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RED Directive 2014/53/EU, the project checklist

This checklist breaks a RED project into six phases, from product concept to post-market. Each task names the provision that requires it (an article of Directive 2014/53/EU, an annex, a citation decision or Regulation (EU) 2019/1020), and tasks that are good practice rather than law are marked as such. It is read from the texts as of 7 October 2026 and complements the RED procedure, the required tests and the technical file. The directive sets no durations and no fees for any phase, so this page gives none: plan from your laboratory and notified body quotes.

PhaseWhat closes itMain provisions
1: ScopingRequirements, standards and procedure decided per radioArticles 1 to 3, 17; Delegated Regulation 2022/30
2: Design and analysisRisk assessment and configurations written downArticle 17(1); Annex III point 3(c) as read by the RED Guide
3: Internal pre-testsGaps closed before the external campaignGood practice, no legal requirement
4: Tests and notified bodyReports, and the certificate where Article 17(4) appliesArticle 17; Annexes II to IV; Decision 2022/2191 as amended
5: Technical file and DoCAnnex V file complete, DoC signedArticles 10(8), 10(9), 18, 21; Annexes V to VII
6: Placing on the market and afterMarked units shipped, surveillance runningArticles 10(4) to 10(12), 15, 19, 20; Regulation 2019/1020; CRA Article 14

Goal: lock down the RED perimeter before any irreversible hardware choice.

  • List every radio function: intentional transmitters (Wi-Fi, BLE, sub-GHz, LTE-M, NB-IoT, 5G, NFC, UWB) and receive-only functions (GNSS, FM, DAB). A receiver is radio equipment: the definition in Article 2(1)(1) says "emits and/or receives" (see RED scope).
  • Check the exclusions: Annex I (radio amateur equipment not made available on the market, marine equipment under Directive 96/98/EC, aviation equipment for exclusively airborne use, custom-built evaluation kits for professionals in R&D facilities) and Article 1(3) (equipment used exclusively for public security, defence or State security).
  • Map the essential requirements per radio: 3(1)(a) health and safety, 3(1)(b) EMC, 3(2) efficient use of spectrum (receivers included), and 3(4) common charger for the categories listed in Annex Ia (from 28 December 2024, laptops from 28 April 2026).
  • Check Article 3(3)(d), (e), (f) against Delegated Regulation (EU) 2022/30, which applies from 1 August 2025 (date set by Delegated Regulation (EU) 2023/2444). Point (d) covers equipment that "can communicate itself over the internet"; point (e) covers internet-connected equipment, childcare equipment, toys and wearables that process personal, traffic or location data; point (f) covers internet-connected equipment that lets the user transfer money, monetary value or virtual currency. Medical devices under Regulations 2017/745 and 2017/746 are excluded from all three.
  • Note the end date: Delegated Regulation (EU) 2026/339 repeals 2022/30 from 11 December 2027, when the Cyber Resilience Act applies in full.
  • Select the cited harmonised standards per radio and requirement in Annex I to Decision 2022/2191 as amended, on the OJEU list and not on a supplier datasheet (for example EN 300 328 V2.2.2 and EN 301 489-17 V3.3.1 for 2.4 GHz). Read the notices attached to each citation.
  • If the product falls under 2022/30, check the restrictions on EN 18031 in Decision (EU) 2025/138: no presumption if the user may choose not to set and use any password (clauses 6.2.5.1 and 6.2.5.2); for toys and childcare equipment under EN 18031-2 clauses 6.1.3 to 6.1.6, no presumption without parental or guardian access control; no presumption for EN 18031-3 clause 6.3.2.4 (secure updates) in any case.
  • Decide the procedure per requirement (Article 17): module A always open for 3(1) and 3(4); for 3(2) and 3(3), module A only with cited standards applied in full and no restriction triggered, otherwise modules B and C (Annex III) or module H (Annex IV). RED has no module A1. See RED procedure.
  • If a notified body is needed, check its scope in NANDO line by line: bodies can be notified for some requirements, for Annex III, Annex IV or both, and for selected equipment types (see choosing a notified body).
  • Identify the other Union acts for the single DoC (Article 18(3)): RoHS 2011/65/EU, the Batteries Regulation (EU) 2023/1542, ecodesign measures, and the machinery rules where the product is also machinery. The LVD does not apply in parallel: its safety objectives come in through Article 3(1)(a) (Article 1(4)). The EMC Directive does not either: its Article 2(2)(a) excludes equipment covered by Directive 1999/5/EC, which Article 50 of the RED reads as the RED.
  • Check that the product can be operated in at least one Member State without infringing spectrum rules (Article 10(2)), and list where use is restricted or needs an authorisation (Article 10(10)).
TaskBasis in the textsEvidence to keep
Radio inventory and exclusionsArticles 1(2), 1(3), 2(1)(1); Annex ICompliance plan, radio section
Requirements per radioArticle 3; Delegated Regulation 2022/30Requirements by radio matrix
Standards with versions and noticesDecision 2022/2191 as amended; Decision 2025/138Standards list with OJ references
Procedure per requirementArticle 17(2) to (4)Decision note
Notified body scope (if needed)Article 17(4); NANDOScope extract archived
Operation in at least one Member State, restrictionsArticle 10(2) and 10(10)Draft of the Annex V(i) statement

Goal: put the RED requirements into the architecture before layout and tooling are frozen.

  • Write the risk analysis. Annex III point 3(c) asks for "an adequate analysis and assessment of the risk(s)", and the RED Guide states it belongs in the technical documentation whatever the procedure, so for module A too.
  • List all configurations and operating modes (bands, modulations, power settings, antennas): Article 17(1) requires the assessment to confirm compliance "in all possible configurations". For multimode equipment the RED Guide limits this to modes that may legally be used in EU, EEA and EFTA countries.
  • Plan the RF exposure route for 3(1)(a): SAR to EN 50360 (devices used next to the ear) or EN 50566 (hand-held and body-mounted devices); EN 50385 or EN 50401 for base station equipment; for other equipment, an assessment against Council Recommendation 1999/519/EC, where EN 62311 or EN 62479 can serve as "other technical specifications", not as cited standards. See RED tests.
  • For each commercial radio module, keep its DoC, the reports relied upon and its integration instructions, and check the host design against them (antenna, ground plane, enclosure). The RED Guide says such reused assessments "may not be sufficient" and that the host manufacturer remains responsible for the whole product.
  • If the antenna or radio parameters differ from what the module assessment covered, plan the 3(2) and 3(1)(b) tests on the host.
  • Under 2022/30, write the EN 18031 analysis: the decision trees decide which requirements apply; record the mechanisms and their rationale. The standards do not prescribe a TLS version or a cipher list.
  • Track the software versions that affect compliance (Annex V(a)(ii)), for example a change "that would allow operation in a different frequency range or at higher output power" (RED Guide). Signed firmware and band locking are design measures the directive does not name; where user-changeable software could take the product out of its assessed configurations, the risk analysis has to address it.
  • For software-defined radio (SDR), note that Article 4 and Article 3(3)(i) are not active: the RED Guide states "currently no delegated act" for each.
TaskBasis in the textsEvidence to keep
Risk analysisAnnex III point 3(c); RED Guide (all procedures)Versioned risk assessment
ConfigurationsArticle 17(1)Configuration table
RF exposure routeArticle 3(1)(a); Recommendation 1999/519/EC; Decision 2022/2191Exposure assessment plan
Module reuseRED Guide on reused assessmentsModule DoC, reports, integration check
EN 18031 analysisDelegated Regulation 2022/30; Decision 2025/138Decision tree records
Software affecting complianceAnnex V(a)(ii)Version list with impact

Phase 3: Internal pre-tests (good practice)

Section titled “Phase 3: Internal pre-tests (good practice)”

Goal: find gross problems before paying for the external campaign. No text requires this phase.

  • Measure conducted emissions on mains and DC ports with an artificial network and a receiver or spectrum analyser, as pre-compliance.
  • Check the 2.4 GHz parameters of EN 300 328: 20 dBm e.i.r.p. maximum, power spectral density, adaptivity (listen before talk or detect and avoid) above 10 dBm e.i.r.p., or medium utilisation for non-adaptive equipment.
  • Check sub-GHz duty cycle against the EN 300 220-2 V3.3.1 band you use (band M, 868.000 to 868.600 MHz: 25 mW e.r.p., 1 % duty cycle or polite spectrum access).
  • Look for transmitter spurious emissions with a wide-span analyser (harmonics, mixing products).
  • Run ESD with a calibrated generator at the EN 301 489-1 V2.2.3 levels (±4 kV contact, ±8 kV air), the common part used through the specific EN 301 489 parts.
  • Walk through the EN 18031 decision trees and test the mechanisms you declared (for example rejection of an unsigned image if secure update is claimed, interrupted update and recovery).
  • Write a short pre-test note listing gaps and corrective actions.
TaskBasisEvidence to keep
Conducted emissionsPre-compliance against the EN 301 489 partInternal note
2.4 GHz and sub-GHz parametersEN 300 328 V2.2.2; EN 300 220-2 V3.3.1Measurement sheet per band
ESDEN 301 489-1 V2.2.3, clause 9ESD note
EN 18031 walk-throughEN 18031-1, -2, -3:2024Checklist and test log
SynthesisPracticeAction plan

Goal: produce the test reports and, where Article 17(4) applies, the EU-type examination certificate or quality system approval.

  • Choose the laboratory. Under module A the directive does not say who tests; under Annex III, test results may come from the manufacturer laboratory or another laboratory acting on its behalf. Accreditation to ISO/IEC 17025 is how a laboratory shows competence for the exact standards and versions on its scope: read the scope annex.
  • Provide samples representative of production and access to test modes. The directive sets no sample count; agree it with the laboratory.
  • 3(1)(a) health and safety. Exposure: EN 50360:2017 + A1:2023, EN 50566:2017 + A1:2023 or + A2:2025 (added by Decision (EU) 2026/2003), EN 50385, EN 50401. SAR measurement follows IEC/IEEE 62209-1528, which is not itself in the RED list. Electrical safety: Article 3(1)(a) covers it with no voltage limit; standards such as EN 62368-1 are not in the RED list and are listed as other technical specifications.
  • 3(1)(b) EMC. Cite the specific EN 301 489 part: -17 V3.3.1 for Wi-Fi and Bluetooth, -3 V2.3.2 for short range devices, -19 V2.2.1 for GNSS receivers, -52 V1.3.1 for cellular user equipment (V1.2.1 deleted from 15 November 2026). EN 301 489-1 is not cited on its own. The cited parts carry two notices: no presumption for emissions below 9 kHz, and none for 3(1)(b) if clause 6 is applied.
  • 3(2) spectrum. EN 300 328 V2.2.2 (2.4 GHz), EN 301 893 V2.2.1 (5 GHz, V2.1.1 deleted from 15 May 2028), EN 300 220-2 V3.3.1 (sub-GHz, V3.1.1 deleted from 11 June 2027), EN 301 908 parts for cellular, EN 303 413 V1.2.1 for GNSS. Radiated emissions of the radio belong here, not in EN 301 489.
  • 3(3)(d), (e), (f). EN 18031-1, -2, -3:2024 applied in full, with none of the Decision 2025/138 restrictions triggered, keeps module A; otherwise a notified body is required (Article 17(4)).
  • Notified body, where required: under Annex III, apply to "a single notified body of his choice"; the body examines the technical documentation and supporting evidence "without examination of a specimen" and issues the EU-type examination certificate. Under Annex IV, the body approves and audits the quality system.
  • Review each report: configurations tested match the configuration table, versions of the standards match the cited ones, firmware version recorded.
  • Close non-conformities with documented corrections and retests.
TaskBasis in the textsEvidence to keep
3(1)(a) exposure and safetyArticle 3(1)(a); Decision 2022/2191; Decision 2026/2003SAR report or exposure assessment; safety report
3(1)(b) EMCDecision 2025/893 (EN 301 489 parts and notices)EMC report per part
3(2) spectrumDecision 2022/2191 as amended; Decisions 2025/893 and 2025/2499Report per radio and standard
3(3) cybersecurityDelegated Regulation 2022/30; Decision 2025/138EN 18031 assessment record
EU-type examination (if required)Article 17(4); Annex IIICertificate and annexes
Quality system approval (if module H)Annex IVApproval decision, audit reports

Phase 5: Technical file and declaration of conformity

Section titled “Phase 5: Technical file and declaration of conformity”

Goal: assemble the file Article 21 requires before placing on the market, and sign the DoC.

  • Fill the nine Annex V elements: (a) general description with (i) photographs or illustrations, (ii) software versions affecting compliance, (iii) user information and installation instructions; (b) design and manufacturing drawings; (c) explanations of those drawings and of the operation; (d) standards applied in full or in part, and the solutions adopted otherwise; (e) copy of the DoC; (f) the EU-type examination certificate where Annex III applies; (g) design calculations and examinations; (h) test reports; (i) the explanation of Article 10(2) and of the Article 10(10) packaging information.
  • Add what sits outside Annex V but belongs in the file: the risk analysis and the configuration coverage (Article 17(1)), and the reused module assessments.
  • Write the instructions and safety information (Article 10(8)): for transmitters, the frequency bands and the "maximum radio-frequency power transmitted" in each; accessories and software that allow the equipment to operate as intended; for Article 3(4) equipment, the charging information and label of Annex Ia. In a language easily understood by end users, as the Member State decides.
  • Where use is restricted or needs authorisation, put the information on the packaging and complete it in the instructions (Article 10(10)), in the format of Implementing Regulation (EU) 2017/1354.
  • Draw up the EU declaration of conformity to the Annex VI model: equipment, manufacturer, the sole responsibility statement, object, the Union acts, the standards "with their identification number and version", the notified body where applicable, accessories and software where applicable, signature, place and date. The DoC number is optional. One DoC covers all applicable Union acts (Article 18(3)) and is translated into the language each Member State requires (Article 18(2)).
  • Prepare the simplified DoC if used (Article 10(9) and Annex VII wording), with the "exact internet address" of the full text.
  • Write a change procedure (good practice, serving Article 10(5)): who assesses a design, component, firmware or standard change, and how the file and DoC are updated.
TaskBasis in the textsEvidence to keep
Annex V elements (a) to (i)Article 21; Annex VStructured technical file
Risk analysis and configurationsAnnex III point 3(c); Article 17(1)Versioned documents
Instructions, bands and maximum powerArticle 10(8)Controlled manual per language
Restrictions of useArticle 10(10); Regulation 2017/1354Packaging artwork
Full DoCArticle 18; Annex VISigned DoC
Simplified DoCArticle 10(9); Annex VIIManual page and live URL

Phase 6: Placing on the market and afterwards

Section titled “Phase 6: Placing on the market and afterwards”

Goal: ship marked and traceable units, and keep the file alive for as long as the product is on the market and 10 years after.

  • Affix the CE marking "visibly, legibly and indelibly" to the equipment or its data plate, and "visibly and legibly" to the packaging (Article 20(1)); it may be lower than 5 mm if it stays visible and legible (Article 19(2)). See CE marking dimensions.
  • Add the notified body number after the CE marking only under module H (Article 20(3)). Under modules B and C, the CE marking stands alone.
  • Mark a type, batch or serial number (Article 10(6)) and the manufacturer name and postal address (Article 10(7)) on the equipment, or on the packaging or an accompanying document where size or nature does not allow it. Importers add their own (Article 12(3)).
  • Ship each unit with the DoC or the simplified DoC (Article 10(9)) and the instructions (Article 10(8)).
  • Make sure an economic operator established in the Union carries the Article 4 tasks of Regulation (EU) 2019/1020 (manufacturer, importer, authorised representative or fulfilment service provider), with its name and postal address on the product, packaging, parcel or an accompanying document. Without it, customs suspend release for free circulation (Article 26(1)(d)). Under the RED, appointing an authorised representative is optional (Article 11(1)). See authorised representative and importer.
  • Keep the technical documentation and the DoC for 10 years after the equipment has been placed on the market (Article 10(4)); the RED Guide counts from the last unit of the product model. Keep supplier and customer identification for 10 years (Article 15).
  • Keep series production in conformity and take into account design changes and changes in the cited standards (Article 10(5)), for example EN 301 489-52 V1.2.1 deleted from 15 November 2026 and EN 300 220-2 V3.1.1 from 11 June 2027.
  • Act on non-conformities: corrective measures, withdrawal or recall, and inform the authorities where the equipment presents a risk (Article 10(11)).
  • Since 11 September 2026, for products with digital elements in the CRA scope, notify actively exploited vulnerabilities and severe incidents to the coordinating CSIRT and ENISA through the single reporting platform (Regulation (EU) 2024/2847, Article 14), including for products placed on the market before 11 December 2027 (Article 69(3)).
  • Keep the Article 3(3) evidence for equipment placed on the market from 1 August 2025 to 10 December 2027: it stays subject to market surveillance after the repeal (Delegated Regulation 2026/339, recital 5).
  • Review the OJ list and Commission guidance periodically (good practice) so that changes reach the file before they reach production.
TaskBasis in the textsEvidence to keep
CE marking on equipment and packagingArticles 19 and 20Label and packaging artwork
NB number (module H only)Article 20(3)Label artwork
Identification, name and addressArticles 10(6), 10(7), 12(3)Label artwork
EU economic operatorRegulation 2019/1020, Article 4Mandate or importer agreement
10-year retentionArticles 10(4), 15Archive with access plan
Changes and standard revisionsArticle 10(5)Change log with impact assessment
Vulnerability and incident reportingCRA Article 14, from 11 September 2026Reporting procedure and records

Dated milestones for a RED project in 2026 and 2027

Section titled “Dated milestones for a RED project in 2026 and 2027”
DateActWhat changes on the checklist
28 December 2024Directive (EU) 2022/2380Article 3(4) common charger and Article 10(8) charging label for the categories in Annex Ia
January 2025Implementing Decision (EU) 2025/138EN 18031-1, -2 and -3:2024 cited, with restrictions
1 August 2025Delegated Regulation 2022/30, as amended by 2023/2444Article 3(3)(d), (e), (f) apply to the categories it lists
28 April 2026Directive 2022/2380Common charger requirements extend to laptops
11 September 2026Regulation (EU) 2024/2847, Article 14CRA vulnerability and incident reporting applies, also to products already on the market
15 November 2026Implementing Decision (EU) 2025/893EN 301 489-52 V1.2.1 loses its citation
11 June 2027Implementing Decision (EU) 2025/2499EN 300 220-2 V3.1.1 loses its citation
11 December 2027Delegated Regulation 2026/339; Regulation 2024/28472022/30 repealed; the CRA applies in full
7 March 2028Decision 2022/2191 as amendedEN 50566:2017 + A1:2023 (row 4a) loses its citation
15 May 2028Implementing Decision (EU) 2025/893EN 301 893 V2.1.1 loses its citation
Claim (several were on earlier versions of this page)What the texts say
"Receive-only radios fall under RED for 3.1(a), 3.1(b) and 3.3."Article 3(2) applies to receivers too; Article 3(3) only where a delegated act covers the product.
"Article 3.3 applies by default to any internet-connected radio product."Only to the categories of Delegated Regulation 2022/30, which excludes MDR and IVDR devices, and only until 11 December 2027.
"Article 3.1(a) is shown with EN 62311 and EN 62209-1/-2/-3."The RED list cites EN 50360, EN 50566 (A2:2025 added by Decision 2026/2003), EN 50385 and EN 50401. EN 62311 is not cited; IEC/IEEE 62209-1528 replaced IEC 62209-1 and -2 and is not cited either.
"A partly applied standard means a notified body, whatever the requirement."Article 17(2): module A stays open for 3(1)(a), 3(1)(b) and 3(4). The notified body is required only for 3(2) and 3(3) (Article 17(4)).
"Radio EMC is tested to EN 301 489-1 plus the radio-specific part."EN 301 489-1 is not cited on its own; the DoC cites the specific part, such as -17 V3.3.1, with its two notices.
"The NB number goes next to the CE marking under module A1, B+C or H."RED has no module A1, and Article 20(3) adds the number only under module H (Annex IV).
"If the CE marking is under 5 mm, it moves to the packaging and the manual."Article 19(2) allows less than 5 mm if visible and legible; Article 20(1) requires the marking on the equipment or data plate and on the packaging in all cases. The manual is not mentioned.
"The manual must give the maximum EIRP."Article 10(8) asks for the frequency bands and the "maximum radio-frequency power transmitted".
"Non-EU manufacturers must designate an authorised representative under Article 11, or customs reject the goods."Article 11(1) says "may". Regulation 2019/1020 requires an EU economic operator (importer is enough) and its details on the product; customs suspend release if they are missing (Article 26(1)(d)).
"The external lab must be ISO/IEC 17025 accredited and three samples are required."The RED does not say who tests under module A and sets no sample count.
"The DoC needs a unique number that is incremented at each change."The Annex VI footnote makes the number optional.
"The full DoC must be a PDF/A at a public URL without cookies, online for 10 years."Article 10(9) requires the exact internet address of the full text; the directive sets no format or access rule.
"EN 18031 requires TLS 1.2 or later."Neither Decision 2025/138 nor Delegated Regulation 2022/30 names a protocol; requirements come from the standard decision trees.
"Typical schedule: 4 to 6 months, 8 to 12 months with a notified body."No text sets durations; earlier figures on this page had no source and were removed.
"A module integration guide not followed invalidates the module CE marking."The host manufacturer is responsible for the whole product; reused module assessments "may not be sufficient" and go in the host file (RED Guide).

See also the common RED pitfalls for risks by family.

Sources & references

  1. Directive 2014/53/EU (RED), Articles 1, 3, 10 to 12, 15, 17 to 21 and Annexes II to VII, EUR-Lex eur-lex.europa.eu/eli/dir/2014/53/oj
  2. Directive 2014/53/EU, consolidated text of 28 December 2024 (Articles 3(4) and 10(8) as amended by Directive (EU) 2022/2380), EUR-Lex eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02014L0053-20241228
  3. Guide to the Radio Equipment Directive 2014/53/EU, European Commission ec.europa.eu/docsroom/documents/33162
  4. Delegated Regulation (EU) 2022/30, Article 3(3)(d), (e) and (f), EUR-Lex eur-lex.europa.eu/eli/reg_del/2022/30/oj
  5. Delegated Regulation (EU) 2023/2444, application of 2022/30 moved to 1 August 2025, EUR-Lex eur-lex.europa.eu/eli/reg_del/2023/2444/oj
  6. Delegated Regulation (EU) 2026/339, repeal of 2022/30 from 11 December 2027, EUR-Lex eur-lex.europa.eu/eli/reg_del/2026/339/oj
  7. Implementing Decision (EU) 2022/2191, list of RED harmonised standards, EUR-Lex eur-lex.europa.eu/eli/dec_impl/2022/2191/oj
  8. 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
  9. Implementing Decision (EU) 2025/893, EN 301 489 parts with notices, EN 301 893 V2.2.1, EUR-Lex eur-lex.europa.eu/eli/dec_impl/2025/893/oj
  10. Implementing Decision (EU) 2025/2499, EN 300 220-2 V3.3.1, V3.1.1 deleted from 11 June 2027, EUR-Lex eur-lex.europa.eu/eli/dec_impl/2025/2499/oj
  11. Implementing Decision (EU) 2026/2003, EN 50566 with A2:2025, EUR-Lex eur-lex.europa.eu/eli/dec_impl/2026/2003/oj
  12. Regulation (EU) 2019/1020 on market surveillance, Articles 4 and 26, EUR-Lex eur-lex.europa.eu/eli/reg/2019/1020/oj
  13. Regulation (EU) 2024/2847 (Cyber Resilience Act), Articles 14, 69 and 71, EUR-Lex eur-lex.europa.eu/eli/reg/2024/2847/oj
  14. Directive 2014/30/EU (EMC), Article 2(2)(a), EUR-Lex eur-lex.europa.eu/eli/dir/2014/30/oj
  15. Implementing Regulation (EU) 2017/1354, presentation of the Article 10(10) information, EUR-Lex eur-lex.europa.eu/eli/reg_impl/2017/1354/oj
  16. ETSI EN 300 328 V2.2.2 (2019-07), 2.4 GHz wideband data transmission, ETSI www.etsi.org/deliver/etsi_en/300300_300399/300328/02.02.02_60/en_300328v020202p.pdf

Frequently asked questions

When should the RED checklist start in a product project?
As early as the product requirements document. Phase 1 (regulatory scoping) should be closed before the hardware architecture is frozen: the band, the radio module and the antenna decide which harmonised standards apply, and whether Article 3(2) can stay under internal production control (module A).
Does every RED product need a notified body?
No. Article 17(2) always allows module A for Article 3(1)(a) health and safety, 3(1)(b) EMC and 3(4). A notified body (modules B and C, or H) is needed for Article 3(2), and for the activated points of Article 3(3), only when the cited harmonised standards are not applied in full or do not exist (Article 17(4)), or when a restriction attached to the EN 18031 citations in Decision (EU) 2025/138 applies to the product.
Does the CE marking need the notified body number?
Only under module H (Annex IV). Article 20(3) of the RED adds the notified body identification number only where the full quality assurance procedure is applied. Under modules B and C the CE marking stands alone, even though a notified body issued the EU-type examination certificate. The marking goes on the equipment or its data plate and on the packaging (Article 20(1)).
What must be kept for 10 years?
The technical documentation (the Annex V elements, including test reports, the versions of software affecting compliance and every DoC issued) and the EU declaration of conformity, for 10 years after the equipment has been placed on the market (Article 10(4)). Under module B and C the EU-type examination certificate and its additions are kept with it. Every economic operator must also be able to name who supplied it and whom it supplied for 10 years (Article 15).
How do we handle a firmware update that changes radio parameters after market placement?
Article 10(5) requires changes in design or characteristics to be adequately taken into account. The RED Guide treats an update as maintenance unless it modifies the intended functions, radio interface, type or performance in a way not foreseen in the initial risk assessment; in that case the updated product is treated as a new product. Record the assessment in the file, update the software versions under Annex V(a)(ii), and under module B and C request an addition to the certificate (Annex III point 7).
Is an EU authorised representative mandatory for a non-EU manufacturer?
Not under the RED, whose Article 11 says a manufacturer "may" appoint one. Article 4 of Regulation (EU) 2019/1020 requires an economic operator established in the Union for RED products: the manufacturer, the importer, an authorised representative with a written mandate, or a fulfilment service provider. Its name and postal address must appear on the product, packaging, parcel or an accompanying document.
Does the Cyber Resilience Act already apply to radio products?
Partly. Its Article 14 reporting obligations (actively exploited vulnerabilities and severe incidents) apply from 11 September 2026, also to products with digital elements placed on the market before 11 December 2027 (Article 69(3)). The rest applies from 11 December 2027, the date Delegated Regulation (EU) 2026/339 repeals the RED cybersecurity act 2022/30.