RED Directive, scope and applicability

Author Hugues Orgitello Last updated 25 May 2026

RED · Pillar

The RED Directive 2014/53/EU covers any equipment that intentionally transmits or receives radio waves for communication or radio determination. The definition is broad and its practical interpretation is the first step of any project, a wrong analysis at this stage tips a product into non-compliance.

The central criterion: intentionality

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

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

Three keywords condition applicability:

Intentionally, excludes parasitic involuntary emissions (which fall under the EMC Directive 2014/30/EU). A LED that emits noise at 100 MHz is not radio equipment; an FM transmitter at 100 MHz is.
For communication or radio determination, excludes purely energetic uses (microwave cooking, induction welding, etc.) that fall under other regulations.
Must be completed with an accessory to transmit, covers equipment sold without antenna but needing one to function. A bare radio card is concerned if intended for use with an antenna.

Products typically covered

Common communication equipment

Type	Band	Harmonised standard 3.2
Wi-Fi 2.4 GHz	2.4–2.4835 GHz	EN 300 328
Wi-Fi 5 GHz	5.15–5.725 GHz	EN 301 893
Wi-Fi 6 GHz	5.945–6.425 GHz	EN 303 687
Bluetooth / BLE	2.4 GHz	EN 300 328
ZigBee / Thread	2.4 GHz	EN 300 328
Z-Wave	868 MHz	EN 300 220
LoRa / Sigfox	868 MHz	EN 300 220
2G GSM	880–960 / 1710–1880 MHz	EN 301 511
3G UMTS	Bands 1, 8	EN 301 908
4G LTE	Bands 1, 3, 7, 8, 20, 28...	EN 301 908
5G NR	Bands n1, n3, n78, n79...	EN 301 908
NB-IoT / Cat-M	Specific LTE bands	EN 301 908
NFC	13.56 MHz	EN 303 098
UWB	6–8.5 GHz	EN 302 065
RFID	125 kHz, 13.56 MHz, 860 MHz	EN 302 208
PMR / DMR	VHF/UHF	EN 300 113

Pure receivers

Receivers without transmission are also covered by RED:

GNSS receivers (GPS, Galileo, GLONASS, BeiDou): EN 303 413
FM/DAB/DAB+ receivers for broadcast radio
Terrestrial TV receivers, EN 303 340
Satellite receivers

For pure receivers, article 3.2 requirements are reduced (no emission, no spectral mask) but articles 3.1(a) safety, 3.1(b) EMC and 3.3 cybersecurity apply normally.

Less obvious but covered equipment

Several product categories are sometimes overlooked:

RF remote controls for various objects (roller blinds, cars, remote-controlled toys)
Wireless home alarms
Connected smoke detectors
Wireless microphones professional and consumer
Drones with radio link (RC + video)
RF gate openers and access systems
Connected hearing aids
Active medical implants with radio
Smart meters (gas, water, electricity)
Movement trackers (dogs, bikes, luggage)

Explicit exclusions

Article 1(2) and Annex I list equipment explicitly out of scope:

Marine equipment

Marine equipment covered by Directive 2014/90/EU falls outside RED, even if it embeds a radio. It is governed by a specific regime with "ship wheel" marking by a designated body.

Aeronautics

Aeronautical equipment covered by Regulation (EU) 2018/1139 (civil aircraft onboard equipment) is excluded from RED. The EASA regime applies with its own airworthiness certifications.

Amateur radio communication equipment

Radio amateur equipment (in the ITU radio regulations sense) is excluded if not made available on the market as commercial products. A transceiver built by an amateur for personal use is out of scope; the same product sold commercially to amateurs is in scope.

Electrotechnical equipment for military use

Article 346 TFEU, military equipment falls under national defence rules and NATO standards.

Equipment intended exclusively for R&D, demonstration

Subject to visible labelling and no commercial placing. The boundary with a pre-production batch distributed to beta-testers is subtle (see CE Scope).

Evaluation kits for integrator manufacturers

Evaluation and development kits intended exclusively for manufacturers to integrate a module into their final product may benefit from a relaxed regime under certain conditions:

exclusive distribution to professionals (no consumer sale);
explicit documentation mentioning use limited to evaluation;
no commissioning as finished product.

Special case: software-defined radio (SDR)

Software-defined equipment (Software-Defined Radio) is covered by RED with specific requirements. The directive requires:

A complete description of authorised hardware-software combinations in the technical file.
Protection mechanisms against the installation of unauthorised configurations by the end user.
Traceability of software updates liable to affect radio parameters.

A mobile phone supporting multiple cellular bands is an SDR. A multi-band Wi-Fi router too. A software update of such equipment may affect its radio compliance, hence the importance of firmware version control.

Article 3(3)(i), not yet activated, specifically targets control of software installation by users on radio equipment. Practice anticipates these requirements by integrating signature and firmware image verification mechanisms.

Modules vs finished products

The case of commercial radio modules (integrable Wi-Fi, BLE, cellular modules) is one of the most frequent error sources in RED. Three statuses coexist:

Module sold as-is to integrators

The module can be CE-marked as such by its manufacturer, practically systematic for cellular modules (Quectel, u-blox, Sierra Wireless...) and qualified Wi-Fi/BLE modules (Espressif, Nordic, ST...). The marking covers the module in defined integration conditions:

supplied antenna or list of compatible antennas
minimum ground plane and supply impedance
thermal and mechanical conditions
isolation distance from other components

Module integrated in a finished product

When the module is integrated in a finished product, the finished product itself is subject to RED. Module tests can be reused only if integration conditions are strictly identical to those tested by the module manufacturer.

In practice, two frequent modifications invalidate reuse:

Different antenna (e.g. PCB antenna instead of the original external antenna): article 3.2 reassessment required.
Noisy power supply or non-compliant ground plane, risk on article 3.1(b) EMC.

Module reconfigured or rebranded

If the integrator modifies the module firmware to change its radio parameters (power, modulation, band), they become the manufacturer in the RED sense and must redo the complete assessment. The original module CE marking no longer applies.

If the integrator resells the module under their brand without modification, they are also considered manufacturer (cf. private-label rule).

Combinations and accessories

An important RED nuance concerns equipment combinations:

Radio equipment sold with an accessory essential to its operation (e.g. a specific external antenna) must be assessed in that configuration.
If multiple accessories are compatible, the file must list the exhaustive list and their compliance impact (power, mask, immunity).
An antenna sold separately as an optional accessory falls under the main equipment assessment, not its own, unless it substantially modifies radio characteristics.

Example: an internet router sold with two interchangeable external antennas. The file must:

assess the router with each of the two antennas (applicable worst case),
document the list of authorised antennas (model, gain, type),
specify use conditions (minimum placement from the user).

Geographic and frequency scope

RED applies to the European market. But authorised frequencies still differ slightly between countries, notably:

Certain 5 GHz and 6 GHz Wi-Fi sub-bands are authorised under different conditions per country.
The 433 MHz band has variable power limits.
Cellular bands depend on national assignments (and thus operators present).

The CEPT (European Conference of Postal and Telecommunications Administrations) publishes decisions (ECC Decisions) that harmonise assignments. The RED file must cite applicable ECC Decisions for the used bands.

Recurring special cases

Multi-radio equipment

A modern IoT product often integrates multiple radios (Wi-Fi + BLE + cellular). Each radio is individually assessed per its article 3.2 standard, but EMC article 3.1(b) is assessed in combined mode. Intermodulation tests between radios must be considered.

Equipment with variable operating modes

Wi-Fi equipment that can switch between access point and client modes must be tested in all modes. The DoC may cover the set of modes or distinct DoCs may be produced.

Product with disableable radio

If the radio can be disabled by the user, compliance is assessed with radio active, the possibility of deactivation does not exempt assessment. A simple software cut-off does not remove the product from RED's scope.

Sale to operators only

A product sold exclusively to telecom operators (e.g. a 5G base station) remains covered by RED. Requirements are the same; only distribution conditions and on-site testing change.

In summary

RED's scope reduces to a three-question test:

Does the product intentionally transmit or receive radio waves?
Is this transmission/reception for communication or radio determination purposes?
Is the product placed on the European market?

If all three answers are "yes", RED applies. Exclusions (military, marine, aeronautics, evaluation kits) are the exception, not the rule.

For practical implementation, see RED harmonised standards and Required tests.

Sources & references

Directive 2014/53/EU, articles 1 and 2 , EUR-Lex eur-lex.europa.eu/eli/dir/2014/53/oj
RED guide of the European Commission , European Commission single-market-economy.ec.europa.eu/sectors/electrical-and-electronic-engineering-industries-eei/radio-equipment-directive-red_en
ECC Decision (06)04: SRD frequencies , CEPT www.cept.org/ecc/