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RED scope, what counts as radio equipment

The RED Directive 2014/53/EU covers any electrical or electronic product that intentionally emits and/or receives radio waves for radio communication or radiodetermination. The definition is broad, it has exactly five exclusions, and the scope analysis is the first step of any project: a wrong answer here sends the product down the wrong conformity route. This page reads Articles 1 and 2 and Annex I of the directive with the Commission RED Guide where it interprets them, as of 7 October 2026.

Article 2(1)(1) of the directive defines "radio equipment" as:

an electrical or electronic product, which intentionally emits and/or receives radio waves for the purpose of radio communication and/or radiodetermination, or an electrical or electronic product which must be completed with an accessory, such as antenna, so as to intentionally emit and/or receive radio waves for the purpose of radio communication and/or radiodetermination

TermWhere it is definedWhat it means in practice
IntentionallyArticle 2(1)(1)Unintended emissions (a switching power supply, a LED driver) do not make a product radio equipment; they fall under the EMC Directive 2014/30/EU
Emits and/or receivesArticle 2(1)(1)A receive-only product is radio equipment
Radio communicationArticle 2(1)(2): "communication by means of radio waves"Any data, voice or broadcast link
RadiodeterminationArticle 2(1)(3): position, velocity or other characteristics of an object by the propagation properties of radio wavesRadar, GNSS, UWB ranging
Radio wavesArticle 2(1)(4): electromagnetic waves below 3 000 GHz, "propagated in space without artificial guide"Includes near-field (NFC, cochlear implants); infrared devices between 300 and 3 000 GHz are in scope, higher-frequency IR is not (RED Guide, sections 1.7.1 and 1.7.4.4)
Must be completed with an accessoryArticle 2(1)(1)A product sold without its antenna, or a module that needs one, is still radio equipment

Article 2(2) lets the Commission adopt implementing acts deciding whether a category of product meets the definition. The RED Guide notes its own examples would be reviewed if such an act were adopted.

The RED Guide (section 1.7.4.5) lists products that propagate electromagnetic waves for other purposes and are therefore not radio equipment: inductive warming and heating appliances, pure wireless power transfer systems without any radio communication or radiodetermination function, high-frequency surgical equipment, cookware for induction hobs, and test equipment using radio waves only to test other devices (case by case). Passive antennas sold on their own and cabling are not radio equipment either (sections 1.7.4.6 and 1.7.4.16).

TechnologyBandETSI standard family for Article 3(2)
Wi-Fi 2.4 GHz2 400-2 483.5 MHzEN 300 328
Wi-Fi 5 GHz5 150-5 350 and 5 470-5 725 MHzEN 301 893
Wi-Fi 6 GHz5 945-6 425 MHzEN 303 687
Bluetooth / BLE2.4 GHzEN 300 328
Zigbee / Thread2.4 GHzEN 300 328
Z-Wave868 MHzEN 300 220
LoRa / Sigfox868 MHzEN 300 220
2G GSM900 / 1 800 MHzEN 301 511
3G UMTS, 4G LTE, NB-IoT, LTE-M3GPP bands used in the EUEN 301 908
5G NRn28 (700 MHz), n78 (3.4-3.8 GHz), plus refarmed LTE bandsEN 301 908
NFC, RFID LF/HF125 kHz, 13.56 MHzEN 300 330
UWB6-8.5 GHzEN 302 065
RFID UHF865-868 MHzEN 302 208
PMR / DMRVHF/UHFEN 300 113

Which part and version of each standard gives presumption of conformity, and with what restriction, is on RED harmonised standards. The EU harmonised the three 5G "pioneer" bands by Commission decisions: 694-790 MHz (Implementing Decision (EU) 2016/687), 3 400-3 800 MHz (Decision 2008/411/EC as amended by (EU) 2019/235) and 24.25-27.5 GHz, 3GPP band n258 (Decision (EU) 2019/784, amended by (EU) 2020/590). Band n79 (4 400-5 000 MHz), sometimes listed for Europe, is harmonised by none of them.

A receive-only product is radio equipment: the definition says "emits and/or receives". The RED Guide (section 1.7.4.8) confirms that broadcast receivers are in scope, including DVB-T, DVB-T2 and DVB-S receivers; only pure DVB-C receivers fed by a wired cable network are out, unless they embed another radio such as WLAN. Typical cases:

  • GNSS receivers (GPS, Galileo, GLONASS, BeiDou): EN 303 413
  • Terrestrial TV receivers: EN 303 340
  • FM, DAB and DAB+ radios, satellite receivers

A receiver has no transmit spectral mask to meet, but Article 3(2) still applies to it. Recital 10 asks a receiver for "a level of performance that allows it to operate as intended and protects it against the risk of harmful interference", and recital 11 explains why reception capability matters for spectrum efficiency. Article 3(1)(a) safety and 3(1)(b) EMC apply as for any radio product. Article 3(3) points apply only where a delegated act covers the product (see below).

  • RF modules, components with an embedded RF module, and integrated circuits that can transmit or receive once integrated (RED Guide, section 1.7.4.11)
  • RFID tags: the tag is radio equipment, the tagged passport, card or ring is not (section 1.7.4.15)
  • Active antennas, and amplifiers, filters, splitters or antenna tuners intended to be connected to an antenna (sections 1.7.4.6 and 1.7.4.7)
  • Software-defined radio, "either as consumer equipment or as a development tool" (section 1.7.4.17)
  • Construction kits that, once assembled, are radio equipment; the kit manufacturer is responsible when the instructions are followed (section 1.7.4.10)
  • Medical devices with a radio: they bear the CE marking under the medical device rules and under the RED; a custom-made medical device that contains radio equipment still needs CE marking for the RED (RED Guide, section 2.8)
  • Drones in the open and specific categories (section 1.7.3.5, see below)
  • Base stations and professional equipment: the RED has no exclusion for professional or operator-only products; only Article 1(3) and Annex I exclude anything
  • Remote controls, wireless alarms, connected smoke detectors, smart meters, trackers, wireless microphones, gate openers: radio equipment by the definition

Article 1(2) points to Annex I, and Article 1(3) adds one exclusion. Nothing else is excluded.

ExclusionTextWhat the RED Guide adds
Public security, defence, State security, State criminal law activitiesArticle 1(3): radio equipment used "exclusively" for those activitiesDual-use equipment is not excluded. TETRA radios used by the police stay in scope because they are not used exclusively for those activities. Excluded equipment falls under the LVD and EMC Directive (section 1.7.3.1)
Radio amateur equipmentAnnex I point 1: equipment used by radio amateurs (ITU Radio Regulations, Article 1, definition 56), "unless the equipment is made available on the market"Not made available: kits for assembly by amateurs, equipment modified by and for amateurs, equipment built by individual amateurs for experimental and scientific purposes. Regular supply between amateurs can be making available (section 1.7.3.2)
Marine equipmentAnnex I point 2: equipment within Directive 96/98/ECThat directive was repealed by Directive 2014/90/EU from 18 September 2016; references are read as references to 2014/90/EU. It covers equipment that must be carried on ships under IMO conventions such as SOLAS. Marine radios for vessels with no such carriage requirement are under the RED. Autonomous Maritime Radio Devices (AMRD) are in scope (sections 1.7.3.3 and 1.7.3.4)
Airborne productsAnnex I point 3: airborne products, parts and appliances within Article 3 of Regulation (EC) 216/2008Replaced by Regulation (EU) 2018/1139 from 11 September 2018. Still under the RED: ground aviation radio equipment, drones in the open and specific categories, and certified-category drones not operating only on protected aeronautical frequencies (section 1.7.3.5)
Custom-built evaluation kitsAnnex I point 4: "custom-built evaluation kits destined for professionals to be used solely at research and development facilities for such purposes"All elements must be met: built on a specific request of a customer or R&D project group, a board for evaluation and development, for professionals at public or private R&D bodies, used for R&D. Not exempt: laboratory equipment used on a regular basis, generic evaluation boards sold to R&D departments, free-programmable SDR "black boxes" (section 1.7.3.6)

Trade fairs are not an exclusion either. Article 9(2) allows non-compliant radio equipment to be displayed with "a visible sign" saying it may not be made available or put into service until brought into conformity, and demonstrations need the measures Member States prescribe against interference. The RED Guide (section 1.6) adds that the national spectrum authority must be contacted to demonstrate a transmitter, and also for field tests of pre-production units.

Overlap with the LVD and the EMC Directive

Section titled “Overlap with the LVD and the EMC Directive”

Article 1(4): radio equipment in the RED scope "shall not be subject to Directive 2014/35/EU", except through Article 3(1)(a), which applies the LVD safety objectives "with no voltage limit". Article 2(2)(a) of the EMC Directive excludes equipment covered by Directive 1999/5/EC, a reference that Article 50 of the RED turns into a reference to the RED; Article 3(1)(b) brings the EMC requirements back in. A radio product therefore has one declaration under the RED for safety, EMC and spectrum, plus every other act that applies (RoHS, ecodesign, batteries, the CRA from 11 December 2027). The full mechanics are in which EU directives apply to my product.

RequirementApplies toStatus on 7 October 2026
3(1)(a) health and safety, no voltage limitAll radio equipmentApplies
3(1)(b) EMCAll radio equipmentApplies
3(2) efficient use of spectrumAll radio equipment, receivers includedApplies
3(3)(a), (b), (c), (h), (i)Only categories named in a delegated actNo delegated act (RED Guide, section 3.3)
3(3)(d), (e), (f) network, privacy, fraudCategories in Delegated Regulation (EU) 2022/30: internet-connected radio equipment; for (e) also toys, childcare and wearable equipment; for (f) equipment that transfers money or virtual currency; devices under the MDR or IVDR excludedApplies since 1 August 2025; 2022/30 repealed from 11 December 2027 by Delegated Regulation (EU) 2026/339
3(3)(g) emergency servicesMobile devices under Delegated Regulation (EU) 2019/320 (caller location) and older decisions (AIS, avalanche beacons, satellite search-and-rescue locator beacons, GMDSS on non-SOLAS vessels)2019/320 applies since 17 March 2022
3(4) common chargerCategories in Annex Ia (phones, tablets, cameras, headphones, headsets, handheld consoles, portable speakers, e-readers, keyboards, mice, portable navigation systems, earbuds, laptops)Since 28 December 2024; laptops since 28 April 2026 (Directive (EU) 2022/2380)

For the RED Guide, "wearable" means equipment worn on the body that monitors and records sensitive data (fitness trackers, smart watches, smart rings), not a smartphone held in the hand; implants are not wearable but can be internet-connected (section 1.7.2). The detail of 3(3) is on RED harmonised standards and the procedure consequences on RED conformity procedure.

The RED Guide treats SDR, consumer or development tool, as radio equipment and asks the manufacturer for enough information on intended use to allow compliant operation, which may include accessories such as antennas, software components and installation specifications, with special care for Article 10(8), Article 10(10) and Annex VI point 8 (section 1.7.4.17).

Two SDR provisions exist in the directive but do not apply yet. Article 4 (information on the compliance of radio equipment and software combinations) and Article 3(3)(i) (software can only be loaded where the combination has been shown to comply) both need a delegated act, and the RED Guide states there is currently none. Recital 19 warns that such verification must not be used to lock out software from independent parties.

A software update to equipment already on the market is maintenance unless it changes the intended functions, radio interface, type or performance in a way the initial risk assessment did not foresee, or changes the hazard or raises the risk; then the product is treated as new (RED Guide, section 1.5).

SituationWho carries the RED obligationsSource
Module placed on the market on its ownIts manufacturer: risk assessment of what can be identified before integration (intended use, and reasonably foreseeable use for safety), plus instructions that keep the module compliant once followedRED Guide, section 1.7.4.11
Module incorporated and permanently affixed in a non-radio electrical product at placing on the marketThe host manufacturer: the combination is a single product under the REDRED Guide, section 1.7.4.1
Radio device that can be easily accessed and readily removed from the hostSeparate products; only the radio device is under the REDRED Guide, section 1.7.4.1
Radio equipment attached to a non-electrical productThe operator placing the final product is the manufacturer if the radio was not already on the market, or if its function or performance is modified or compliance is affectedRED Guide, section 1.7.4.2
Importer or distributor selling under its own name, or modifying the equipment so compliance may be affectedThat importer or distributor becomes the manufacturerArticle 14
Vehicle with radio equipment not previously placed on the marketThe vehicle manufacturer is also the radio equipment manufacturerRED Guide, section 1.7.4.12

The host manufacturer can use the module assessment as evidence, but Article 17(1) still requires the assessment to "take into account all intended operating conditions" and to cover "all possible configurations". An antenna, power supply or enclosure outside the module instructions is the usual reason a module test report stops covering the final product; the RED tests page lists what is then repeated.

  • A radio product with its antenna attached is assessed as a whole. The radio-antenna interface need not be assessed separately unless the radio part is also sold without the antenna (RED Guide, section 1.7.4.6).
  • Passive antennas sold on their own are not radio equipment; active antennas always are.
  • Article 10(8): the instructions must include, where applicable, "a description of accessories and components, including software, which allow the radio equipment to operate as intended", plus the frequency bands and the maximum radio-frequency power transmitted.
  • A router sold with two interchangeable antennas must be assessed in both configurations (Article 17(1)), and the technical file lists both.

Multimode equipment and national restrictions

Section titled “Multimode equipment and national restrictions”

The RED Guide (section 1.7.4.3) allows multimode equipment with modes that cannot legally be used in any EU, EEA or EFTA country. The assessment covers the modes intended for use there; for the other modes, the manufacturer runs a risk analysis (how easy is it to activate the mode, what would it harm) and may need safeguards and user instructions.

Spectrum use is not fully harmonised. Article 7 lets Member States restrict putting into service and use for spectrum, interference, disturbance or public health reasons. Article 10(2) requires that the equipment can be operated in at least one Member State without infringing spectrum rules, and Article 10(10) requires the packaging to identify the Member States or areas with restrictions or authorisation requirements, completed in the instructions; Implementing Regulation (EU) 2017/1354 sets how to present it. The RED Guide (section 1.2.1) notes that the RED also applies in Iceland, Liechtenstein, Norway and Türkiye. Short range device conditions across CEPT countries are collected in ERC Recommendation 70-03, which is a recommendation, not EU law.

The RED applies to each unit placed on the EU market and then to every later making available until the end user (RED Guide, section 1.3). It covers new products made in the EU and new or second-hand products imported from third countries (section 1.5). A product bought by a consumer while abroad and brought into the EU for personal use is not placed on the market. Units must comply with the requirements in force on the day they are placed on the market, which is why the 1 August 2025 and 11 December 2027 dates above matter for stock. When and how a unit is placed is covered in CE scope.

ClaimWhat the text says
"Equipment intended exclusively for R&D or demonstration is excluded if labelled."Annex I point 4 excludes only custom-built evaluation kits for professionals used solely at R&D facilities. Demonstration is handled by Article 9(2), a display rule, not an exclusion.
"Evaluation and development kits sold to integrators get a relaxed regime."Generic evaluation boards sold to R&D departments are not exempt; the kit must be custom-built for a specific customer or project (RED Guide, section 1.7.3.6).
"Military equipment is excluded under Article 346 TFEU and NATO standards."The RED exclusion is Article 1(3): equipment used exclusively for public security, defence or State security. Dual-use equipment stays in scope.
"A transceiver built by an amateur for personal use is excluded."Annex I point 1 excludes equipment built by individual amateurs "for experimental and scientific purposes related to amateur radio", kits for assembly by amateurs and equipment modified by and for amateurs.
"All aeronautical equipment is excluded."Ground aviation radio equipment and drones in the open and specific categories are under the RED (RED Guide, section 1.7.3.5).
"Pure receivers are exempt from Article 3(2)."Article 3(2) applies to all radio equipment; recitals 10 and 11 set the receiver performance objective.
"Article 3(3) cybersecurity applies to every receiver or radio product."Only to the categories in Delegated Regulation (EU) 2022/30, which also excludes MDR and IVDR devices.
"The directive requires SDR protection mechanisms and a list of authorised hardware-software combinations."Article 4 and Article 3(3)(i) have no delegated act; the RED Guide states "currently no delegated act".
"A passive antenna sold as an accessory is covered by the RED."Passive antennas sold on their own are not radio equipment; active antennas are (RED Guide, section 1.7.4.6).
"The RED file must cite the applicable ECC Decisions."No such obligation exists in the directive. Article 10(10) requires restriction information on the packaging and in the instructions.
"Band n79 is a European 5G band."The EU harmonised 5G bands come from Decisions 2016/687, 2019/235 and 2019/784; none covers 4 400-5 000 MHz.
"Marine equipment carries the wheel mark from a designated body."Equipment within Directive 2014/90/EU is outside the RED. Radio equipment can also comply with both and then carries both the CE marking and the wheel mark (RED Guide, section 1.7.3.3).
  1. Does the product intentionally emit or receive radio waves below 3 000 GHz?
  2. Is that for radio communication or radiodetermination?
  3. Is it placed on, or made available on, the EU market?
  4. Does none of the five exclusions (Article 1(3), Annex I points 1 to 4) apply?

If all four answers are "yes", the RED applies, and with it Article 3(1) and 3(2), plus any Article 3(3) point or 3(4) that covers the product category. Continue with RED harmonised standards, required tests, the technical file and the conformity procedure.

Sources & references

  1. Directive 2014/53/EU (RED), Articles 1 to 4, 9, 10, 14, 17 and Annex I, EUR-Lex eur-lex.europa.eu/eli/dir/2014/53/oj
  2. Guide to the Radio Equipment Directive 2014/53/EU, sections 1.1 to 1.7 and 3.3, European Commission ec.europa.eu/docsroom/documents/33162
  3. Radio Equipment Directive (RED), Commission page, European Commission single-market-economy.ec.europa.eu/sectors/electrical-and-electronic-engineering-industries-eei/radio-equipment-directive-red_en
  4. Directive 2014/30/EU (EMC), Article 2(2)(a), EUR-Lex eur-lex.europa.eu/eli/dir/2014/30/oj
  5. Directive (EU) 2022/2380 amending the RED (common charger, Annex Ia), EUR-Lex eur-lex.europa.eu/eli/dir/2022/2380/oj
  6. Delegated Regulation (EU) 2022/30, Article 3(3)(d), (e) and (f), EUR-Lex eur-lex.europa.eu/eli/reg_del/2022/30/oj
  7. 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
  8. Delegated Regulation (EU) 2019/320, Article 3(3)(g) caller location, EUR-Lex eur-lex.europa.eu/eli/reg_del/2019/320/oj
  9. Implementing Regulation (EU) 2017/1354, presentation of Article 10(10) information, EUR-Lex eur-lex.europa.eu/eli/reg_impl/2017/1354/oj
  10. Implementing Decision (EU) 2016/687, 694-790 MHz band, EUR-Lex eur-lex.europa.eu/eli/dec_impl/2016/687/oj
  11. Implementing Decision (EU) 2019/235, 3 400-3 800 MHz band, EUR-Lex eur-lex.europa.eu/eli/dec_impl/2019/235/oj
  12. Implementing Decision (EU) 2019/784, 24.25-27.5 GHz band, EUR-Lex eur-lex.europa.eu/eli/dec_impl/2019/784/oj
  13. Implementing Decision (EU) 2020/590 amending 2019/784 (26 GHz technical conditions), EUR-Lex eur-lex.europa.eu/eli/dec_impl/2020/590/oj
  14. Directive 2014/90/EU on marine equipment, EUR-Lex eur-lex.europa.eu/eli/dir/2014/90/oj
  15. Regulation (EU) 2018/1139 on civil aviation (EASA), EUR-Lex eur-lex.europa.eu/eli/reg/2018/1139/oj
  16. ERC Recommendation 70-03 on short range devices (ECC), CEPT www.cept.org/ecc/

Frequently asked questions

Which products fall under the Radio Equipment Directive?
Any electrical or electronic product that intentionally emits and/or receives radio waves (below 3 000 GHz) for radio communication and/or radiodetermination, or that must be completed with an accessory such as an antenna to do so (Article 2(1)(1) of Directive 2014/53/EU). Pure receivers, broadcast receivers, RF modules, RFID tags and active antennas are covered. Products that use radio waves only for heating, wireless power transfer without data or surgery are not (RED Guide, section 1.7.4.5).
What does the RED exclude?
Five things: radio equipment used exclusively for public security, defence, State security or State criminal law activities (Article 1(3)); radio amateur equipment not made available on the market; marine equipment under the marine equipment directive (now 2014/90/EU); airborne products under the EU aviation safety regulation (now 2018/1139); and custom-built evaluation kits for professionals used solely at R&D facilities (Annex I). Dual-use equipment such as TETRA radios used by the police stays in scope.
Is a radio module covered by the RED on its own?
Yes. The RED Guide (section 1.7.4.11) lists RF modules, components with an embedded RF module and transmitting or receiving integrated circuits as radio equipment. Whoever places the module on the market assesses the risks identifiable before integration and supplies instructions that keep it compliant. When the module is incorporated and permanently affixed in a host product, the RED applies to the combination as a whole (section 1.7.4.1).
Do the RED cybersecurity requirements apply to every radio product?
No. Article 3(3) points only apply to the categories named in a delegated act. Delegated Regulation (EU) 2022/30 applies points (d), (e) and (f) since 1 August 2025 to internet-connected radio equipment and some toys, childcare and wearable equipment, excluding devices under the MDR and IVDR. It is repealed from 11 December 2027 by Delegated Regulation (EU) 2026/339, when the Cyber Resilience Act applies.