunity tests "may be performed in any order". The sequence in your plan is a project choice (destructive tests last, shared units, lab availability), not a regulatory one.
• Criterion C covers a loss of function that is self-recoverable or restored by the controls. Criterion B allows degradation during the test but no change of operating state or stored data.
• FCC certification data must come from a lab that is accredited (ISO/IEC 17025) and recognised by the FCC (2.948(a)). The RED sets no such requirement under module A, and under module B the notified body examines the documentation "without examination of a specimen".
• Several RED references change during typical campaigns: EN 301 489-52 V1.2.1 and EN 301 908-13 V13.2.1 lose presumption on 15 November 2026, EN 301 893 V2.1.1 on 15 May 2028.

What the texts require the plan to fix

The table maps each block of the template to the provision that makes it necessary. A field with no source is a good practice, not an obligation, and the plan should say so.

Plan field	Source	What the text says
Firmware versions	RED Annex V, point (a)(ii)	The technical documentation contains "versions of software or firmware affecting compliance with essential requirements"
Standards and parts applied	RED Annex V, point (d)	List of harmonised standards "applied in full or in part"; for partly applied standards, "the parts which have been applied"
Functional description and performance criteria	EN 61000-6-1 and EN 61000-6-2, clause 4	Provided by the manufacturer and noted in the test report
Operating mode	Same standards, clause 5	The EUT is tested in "the expected most susceptible operating mode", which may be identified by limited pre-tests
Configuration	Same standards, clause 5	The configuration "shall be varied to achieve maximum susceptibility consistent with typical applications"; configuration and mode are "precisely noted in the test report"
Tests not run	Same standards, clause 7	Where a test is judged unnecessary, "the decision and justification not to test shall be recorded in the test report"
Accessories	47 CFR 15.31(i) and (j)	A device with accessory connections is tested with accessories attached, configured to maximise emissions; accessories made by the applicant are used
EUT adjustment	47 CFR 15.31(g)	Positioned and adjusted with user-accessible controls to maximise emissions
Supply voltage	47 CFR 15.31(e)	Intentional radiators: fundamental measured with supply varied between 85 % and 115 % of nominal; battery equipment tested with a new battery
Channels	47 CFR 15.31(m)	Per band: 1 frequency if the range is 1 MHz or less, 2 if 1 to 10 MHz, 3 (top, middle, bottom) if more than 10 MHz
Measurement procedure	47 CFR 15.31(a) and (b)	ANSI C63.10-2020 for intentional radiators, ANSI C63.4-2014 (with listed exclusions) for unintentional radiators; procedure and equipment list go into the application or the SDoC records
Test lab	47 CFR 2.948(a) and (f)	Certification testing in a lab accredited under ISO/IEC 17025 and recognised by the FCC; a lab outside the US through a government-to-government MRA or an accreditation body recognised under 2.949
Retention	RED Article 10(4)	Technical documentation and EU declaration kept for 10 years after placing on the market

Project test plan versus per-campaign test schedule

The two documents serve different purposes and change at different rates.

Aspect	Project test plan	Campaign test schedule
Scope	Every market, standard and configuration, full lifecycle	A subset of tests at one laboratory
Cadence	Issued once, revised on design or standards changes	Re-issued per booked campaign
Owner	Project and compliance leads	Engineer who manages the lab interface
Content	Variants, cited editions, sample register, sequence, criteria, risks, change control	Dates, units shipped, witnesses, lab contact, expected report date
Lifetime	As long as the product is on the market (and the retention period after)	One campaign

One project plan feeds several schedules: EMC, radio, RF exposure, safety, and for cellular products the PTCRB and carrier campaigns. Merged into one document, either the schedule is never updated or every booking rewrites the plan.

Product configuration: variants, options, worst case

The plan fixes what is tested. Variants multiply the matrix, so the team declares which configuration is tested for which family and why. Two texts frame this:

• EMC immunity. EN 61000-6-1 and EN 61000-6-2 (clause 5) require the most susceptible operating mode and a configuration varied to maximise susceptibility within typical use. Where the apparatus connects to auxiliary equipment, it is tested with the "minimum representative configuration" needed to exercise the ports. Where the manual requires external protection devices, the tests are run with them in place.
• FCC emissions. 47 CFR 15.31 requires the EUT to be adjusted to maximise emissions (g), tested with accessories attached (i), and with the accessories the applicant makes (j). For intentional radiators, measurements are made at the number of frequencies set by 15.31(m) in each band.

Three families of decisions to record:

• Hardware variants: antennas, power options, enclosures. The plan states which variant is tested for which family and the rationale (for radio, the antenna with the highest gain the grant or declaration will cover; for conducted emissions, each supply option that changes the mains interface).
• Firmware: the build loaded for each test, with version and checksum. Test firmware (continuous transmission, fixed channel) is common for radio measurements; the plan records how its RF settings match the shipped firmware, because RED Annex V asks for the firmware versions affecting compliance.
• Accessories and cables: the kit supplied with the product, cable types and lengths. Cable length decides whether some immunity tests apply at all: in EN 61000-6-1 and 6-2 the burst test on signal ports applies only to cables that may exceed 3 m, and in EN 61000-6-2 the surge test on signal ports only to cables that may exceed 30 m.

Standards selection table by market

The heart of the plan. Each row gives the reference as cited, not the standard number alone. Editions below are those cited or published on 7 October 2026.

Market	Legal basis	Scope	Reference in force
EU	RED Article 3(2)	2.4 GHz wideband	EN 300 328 V2.2.2
EU	RED Article 3(2)	5 GHz RLAN	EN 301 893 V2.2.1 (V2.1.1 until 15 May 2028)
EU	RED Article 3(1)(b)	EMC of radio equipment	EN 301 489-17 V3.3.1 (Wi-Fi, Bluetooth), EN 301 489-52 V1.3.1 (cellular), with restrictions; EN 301 489-1 is not cited
EU	RED Article 3(1)(a)	RF exposure	EN 50360:2017 + A1:2023 (at the ear), EN 50566:2017 + A1:2023 + A2:2025 (hand-held, body-mounted)
EU	RED Article 3(3)(d), (e), (f), applicable since 1 August 2025	Cybersecurity	EN 18031-1:2024 (and -2, -3 where relevant), cited with restrictions by Decision (EU) 2025/138
EU	EMC Directive 2014/30/EU	Generic EMC	EN 61000-6-1:2007, EN 61000-6-2:2005, EN 61000-6-3:2007 + A1:2011 + AC:2012; multimedia: EN 55032:2015 + A11:2020, EN 55035:2017 + A11:2020
EU	LVD 2014/35/EU	Safety of AV, IT and communication equipment	EN 62368-1:2014 + AC:2015 (EN IEC 62368-1:2020 and :2024 are not cited under the LVD)
US	FCC ID, certification	Part 15 intentional radiators	47 CFR 15.247 (DTS, FHSS), 15.407 (U-NII), measured to ANSI C63.10-2020
US	SDoC or certification	Part 15 digital devices	47 CFR 15.107 (conducted), 15.109 (radiated), measured to ANSI C63.4-2014
US	FCC rules	RF exposure	47 CFR 1.1310 limits, 2.1093 evaluation for portable devices
US	Industry scheme (CTIA Certification)	Cellular	PTCRB: PPMD and NAPRD03, 3GPP TS 36.521/36.523 (LTE), TS 38.521/38.523 (NR)
Canada	ISED certification	Radio	RSS-Gen issue 6, RSS-247 issue 4, RSS-102 issue 6
Great Britain	UKCA or CE (both accepted for radio equipment)	Radio	UK designated standards or EU harmonised standards, with their dates

The RED does not list EN 62368-1: an electrical safety demonstration for radio equipment uses it under the LVD safety objectives that Article 3(1)(a) imports. A row that names "EN 301 489-1" or "EN 61000-6-1:2019" points at a reference that gives no presumption of conformity today. See harmonised standards and presumption of conformity for how citations work.

The plan should name who checks this table and how often: the Commission summary lists are only informative, and the legal text is the implementing decision in the Official Journal. See certification timeline for the phases.

References that change during a campaign

A plan written in 2026 meets these dates. Each is set by the cited act, not by the standards body.

Date	Act	What changes
1 August 2025	Delegated Regulation (EU) 2022/30, Decision (EU) 2025/138	RED Article 3(3)(d), (e), (f) apply; EN 18031-1/-2/-3:2024 cited with restrictions
15 May 2025	Decision (EU) 2025/893	EN 301 489-17 V3.3.1, EN 301 489-52 V1.3.1 and EN 301 893 V2.2.1 cited
11 September 2026	Regulation (EU) 2024/2847 (CRA)	Reporting obligations for actively exploited vulnerabilities apply
15 November 2026	Decision (EU) 2025/893	EN 301 489-52 V1.2.1 and EN 301 908-13 V13.2.1 lose presumption
11 December 2027	Regulation (EU) 2024/2847 (CRA)	Full application of the CRA
7 March 2028	Decision (EU) 2026/2003	EN 50566:2017 + A1:2023 without A2 leaves the RED list
15 May 2028	Decision (EU) 2025/893	EN 301 893 V2.1.1 loses presumption

A withdrawal does not make products already placed on the market non-compliant, but RED Article 10(5) requires changes in the harmonised standards to be "adequately taken into account" for series production. The plan should list each reference with its withdrawal date where one is set.

Sample plan: golden samples, pilot run, production-representative

No EU or FCC rule sets a number of units for EMC, radio or safety testing. The plan defines unit types and how each is identified:

• Golden samples: engineering units with serial number, photographs, hardware revision and firmware checksum. Used for pre-compliance and early formal slots.
• Pilot run units: built on production tooling. They show whether assembly, soldering and shielding change the results.
• Production-representative units: production firmware and process. Used for the final formal slots and kept as reference units.

For each unit the plan records serial number, hardware revision, firmware version, accessory kit, photographs of markings, and which tests it went through. The count follows from the plan: destructive tests, parallel campaigns at different labs, configurations that must be tested separately, and the spares the team decides to hold.

Two points from the texts. Under the RED, EU-type examination (module B, Annex III) is carried out "without examination of a specimen (design type)": the notified body assesses the technical documentation and supporting evidence, so the test reports and the configuration they describe carry the file. Under FCC rules, the Commission may ask for a sample or test data after authorization (2.945), so the plan should say which reference units are kept.

Test sequence and dependencies

EN 61000-6-1 and EN 61000-6-2 (clause 8) state that the immunity tests "shall be carried out individually as single tests in sequence. The tests may be performed in any order." The order in the plan is a project decision driven by practical constraints:

• Destructive tests last on a given unit. Safety tests under EN 62368-1 include single fault conditions and abnormal operating conditions that can damage the unit; plan them on units that are not needed afterwards.
• Shared units. Units that travel between labs cannot be in two places; the schedule follows the units.
• Pre-compliance before formal slots. Radiated and conducted emission scans in-house or at a pre-compliance facility. See conducted emissions LISN test.
• Configuration freeze. Formal radio and EMC tests on the same hardware and firmware the declaration or grant will cover.

A reference list of test families, in no mandatory order:

1. EMC emissions: radiated and conducted, to the generic or product standard (EN 55032 for multimedia equipment, EN 61000-6-3 otherwise) and, for the US, 15.107 and 15.109.
2. EMC immunity: ESD, radiated RF, conducted RF, burst, surge, dips and interruptions, power-frequency magnetic field where relevant. See ESD IEC 61000-4-2, radiated RF immunity, conducted RF immunity.
3. Radio: the parameters of the cited radio standard (EN 300 328, EN 301 893) and of 15.247 or 15.407, including DFS where the band requires it.
4. RF exposure: SAR or an exposure assessment, on the configuration closest to the body.
5. Safety: EN 62368-1 or the relevant product standard, including fault tests.
6. Functional safety where applicable: see IEC 61508 functional safety.
7. Laboratory and measurement equipment where applicable: see IEC 61010 lab measurement safety.
8. Cellular acceptance: PTCRB at a PTCRB-validated lab, then any carrier programme (for example AT&T NAF).

The plan states which step uses which unit, the slot, the witness mode and the expected report date, and lists the dependencies explicitly.

Laboratory selection: scope, recognition, witness mode

Criterion	What to verify	Where it comes from
ISO/IEC 17025 scope	The exact standards and editions in the scope annex, not a generic claim	Accreditation body register; ISO/IEC 17025:2017
FCC recognition	Certification testing needs a lab accredited and recognised by the FCC (2.948(a)); a lab outside the US qualifies through an MRA designation or an accreditation body recognised under 2.949 (2.948(f)); accreditation reassessed at least every two years (2.948(e))	47 CFR 2.948
SDoC testing	No accreditation requirement under 2.906; the lab still compiles the description of its measurement facilities (2.948(b))	47 CFR 2.906, 2.948(b)
ISED	ISED recognises labs and certification bodies designated by the US authority under the Canada-US MRA	ISED
EU module A	The RED, EMC Directive and LVD set no accreditation requirement on the manufacturer test lab	Directive texts
EU module B	Supporting evidence may include tests "by the appropriate laboratory of the manufacturer, or by another testing laboratory on his behalf and under his responsibility"	RED Annex III, point 3(d)
Witness or full service	Whether the team operates the EUT during tests or hands it over	Lab quote and the plan

Accreditation is still useful in the EU: market surveillance or a notified body can challenge non-accredited data more easily. See conformity assessment bodies and accreditation.

Acceptance criteria: performance criteria A, B, C

The generic standards cited under the EMC Directive, EN 61000-6-1:2007 and EN 61000-6-2:2005 (identical to IEC 61000-6-1:2005 and IEC 61000-6-2:2005), define the criteria in clause 4:

Criterion	Text
A	Operates as intended during and after the test; no degradation of performance or loss of function below a performance level specified by the manufacturer
B	Operates as intended after the test; degradation of performance is allowed during the test, but "no change of actual operating state or stored data is allowed"
C	"Temporary loss of function is allowed, provided the function is self-recoverable or can be restored by the operation of the controls"

If the manufacturer does not specify the performance level, it "may be derived from the product description and documentation and what the user may reasonably expect". An apparatus that becomes dangerous or unsafe during the tests fails.

The criterion is set per phenomenon by the standard, not chosen by the plan:

Phenomenon	Basic standard	EN 61000-6-1:2007 level	EN 61000-6-2:2005 level	Criterion
Power-frequency magnetic field (only apparatus with susceptible devices)	IEC 61000-4-8	3 A/m	30 A/m	A
Radiated RF, 80 to 1 000 MHz	IEC 61000-4-3	3 V/m	10 V/m (3 V/m in some broadcast bands)	A
Radiated RF, 1.4 to 2.0 GHz / 2.0 to 2.7 GHz	IEC 61000-4-3	3 V/m / 1 V/m	3 V/m / 1 V/m	A
ESD	IEC 61000-4-2	4 kV contact, 8 kV air	4 kV contact, 8 kV air	B
Conducted RF, 0.15 to 80 MHz	IEC 61000-4-6	3 V	10 V	A
Burst, AC power	IEC 61000-4-4	1 kV	2 kV	B
Surge, AC power	IEC 61000-4-5	2 kV line-to-earth, 1 kV line-to-line	2 kV line-to-earth, 1 kV line-to-line	B
Dips, AC power	IEC 61000-4-11	0 % for 0.5 and 1 cycle (B), 70 % for 25/30 cycles (C)	0 % for 1 cycle (B), 40 % for 10/12 cycles (C), 70 % for 25/30 cycles (C)	B or C
Interruptions, AC power	IEC 61000-4-11	0 % for 250/300 cycles	0 % for 250/300 cycles	C

Industrial does not mean stricter criteria: the letters are largely the same, the levels are higher. The plan declares, per test, the functions observed and the means of observation (visual, log, automated check). For the detail by phenomenon see surge and burst and dips and interruptions.

Radio equipment under RED Article 3(1)(b) uses the EN 301 489 specific parts instead. Their citations carry restrictions: for EN 301 489-17 V3.3.1, Decision (EU) 2025/893 states that it does not address emissions below 9 kHz, and that it "does not confer a presumption of conformity" for Article 3(1)(b) "if its clause 6 is applied"; recital 7 explains that these parts "lay down performance-based criteria on a subjective basis". The plan records how the restricted part is handled.

For radio, acceptance is against the limits of the cited standard or the rule section. For safety, the standard defines the pass condition of each test.

See also

• Copy-paste certification templates: DoC, file, tests
• Choosing a Notified Body: NANDO and scope verification
• NB surveillance audits: cadence and conduct
• Conformity assessment modules A-H (768/2008/EC)
• EU Authorised Representative and Importer
• FCC ID, grantee and TCB
• RED harmonised standards list

Working on drafting a complete certification test plan for a CE, FCC, RED or PTCRB campaign for a real product? AESTECHNO can audit your design and certification plan. Get in touch

Risk register and pre-compliance

The plan carries a risk register: known threats to the campaign, the mitigation and how each is screened. Typical entries:

• Emissions from cables (USB, supply): common-mode filtering and cable choice, screened in pre-compliance scans.
• Radiated RF immunity on high-impedance inputs: filtering and ground review, screened with a near-field probe or a pre-compliance setup.
• RF exposure margin: antenna placement or output power, screened by simulation or a pre-scan.
• DFS behaviour at 5 GHz: firmware, screened with a radar signal generator where available.
• Change of a cited reference mid-campaign: tracked with the dates table above.

Pre-compliance screens these risks before formal slots. The plan says which tests are screened, the gating result and who decides go or no-go. See pre-compliance with TEM cells and near-field probes and certification costs.

Change control: what triggers retest

A conformity demonstration is tied to a configuration. The plan defines which changes reopen it.

Change	What the texts say	Typical action
Any design or characteristic change (EU)	RED Article 10(5): changes in design or characteristics "shall be adequately taken into account"	Impact assessment recorded in the file; retest of the affected families. See component substitution rules
Frequency determining circuitry, clock or data rates, modulator, maximum power (FCC)	2.1043(a): a new grant is needed, except Class III for software defined radios	New application
Change that does not degrade reported characteristics (FCC)	2.1043(b)(1), Class I: no filing; 2.938 requires records of changes that may affect compliance	Evidence kept in records
Change that degrades reported characteristics, still within the rules (FCC)	2.1043(b)(2), Class II: filing with test results for the affected characteristics, by the grantee only	See FCC Class II permissive change and KDB 178919
Software change not affecting RF emissions (FCC)	2.1043(a): no filing	Record the version
Antenna change	KDB 178919 treats antenna changes case by case; RF exposure may need its own evaluation	Radio and RF exposure review
Safety-critical component change	The standard applied defines critical components	Targeted safety retest; IEC 61508 or ISO 26262 impact analysis where those apply
Cited reference withdrawn or replaced (EU)	RED Article 10(5): changes in harmonised standards taken into account	Gap analysis against the new edition

The plan names who logs the change, who assesses the impact and who triggers the retest, usually through the engineering change order system.

Deliverables and traceability

The plan ends with what it produces, in the form required where a form is required.

• Test reports, one per campaign, stating the edition tested, the unit serial numbers, the configuration and mode, the performance criteria and the results.
• EU declaration of conformity: RED Annex VI lists its content, including the references of the harmonised standards used.
• FCC: for certification, the application exhibits of 2.1033(b) (instructions, circuit description, block diagram, measurement report identifying the test procedure, photographs, accessory description); for SDoC, the compliance information of 2.1077 supplied with the product. There is no FCC "declaration of conformity" document under SDoC.
• Technical documentation (EU): the RED Annex V elements, kept for 10 years after placing on the market (Article 10(4)).
• Traceability matrix: each result tied to a standard clause, a unit serial number, a date and a report number.

The traceability matrix lets a market surveillance authority, a notified body or a TCB go from a declaration or a grant to the underlying result. When a cited edition changes, it shows which results need a gap analysis.

One-page test-plan skeleton

A starting point to copy into the project repository.

Project: <name>
Product: <reference>, hardware rev <X.Y>, firmware <Z.W> (checksum)
Variants: <list with worst-case rationale per test family>
Accessories in kit: <list, cable types and lengths>

Regulatory scope:
  - EU: RED (3.1a, 3.1b, 3.2, 3.3 d/e/f), EMC Directive, LVD, RoHS
  - US: FCC certification (FCC ID) and/or SDoC
  - Canada: ISED certification
  - Great Britain: UKCA or CE
  - PTCRB and carrier programmes (cellular)

Standards table:
  - <market>, <legal basis>, <reference as cited>, <restriction>, <withdrawal date>

Sample register:
  - Golden: S/N <list>, HW rev, FW ver
  - Pilot: S/N <list>
  - Production-representative: S/N <list>
  - Reference units kept: S/N <list>

Test families and order (project choice):
  - Pre-compliance scans (in-house)
  - EMC emissions (lab A)
  - EMC immunity (lab A)
  - Radio (lab B, FCC-recognised)
  - RF exposure (lab B)
  - Safety, destructive tests last (lab C)
  - PTCRB (PTCRB-validated lab D)

Per test: unit S/N, configuration, operating mode,
  functions observed, criterion from the standard,
  justification for any test not run

Risk register:
  - <risk>, <mitigation>, <screened how>

Change control:
  - Triggers: design change, firmware affecting RF, antenna,
    critical component, cited reference withdrawn
  - Workflow: ECO log, compliance impact assessment, retest decision

Deliverables:
  - Test reports per campaign
  - EU declaration of conformity, FCC exhibits or SDoC information
  - Technical documentation
  - Traceability matrix

Approval:
  - Names, roles, date and version

The detail goes into linked annexes: standards table, sample register, lab quotes, change log.

Claims the texts contradict

Common claim (including on earlier versions of this page)	What the text says
The test sequence is fixed; radio tests come after EMC because continuous transmission can damage EMC loads	EN 61000-6-1 and 6-2, clause 8: tests are single tests in sequence and "may be performed in any order". The order is a project choice
Criterion B means temporary degradation with self-recovery; C means operator action is needed	Criterion C covers a loss of function that is "self-recoverable or can be restored by the operation of the controls". Criterion B forbids any "change of actual operating state or stored data"
Industrial products face tighter criteria (A or B where residential tolerates B or C)	EN 61000-6-2 keeps largely the same letters as EN 61000-6-1 and raises the levels (for example 10 V/m instead of 3 V/m, 2 kV burst instead of 1 kV)
EN 301 489-1 is the RED EMC standard to cite	EN 301 489-1 is not in the RED list; presumption comes from the specific parts (-17, -52 and others), cited with restrictions
The generic EMC standards in force are the 2019 and 2021 editions	The EMC Directive list cites EN 61000-6-1:2007, EN 61000-6-2:2005 and EN 61000-6-3:2007 + A1:2011
A CE campaign must be run in an ISO/IEC 17025 accredited lab	The RED, EMC Directive and LVD set no such requirement for module A. Under RED module B, tests may come from "the appropriate laboratory of the manufacturer". FCC certification does require an accredited, FCC-recognised lab (2.948(a)); SDoC does not
The notified body is informed of the test plan and reviews it	No text says so. Under RED module B the notified body examines the technical documentation and supporting evidence, "without examination of a specimen"
A firmware change that alters output power is a Class II permissive change	2.1043(a): a change to maximum power ratings needs a new grant (Class III only for software defined radios). Class II covers degradation that still meets the rules
UK standards are "designated by OPSS"	Designation is made by the Secretary of State through notices on GOV.UK; the UK declaration may reference UK designated standards or EU harmonised standards
A typical cellular IoT campaign needs eight to twelve units	No regulation sets a unit count; it follows from the plan and the lab requirements

Cross-cutting references

• CE procedure: EU regulatory framework and the directives the plan addresses
• FCC procedure: US regulatory framework and the rule parts
• RED procedure: radio-specific EU framework, Article 3(1), 3(2) and 3(3)
• Certification timeline: phases of a certification project
• Certification costs: structure of lab, notified body and agent fees
• Component substitution rules: retest triggers after a BOM change
• IEC 61010 laboratory measurement safety: test plan considerations for laboratory equipment
• Glossary: definitions of golden sample, witness testing, TCB, MRA, performance criterion

Frequent pitfalls

Pitfall	Consequence
Plan issued after the first lab slot is booked	Scope rewritten under deadline pressure, missed references
Standard number without edition in the table	Campaign run against an edition that gives no presumption, discovered at report stage
Project plan and campaign schedule merged	Document too large to maintain, versions drift
Unit count not derived from the plan	Campaign paused to build more units
Accessories treated as out of scope	15.31(i) requires them attached; a cable failure widens the scope late
No worst-case rationale for variants	The notified body or TCB challenges the choice
No justification for tests not run	EN 61000-6-1 and 6-2 clause 7 require it in the test report
No change-control linkage	A BOM substitution or a standard withdrawal is never assessed
No traceability matrix	The file cannot show which unit and edition support each result

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Sources & references

1. Directive 2014/53/EU (RED), Articles 10, 17, Annex III (module B) and Annex V (technical documentation), EUR-Lex eur-lex.europa.eu/eli/dir/2014/53/oj
2. Implementing Decision (EU) 2022/2191, RED harmonised standards list, EUR-Lex eur-lex.europa.eu/eli/dec_impl/2022/2191/oj
3. Implementing Decision (EU) 2025/893, EN 301 489 parts, EN 301 893 V2.2.1, deferred withdrawals, EUR-Lex eur-lex.europa.eu/eli/dec_impl/2025/893/oj
4. Implementing Decision (EU) 2025/138, EN 18031-1, -2 and -3 cited with restrictions, EUR-Lex eur-lex.europa.eu/eli/dec_impl/2025/138/oj
5. Implementing Decision (EU) 2019/1326 on EMC harmonised standards, consolidated text of 10 June 2022, EUR-Lex eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02019D1326-20220610
6. Commission communication 2018/C 246/01, EMC Directive references (EN 61000-6-1:2007, EN 61000-6-2:2005), EUR-Lex eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52018XC0713(02)
7. Implementing Decision (EU) 2023/2723 on LVD harmonised standards, consolidated version of 30 April 2026, EUR-Lex eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023D2723-20260430
8. IS 14700 (Part 6/Sec 1):2008, identical adoption of IEC 61000-6-1:2005 (secondary copy of the IEC text), Bureau of Indian Standards, via Public.Resource.Org law.resource.org/pub/in/bis/S04/is.14700.6.1.2008.pdf
9. IS 14700 (Part 6/Sec 2):2008, identical adoption of IEC 61000-6-2:2005 (secondary copy of the IEC text), Bureau of Indian Standards, via Public.Resource.Org law.resource.org/pub/in/bis/S04/is.14700.6.2.2008.pdf
10. ETSI EN 300 328 V2.2.2 (2019-07), ETSI www.etsi.org/deliver/etsi_en/300300_300399/300328/02.02.02_60/en_300328v020202p.pdf
11. 47 CFR 15.31, measurement standards, eCFR www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-15/subpart-A/section-15.31
12. 47 CFR 2.948, measurement facilities, eCFR www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-2/subpart-J/section-2.948
13. 47 CFR 2.1033, application for certification, eCFR www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-2/subpart-J/section-2.1033
14. 47 CFR 2.1043, changes in certificated equipment, eCFR www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-2/section-2.1043
15. 47 CFR Part 2 Subpart J, equipment authorization procedures (2.906, 2.911, 2.938, 2.1077), eCFR www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-2/subpart-J
16. FCC KDB 178919, Section 2.1043 permissive changes (D01 Permissive Change Policy v06), FCC apps.fcc.gov/oetcf/kdb/forms/FTSSearchResultPage.cfm?id=33013&switch=P
17. RSS-Gen, issue 6: General Requirements for Compliance of Radio Apparatus, ISED Canada ised-isde.canada.ca/site/spectrum-management-telecommunications/en/devices-and-equipment/radio-equipment-standards/radio-standards-specifications-rss/rss-gen-general-requirements-compliance-radio-apparatus
18. Designated standards (Great Britain), gov.uk www.gov.uk/guidance/designated-standards
19. ISO/IEC 17025:2017, General requirements for the competence of testing and calibration laboratories, ISO www.iso.org/standard/66912.html
20. PTCRB, get certified (PPMD and NAPRD03), PTCRB www.ptcrb.com/get-certified/