What certifications does a LoRaWAN sensor need?
A LoRaWAN sensor is a small radio product, and a small radio product touches a surprising number of regimes at once. Before a battery-powered temperature, level or asset-tracking sensor can ship, it needs a radio approval in each target market, usually a LoRaWAN Certification, a lithium cell that is cleared for transport, a battery that meets the EU Battery Regulation, cyber security obligations under the RED and the Cyber Resilience Act, and a layer of substance and waste compliance. This page reads each obligation from its text as it stands on October 7, 2026: which clause applies to a sensor, which dates have already passed, how the LoRaWAN channel plans map onto the regional band rules, and the claims about this product type that the texts contradict.
TL;DR:
- Radio is the legal gate. EU: RED, with EN 300 220 part 2 V3.3.1 cited since December 11, 2025. US: 47 CFR 15.247 (or 15.249) and a TCB grant. Canada: RSS-247 issue 4.
- LoRaWAN Certification is voluntary. LoRa Alliance members only, against TS001-1.0.4 and RP002; certificates are valid five years for devices certified after June 3, 2024.
- The cell, not the sensor, is UN 38.3 tested. Button cells installed in equipment are exempt from the test summary duty in the 2026 IATA guidance.
- Battery Regulation. Removability by the end user applies from February 18, 2027; labelling from August 18, 2026 or 18 months after the implementing act, whichever is later.
- Cyber. RED Article 3(3)(d) since August 1, 2025 for internet-connected radio equipment; CRA reporting since September 11, 2026, full application December 11, 2027.
How the obligations fit together
Section titled “How the obligations fit together”Three families of requirement run in parallel, with different owners. A gap in any one of them can block a market or a shipment.
| Family | What it covers | Who sets it | Legally required? |
|---|---|---|---|
| Radio and market access | Spectrum, EMC, safety, RF exposure, network protection | EU (RED), FCC, ISED, national regulators | Yes |
| Interoperability | LoRaWAN MAC behaviour and the LoRaWAN Certified claim | LoRa Alliance (private) | No |
| Product compliance | Battery, cyber (CRA), substances, waste, transport | EU law, dangerous goods rules | Yes, for each item in scope |
For the sequencing of a first programme, see certification getting started and the certification timeline. A worked campaign for a comparable product is in IoT sensor: RED and FCC worked example.
Radio approval in the European Union
Section titled “Radio approval in the European Union”A LoRaWAN sensor is radio equipment under 2014/53/EU, the Radio Equipment Directive (RED pillar). The essential requirements and the harmonised standards that give a presumption of conformity for a sub-GHz sensor are:
| RED requirement | What it covers | Harmonised standard (October 2026) | Citing decision |
|---|---|---|---|
| Article 3(2) | Efficient use of spectrum | EN 300 220-2 V3.3.1 (V3.1.1 withdrawn from June 11, 2027) | (EU) 2025/2499 |
| Article 3(2), 915 MHz data networks | SRD in data networks at 865 to 868 and 915 to 919.4 MHz | EN 303 659 V1.1.1 | (EU) 2025/2499 |
| Article 3(1)(b) | EMC | EN 301 489-3 V2.3.2 (short range devices) | (EU) 2025/893 |
| Article 3(1)(a) | Health and safety, with no voltage limit | No safety standard in the RED list; EN 62368-1:2014 + AC:2015 is cited under the LVD | LVD list |
| Article 3(3)(d) | Network protection, internet-connected equipment | EN 18031-1:2024, with restrictions | (EU) 2025/138 |
Three points the texts make that matter for a sensor:
- Safety applies at battery voltage. Article 3(1)(a) of the RED covers the safety objectives of the Low Voltage Directive "with no voltage limit applying", so a 3 V sensor is in scope.
- "Internet-connected" includes sensors behind a gateway. Delegated Regulation (EU) 2022/30 applies Article 3(3)(d) to radio equipment "that can communicate itself over the internet, whether it communicates directly or via any other equipment". The requirement applies since August 1, 2025. EN 18031-1 gives a presumption only within the restrictions of Decision (EU) 2025/138.
- The route depends on the standards. Article 17(3) allows internal production control for Articles 3(2) and 3(3) only when the cited harmonised standards were applied. Otherwise a notified body is involved (EU-type examination or full quality assurance). Article 17(1) also requires the assessment to cover every configuration of the equipment.
Conformity is declared in an EU declaration of conformity backed by a technical file. The RED checklist and applicable RED standards go article by article. For Great Britain, see UKCA marking and the UKCA vs CE comparison.
EU868 channels against the band rules
Section titled “EU868 channels against the band rules”The LoRaWAN EU868 plan in RP002 has to fit inside the rows of Commission Decision 2006/771/EC (consolidated text of January 23, 2025). The default channels land in two different rows:
| LoRaWAN EU868 (RP002-1.0.3) | Decision 2006/771/EC row | Limit | Access |
|---|---|---|---|
| Join channels 868.10, 868.30, 868.50 MHz | Band 48, 868 to 868.6 MHz | 25 mW e.r.p. | Access techniques, or duty cycle 1 % or less |
| Default RX2 downlink, 869.525 MHz | Band 54, 869.4 to 869.65 MHz | 500 mW e.r.p. | Access techniques, or duty cycle 10 % or less |
| Additional channels in 865 to 868 MHz | Band 47, 865 to 868 MHz | 25 mW e.r.p. | Access techniques, or duty cycle 1 % or less |
RP002 gives +16 dBm EIRP as the EU868 default maximum, which is 25 mW e.r.p. expressed as EIRP (a half-wave dipole has 2.15 dBi of gain). RP002 also notes that LoRaWAN "exclusively uses duty-cycle limited transmissions" in EU868, although the ETSI rules would also allow Listen Before Talk. The annex of Decision 2006/771/EC measures duty cycle over one continuous hour unless the row says otherwise: 1 % is 36 seconds of airtime per hour.
The 915 MHz band is not the US band in Europe. Implementing Decision (EU) 2018/1538, as amended by (EU) 2025/650, opens 916.1 to 919.4 MHz only to SRD in data networks controlled by a network access point, at 25 mW e.r.p. for non-specific SRD, with a Member State opt-out for defence use. The details are in radio spectrum and SRD license-free bands.
Radio approval in the United States and Canada
Section titled “Radio approval in the United States and Canada”United States. An intentional radiator under Part 15 needs a certification issued by a TCB, which produces the FCC ID (FCC pillar, FCC ID, grantee and TCB). A US915 LoRaWAN sensor has two possible rules:
| Route | Rule | Key limits in 902 to 928 MHz |
|---|---|---|
| Frequency hopping | 15.247(a)(1)(i), (b) | At least 50 channels when the 20 dB bandwidth is under 250 kHz, 0.4 s dwell in any 20 s, 1 W peak conducted (0.25 W with 25 to 49 channels) |
| Digital modulation (DTS) | 15.247(a)(2), (b), (e) | 6 dB bandwidth at least 500 kHz, 1 W peak conducted, 8 dBm in any 3 kHz |
| Hybrid | 15.247(f) | Hopping and digital modulation combined |
| Low field strength | 15.249(a) | 50 mV/m at 3 m, any modulation |
The 15.247 power limits assume a directional antenna gain of 6 dBi or less. LoRa at 125 kHz cannot meet the 500 kHz DTS bandwidth alone, which is why RP002 lists FHSS, DTS (the 500 kHz channels) and hybrid modes for US915. A module with a modular grant can be reused within its grant conditions; if its FCC ID is not visible once installed, the host carries a label such as "Contains FCC ID" (47 CFR 15.212).
Canada. ISED certification under RSS-Gen and RSS-247 issue 4, which covers DTS and frequency hopping devices in 902 to 928 MHz, with a listing in the Radio Equipment List before sale. See ISED Canada radio certification and, for running the US and EU files together, EU + US dual certification and CE vs FCC EMC.
Other markets and their channel plans
Section titled “Other markets and their channel plans”RP002 assigns a channel plan to each country, but the national rule still decides. The rows below are those confirmed on sibling pages read from the national texts:
| Market | LoRaWAN plan (RP002-1.0.3) | National basis | Guide |
|---|---|---|---|
| Australia | AU915 (915 to 928 MHz) | Radiocommunications (Low Interference Potential Devices) Class Licence 2025, which replaced the 2015 licence on October 1, 2025; RCM labelling | ACMA RCM |
| Brazil | AU915 (915 to 928 MHz) | ANATEL homologation | ANATEL |
| Japan | AS923-1 (920.6 to 928.0 MHz) | Ordinance Regulating Radio Equipment, Article 49-14 item 7: 16 dBm EIRP, 200 kHz channels, carrier sense required except in two listed cases | Giteki Japan |
| South Korea | KR920 (920.9 to 923.3 MHz) | Radio Waves Act, KC certification | KC mark |
| China | CN470 (470 to 510 MHz) | MIIT type approval or the micro-power exemption, depending on the device | SRRC China |
LoRaWAN Certification
Section titled “LoRaWAN Certification”LoRaWAN Certification is a LoRa Alliance programme open only to members (all four tiers, Institutional included, can certify end devices). It tests the device against the L2 specification TS001-1.0.4, the version the Alliance tags "required for certification", and against RP002 for each channel plan. It is not a radio approval and gives no presumption under the RED or the FCC rules.
| Point | What the Alliance publishes |
|---|---|
| Test path | An Authorized Test Lab, or Self-Test for qualified members |
| Device class | Class A is mandatory for every end device (TS001-1.0.4); Class B and C are optional |
| Fees | One-time licence fee of USD 1,200 for an end device tested at an ATL, USD 1,700 at a self-test lab; extra regions and similar devices are cheaper child certificates |
| Validity | Five years for devices certified after June 3, 2024 |
| Module integration | Certification by Similarity, if the LoRaWAN transceiver and protocol software version are unchanged and the parent certificate is under five years old |
Details, the full fee table and the per-plan parameters are in LoRa Alliance LoRaWAN certification.
Battery: transport, safety and the Battery Regulation
Section titled “Battery: transport, safety and the Battery Regulation”Most LoRaWAN sensors run on a lithium primary cell (lithium metal) for multi-year life; some use a rechargeable lithium-ion cell.
Transport
Section titled “Transport”The 2026 IATA guidance, based on the 67th edition of the IATA Dangerous Goods Regulations, states that "all cells and batteries must be tested in accordance with the UN Manual of Tests and Criteria Part III Subsection 38.3". The test is on the cell and battery type, so in practice the sensor maker obtains the evidence from the cell supplier, and only tests itself when it assembles its own battery pack. For a sensor with its cell installed:
| Situation | UN number | Air packing instruction |
|---|---|---|
| Lithium metal cell installed in the sensor | UN 3091, lithium metal batteries contained in equipment | PI 970 (Section II for cells of 1 g lithium or less, batteries of 2 g or less) |
| Lithium-ion cell installed in the sensor | UN 3481, lithium ion batteries contained in equipment | PI 967 |
| Spare cells shipped in the same box | UN 3091 or UN 3481, packed with equipment | PI 969 or PI 966 |
Manufacturers and distributors must make the UN 38.3 test summary (paragraph 38.3.5 of the Manual, Revision 8) available, "except for button cells installed in equipment (including circuit boards)". Prototypes that have not passed UN 38.3 can only travel by air with a State approval (Special Provision A88). See HAZMAT, IMDG and IATA lithium shipping.
Cell safety
Section titled “Cell safety”IEC 62133-2 covers secondary lithium cells and batteries; it does not cover primary lithium cells, for which the IEC safety standard is IEC 60086-4. These standards support the Article 3(1)(a) assessment but are not cited under the RED. See IEC 62133 and UN 38.3.
EU Battery Regulation
Section titled “EU Battery Regulation”The cell in a sensor is a "portable battery" under 2023/1542: sealed, 5 kg or less, not designed specifically for industrial use. The dates that concern a sensor maker:
| Obligation | Article | Applies from |
|---|---|---|
| General application | Article 96(2) | February 18, 2024 |
| Management of waste batteries: producer register and producer responsibility, including batteries "incorporated in appliances" | Chapter VIII | August 18, 2025 |
| Battery labels (general information; "non-rechargeable" and minimum average duration for primary portable batteries) | Article 13 | August 18, 2026, or 18 months after the implementing act, whichever is later |
| Portable battery readily removable and replaceable by the end user | Article 11 | February 18, 2027 |
Article 11(3) lifts the removability duty only where continuity of power supply is necessary and a permanent connection is required for the safety of the user and the appliance or, "for products that collect and supply data as their main function, for data integrity reasons". A sealed sensor needs a documented reason that fits those words; the battery being small or soldered is not one. See EU Battery Regulation.
Cyber security
Section titled “Cyber security”Two texts now apply in sequence:
| Text | What applies | Date |
|---|---|---|
| RED Article 3(3)(d), (e), (f), via Delegated Regulation (EU) 2022/30 | Network protection for internet-connected radio equipment; (e) when the device processes personal, traffic or location data | Since August 1, 2025 |
| CRA, Chapter IV | Notification of conformity assessment bodies | Since June 11, 2026 |
| CRA, Article 14 | Notify actively exploited vulnerabilities and severe incidents to the coordinating CSIRT and ENISA; early warning within 24 hours | Since September 11, 2026 |
| CRA, all other provisions | Essential requirements of Annex I, conformity assessment, CE marking | December 11, 2027 |
Under 2024/2847, most sensors are default-category products and can use internal control (module A, Article 32(1)). A sensor sold as part of a smart home alarm system falls under Annex III, class I, item 17 ("smart home products with security functionalities", alarm systems among them), which needs harmonised standards applied in full or third-party assessment. EN 303 645 (V3.1.3, September 2024) is a useful baseline for consumer devices, but it is not a harmonised standard under the RED or the CRA. See Cyber Resilience Act (CRA) and EN 303 645 IoT cyber security.
Substances and waste
Section titled “Substances and waste”These rarely involve a test chamber, but a missing declaration can still block a listing.
| Obligation | Text | Scope for a sensor | Guide |
|---|---|---|---|
| RoHS | Directive 2011/65/EU | Restricted substances in the electronics | RoHS |
| REACH | Regulation (EC) 1907/2006, Article 33 | Information on substances of very high concern in articles | REACH SVHC |
| WEEE | Directive 2012/19/EU | Marking, registration, take-back | WEEE |
| Batteries | Regulation (EU) 2023/1542 | Cell, labels, producer responsibility | EU Battery Regulation |
| Conflict minerals | Regulation (EU) 2017/821; Dodd-Frank section 1502 in the US | Importers of 3TG minerals and metals (EU); issuers reporting to the SEC (US); customers often ask suppliers for a CMRT | Conflict minerals CMRT |
| Proposition 65 | California | Warnings for listed chemicals, for California sales | California Prop 65 |
Key dates for a LoRaWAN sensor
Section titled “Key dates for a LoRaWAN sensor”| Date | Event | Source |
|---|---|---|
| June 3, 2024 | LoRaWAN certificates issued after this date are valid five years | LoRa Alliance |
| August 1, 2025 | RED Article 3(3)(d), (e), (f) applies | Delegated Regulation (EU) 2022/30, as amended |
| August 18, 2025 | Battery Regulation Chapter VIII (management of waste batteries, producer register) applies | Regulation (EU) 2023/1542, Article 96 |
| October 1, 2025 | Australian LIPD Class Licence 2025 replaces the 2015 licence | ACMA |
| December 11, 2025 | EN 300 220-2 V3.3.1 cited under the RED | Decision (EU) 2025/2499 |
| September 11, 2026 | CRA vulnerability and incident reporting applies | Regulation (EU) 2024/2847, Article 71 |
| February 18, 2027 | Portable batteries removable and replaceable by the end user | Regulation (EU) 2023/1542, Article 11 |
| June 11, 2027 | EN 300 220-2 V3.1.1 loses presumption of conformity | Decision (EU) 2025/2499 |
| December 11, 2027 | CRA applies in full | Regulation (EU) 2024/2847, Article 71 |
Decision table: do I need it?
Section titled “Decision table: do I need it?”| Item | Need it? | Trigger |
|---|---|---|
| RED conformity (EN 300 220-2, EN 301 489-3, Article 3(1)(a), EN 18031-1) | Yes, EU | Placing on the EU market |
| FCC certification (15.247 or 15.249) | Yes, US | Any Part 15 intentional radiator |
| ISED certification (RSS-247) | Yes, Canada | Sale in Canada |
| LoRaWAN Certification | Voluntary | Claiming LoRaWAN Certified |
| UN 38.3 evidence for the cell | Yes, any lithium cell | Transport of the cell or the product |
| IEC 62133-2 or IEC 60086-4 | Supports the safety file | Rechargeable or primary lithium cell |
| Battery Regulation | Yes, EU | Any incorporated battery |
| CRA | Yes, EU, by December 11, 2027 (reporting already) | Product with digital elements |
| RoHS, REACH Article 33, WEEE | Yes, EU | Electronics placed on the market |
Claims the texts contradict
Section titled “Claims the texts contradict”| Claim | What the text says |
|---|---|
| "EN 300 220 V3.1.1 is the standard for EU868." | EN 300 220-2 V3.3.1 is cited since December 11, 2025; V3.1.1 loses presumption from June 11, 2027 (Decision (EU) 2025/2499). |
| "Apply the EN 301 489 series." | EN 301 489-1 is not cited by itself; the presumption for an SRD comes from EN 301 489-3 V2.3.2 (Decision (EU) 2025/893). |
| "Every lithium cell and the finished product must pass UN 38.3." | UN 38.3 tests cell and battery types. The sensor is not tested; it is shipped as UN 3091 or UN 3481 "contained in equipment", and button cells installed in equipment are exempt from the test summary duty (IATA 2026). |
| "IEC 62133 is the reference for the cell." | IEC 62133-2 covers secondary lithium cells only; a primary lithium cell falls under IEC 60086-4. |
| "15.249 is for low duty cycle designs." | 15.249 sets a field strength limit (50 mV/m at 3 m in 902 to 928 MHz) for any modulation; it has no duty-cycle condition. |
| "Certification runs against LoRaWAN 1.0.4 or 1.1." | The Alliance tags TS001-1.0.4 as required for certification. |
| "A pre-certified module does not waive a finished-product LoRaWAN submission." | Certification by Similarity covers module integration at child-certificate prices when its preconditions are met. |
| "Membership at Adopter level at least." | Institutional membership is free and can also certify end devices. |
| "The EU Battery Regulation adds carbon footprint duties for the sensor cell." | The carbon footprint articles target electric vehicle, LMT and certain industrial batteries, not portable batteries. |
| "A coin-cell sensor is not exempt from removability." | Article 11(3) exempts products that collect and supply data as their main function where a permanent connection is required for data integrity and continuity of power supply is necessary. |
| "Conflict minerals reporting applies to the sensor in the EU." | Regulation (EU) 2017/821 applies to Union importers of 3TG minerals and metals above the Annex I thresholds, not to finished electronics. |
| "A 3 V sensor is outside safety rules." | RED Article 3(1)(a) applies the LVD safety objectives with no voltage limit. |
Project checklist
Section titled “Project checklist”- Fix the target markets, then the RP002 channel plans (EU868, US915, AU915, AS923-1, KR920 and others).
- Choose a radio module and read its grant conditions and its LoRaWAN certificate (for Certification by Similarity).
- Build the technical file and a test plan.
- Run EN 300 220-2 V3.3.1, EN 301 489-3 and the Article 3(1)(a) assessment; FCC 15.247 and RSS-247 in parallel.
- Assess EN 18031-1 for Article 3(3)(d), and plan CRA vulnerability handling and reporting.
- Collect the UN 38.3 test summary and the safety evidence for the cell from its supplier.
- Check Article 11 removability against the February 18, 2027 date, or document the Article 11(3) exemption.
- Submit for LoRaWAN Certification at an ATL or in Self-Test.
- Compile RoHS, REACH Article 33, WEEE and battery producer registrations.
- Issue the EU declaration of conformity and apply the marks. Budget with the certification costs guide.
Common pitfalls
Section titled “Common pitfalls”| Pitfall | Consequence | Avoid by |
|---|---|---|
| Treating LoRaWAN Certified as a legal approval | Product blocked by market surveillance | Running the RED and FCC files separately |
| Designing for US915 power, then porting to Europe | Re-tuning to 25 mW e.r.p. and the duty cycle | Fixing all target plans before layout |
| Buying cells without their UN 38.3 summary | Shipment refused | Asking the cell supplier for it before ordering |
| Assuming the module grant covers the product | Failed EMC or a missing host label | Checking grant conditions and testing the finished product |
| Ignoring the gateway path for cyber | Article 3(3)(d) gap | Reading "directly or via any other equipment" in 2022/30 |
| Soldering the cell without a documented exemption | Non-compliance from February 18, 2027 | Designing for removability or recording the Article 11(3) reason |
Further reading
Section titled “Further reading”- LoRa Alliance LoRaWAN certification
- Radio spectrum and SRD license-free bands
- IEC 62133 and UN 38.3 battery safety and transport
- Cyber Resilience Act (CRA)
- CE vs FCC EMC: comparing the EU and US routes
- Certification getting started
Sources and references
Section titled “Sources and references”See also
Section titled “See also”Sources & references
- Directive 2014/53/EU (Radio Equipment Directive), EUR-Lex eur-lex.europa.eu/eli/dir/2014/53/oj
- Delegated Regulation (EU) 2022/30, Article 3(3)(d), (e) and (f) of the RED, EUR-Lex eur-lex.europa.eu/eli/reg_del/2022/30/oj
- Implementing Decision (EU) 2025/2499, EN 300 220-2 V3.3.1 cited, V3.1.1 withdrawn from June 11, 2027, EUR-Lex eur-lex.europa.eu/eli/dec_impl/2025/2499/oj
- Implementing Decision (EU) 2025/893, EN 301 489 parts cited under the RED, EUR-Lex eur-lex.europa.eu/eli/dec_impl/2025/893/oj
- 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
- Decision 2006/771/EC on short-range devices, consolidated text of January 23, 2025, EUR-Lex eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02006D0771(01)-20250123
- Implementing Decision (EU) 2025/650 amending Decision (EU) 2018/1538 (874 to 876 and 915 to 921 MHz), EUR-Lex eur-lex.europa.eu/eli/dec_impl/2025/650/oj
- ETSI EN 300 220-2 V3.3.1, short range devices in the 25 MHz to 1 000 MHz range, ETSI www.etsi.org/deliver/etsi_en/300200_300299/30022002/03.03.01_60/en_30022002v030301p.pdf
- 47 CFR 15.247, operation within the bands 902-928 MHz, 2400-2483.5 MHz and 5725-5850 MHz, eCFR www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-15/subpart-C/section-15.247
- 47 CFR 15.249, field strength limits in 902-928 MHz and other bands, eCFR www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-15/subpart-C/subject-group-ECFR2f2e5828339709e/section-15.249
- 47 CFR 15.212, modular transmitters, eCFR www.ecfr.gov/current/title-47/chapter-I/subchapter-A/part-15/subpart-C/section-15.212
- RSS-247, issue 4: DTS, FHS and LE-LAN devices, ISED Canada ised-isde.canada.ca/site/spectrum-management-telecommunications/en/devices-and-equipment/radio-equipment-standards/radio-standards-specifications-rss/rss-247-digital-transmission-systems-dtss-frequency-hopping-systems-fhss-and-licence-exempt-local
- Ordinance Regulating Radio Equipment (Japan), Article 49-14, current Japanese text, e-Gov Japan laws.e-gov.go.jp/law/325M50080000018
- LoRaWAN certification programme, LoRa Alliance lora-alliance.org/lorawan-certification/
- TS001-1.0.4 LoRaWAN L2 specification, LoRa Alliance lora-alliance.org/wp-content/uploads/2021/11/LoRaWAN-Link-Layer-Specification-v1.0.4.pdf
- RP002-1.0.3 LoRaWAN Regional Parameters, LoRa Alliance lora-alliance.org/wp-content/uploads/2021/05/RP002-1.0.3-FINAL-1.pdf
- Regulation (EU) 2023/1542 concerning batteries and waste batteries, EUR-Lex eur-lex.europa.eu/eli/reg/2023/1542/oj
- Lithium Battery Guidance Document, 2026 (based on the 67th edition of the IATA DGR), industry guidance, IATA www.iata.org/contentassets/05e6d8742b0047259bf3a700bc9d42b9/lithium-battery-guidance-document.pdf
- Regulation (EU) 2024/2847 (Cyber Resilience Act), EUR-Lex eur-lex.europa.eu/eli/reg/2024/2847/oj
- ETSI EN 303 645, cyber security for consumer Internet of Things (all versions), ETSI www.etsi.org/deliver/etsi_en/303600_303699/303645/
- Regulation (EU) 2017/821, supply chain due diligence for tin, tantalum, tungsten and gold, EUR-Lex eur-lex.europa.eu/eli/reg/2017/821/oj
Frequently asked questions
- Does a LoRaWAN sensor need both radio approval and LoRaWAN Certification?
- They are separate, and only radio approval is a legal requirement. Radio approval (the Radio Equipment Directive in the European Union, an FCC certification under 47 CFR Part 15 in the United States, an ISED certification in Canada) is what allows the product on the market. LoRaWAN Certification is a voluntary LoRa Alliance programme, open to members only, that tests the device against TS001-1.0.4 and the Regional Parameters (RP002) and gives the right to claim LoRaWAN Certified. A certified device still needs its CE marking and EU declaration of conformity.
- Which FCC rule applies to a 902 to 928 MHz LoRaWAN sensor?
- 47 CFR 15.247 in most cases. It allows 1 W peak conducted output for frequency hopping on at least 50 channels or for digital modulation with a 6 dB bandwidth of at least 500 kHz, and a hybrid mode under 15.247(f). The LoRa Alliance Regional Parameters summarise the US915 options as FHSS, DTS and hybrid. 47 CFR 15.249 is a different route, limited by field strength (50 mV/m at 3 m) rather than by duty cycle or bandwidth. Either way the device needs a certification granted by a TCB.
- Do UN 38.3 and the EU Battery Regulation apply to a coin-cell sensor?
- Yes, with nuances. Every lithium cell and battery type must have passed UN 38.3 before it is transported, but that is a test of the cell or battery, normally done by the cell maker, not of the sensor. The 2026 IATA guidance exempts button cells installed in equipment from the duty to make the test summary available. Under Regulation (EU) 2023/1542 the cell is a portable battery: removability by the end user applies from February 18, 2027, with a narrow exemption for data-collecting products when a permanent connection is needed for data integrity.
- When does the Cyber Resilience Act apply to my sensor?
- Regulation (EU) 2024/2847 applies in full from December 11, 2027. The reporting obligations of Article 14 (an early warning within 24 hours of becoming aware of an actively exploited vulnerability) already apply since September 11, 2026, and the notified body rules since June 11, 2026. A sensor is a default-category product (internal control, module A) unless it is listed in Annex III, for example a smart home alarm system component (class I). Under the Radio Equipment Directive, Article 3(3)(d) already applies since August 1, 2025 to internet-connected radio equipment.
- Which harmonised radio standard covers the EU 868 MHz band?
- ETSI EN 300 220-2 for Article 3(2) of the Radio Equipment Directive. Implementing Decision (EU) 2025/2499 cited version V3.3.1 from December 11, 2025 and withdraws V3.1.1 from June 11, 2027. EMC comes from EN 301 489-3 (V2.3.2, cited by Decision (EU) 2025/893), safety and RF exposure from Article 3(1)(a), which has no voltage limit, and network protection from EN 18031-1 (cited with restrictions by Decision (EU) 2025/138).
- Can a pre-certified LoRaWAN module cover the whole finished product?
- Not for radio law. Under the RED the finished product is assessed in all its configurations (Article 17(1)), and under the FCC rules a modular grant is reused only within its conditions, with a "Contains FCC ID" label on the host when the module ID is hidden (47 CFR 15.212). For LoRaWAN Certification, the LoRa Alliance offers Certification by Similarity for module integration, at child-certificate prices, if the transceiver and the LoRaWAN protocol software are unchanged and the parent certificate is under five years old.
- Does a US915 device work in every 915 MHz region?
- No. RP002 defines separate channel plans: US915 (902 to 928 MHz), AU915 (915 to 928 MHz, also used in Brazil according to the RP002-1.0.3 country table), four AS923 variants and KR920. Japan uses AS923-1 under Article 49-14 of the Ordinance Regulating Radio Equipment, with a 16 dBm EIRP cap and carrier sense for general use. Each market needs its own radio approval.
- Which environmental rules apply to a LoRaWAN sensor sold in the EU?
- RoHS (Directive 2011/65/EU), WEEE (Directive 2012/19/EU), REACH Article 33 information on substances of very high concern, and the Battery Regulation for the cell, including extended producer responsibility for batteries incorporated in appliances. The EU conflict minerals regulation (EU) 2017/821 is not a product obligation: it applies to Union importers of tin, tantalum, tungsten and gold minerals or metals above the Annex I volume thresholds.