Radio Equipment Directive FAQs of Life

Frequently Asked Questions
Radio Equipment Directive (RED)

American Certification Body (NB Number 1588) is notified under the Radio Equipment Directive (2014/53/EU) and EMC Directive (2014/30/EU). We have received many questions about the upcoming Radio Equipment Directive. The following is a summary of some of those “Frequently-Asked-Questions.”

1. Q. What is covered by the Radio Equipment Directive (RED)?

A. A radio transmitter, or receiver, or transceiver, which is used for radio communication or radio determination. It does not include transmitters used for other purposes, such as heating, cutting, treating materials, etc.

2. Q. What radio equipment is NOT covered by the RED?

A. Annex I of the RED covers equipment that is NOT covered by the RED. In general, equipment intended by radio amateurs is exempt. In addition, marine equipment and airborne equipment.

3. Q. When is the RED required?

A. After June 12, 2017. Up until that time, both the R&TTED or RED can be used. From June 13, 2017 and on, only the RED is allowed.

4. Q. What about products that use the RTTED?

A. From June 13, 2017, all products that are already physically in the market (in retail stores or in the supply chain that is not controlled by the manufacturer) can still be used or sold on to a final user. Any product that is placed on the market after June 13, 2017, must comply with the RED.

5. Q. Can I electronically label my device under RED?

A. No. This is not allowed for RED or any other Directive. The European Commission are looking at this option, which is allowed in several other markets, but not in the EU. Part of the concern is based around Market Surveillance and identifying a product without having to “turn it on.” There is also a concern that one cannot turn a product on until it is known to be CE-Marked. For example, in the EU, the CE Mark is not just about radio performance. It is safety too. Some argue that “maybe if we have it boot up in flight mode, so that it does not transmit until the CE Marking is displayed?” But CE Marking includes safety, one does not know that it is safe to plug it in or turn it on until the CE Marking is evident.

B. Finally, the EU commission say they have put a lot of effort into the CE Marking ‘brand’ and they don’t wish to dilute it now.

6. Q. Do I place an NB Number on my device if I use a Notified Body?

A. Under RED, this is only allowed for devices that are approved under Full Quality Assurance (Annex IV of the RED).

7. Q. What standards should I apply?

A. The recommended approach is to apply the harmonized standards (HS) that are listed in the Official Journal to self-declare to the RED. One difficulty lies in the fact that there is not a complete list of harmonized standards in the Official Journal.

8. Q. If HS are not accessible, how can I place a CE Mark on my product?

A. The RED allows for the use of a Notified Body (NB) to issue a EU-Type Examination Certificate (EU TEC). A manufacturer would submit an application for the EU TEC to a Notified Body who will evaluate the application for compliance with the RED. The NB would assess the Technical Documentation relating to the device and compare the test results or calculations to available standards (harmonized and non-harmonized) for compliance. A NB can accept testing to standards that are in various stages of development, including draft standards and committee working drafts, if available. There is some risk that draft standards are subject to change. A NB should give guidance on the potential risk for any of the approaches that may be used.

9. Q. Who can apply for an EU TEC?

A. The manufacturer or its authorized representative can apply for the EU TEC. Note that regardless of who submits the project to the Notified Body; the TEC would always be in the name of the manufacturer who places the product onto the market, with their brand name and company details on the product.

10. Q. What Documents are necessary for issuance of an EU-Type Examination Certificate?

A. The following information is required:

  • ACB Application Form: Review and Certificate - RED

  • External photos of the product

  • Internal photos of the product

  • User manual or instructions

  • Technical operation description

  • Block diagram

  • Parts list

  • Circuit schematic diagrams

  • Tune up tolerances

  • Product Safety test report

  • RF Exposure test report

  • EMC test report

  • Radio test report

  • Declaration of Conformity

  • Risk assessment by manufacturer

  • EFIS research evidence (for Class 2 devices)

  • Justification and explanation letters, in cases where full use of Harmonised Standards has not been used, or if any deviations or partial testing has been included.

  • Label

  • Packaging (optional)

NOTE: EU-Type Examination Certificates will feature an expiration date with the period of validity determined by the NB.

11. Q. What about scaled SAR?

A. “Scaled SAR” refers to the practice of adding transmitter tolerance to rated output power to determine SAR levels. This practice is referenced in Technical Guidance Note 20 (TGN20). This is guidance and it is not mandatory to comply with scaled SAR. However, there is a risk that market authorities may test devices at a higher-than-rated output power and so manufacturers are recommended to follow the guidance.

12. Q. What about Risk Assessment?

A. A manufacturer must prepare a Risk Assessment. Some of the ways to perform a Risk Assessment is to review the application and use of the device, such as its installation location, environmental conditions and end-use. If there is a good track record of performance with little risk, the risk assessment can be fairly straightforward. It is important for the manufacturer to check their products to the standards they have applied, to make sure there are no compliance risks to the Directive which were not covered by the standard.

B. It’s also important to remember that the standards will always lag behind technology. So, in cases where the device might do something (and therefore have a risk or mode) which is not covered by the standard (yet), they may need to do additional testing or research above and beyond the requirements of the standard. This is not certification to the standards; this is declaration to the Directive while using the standards as a ‘minimum starting point’ tool.

13. Q. Is an ISO 17025 accredited test report required?

A. No. The NB must be satisfied that the testing is being performed properly. Accreditation is not required for the testing lab.

14. Q. What additional tests are required under RED?

A. That depends. In many cases, you may have to perform some additional Receiver Tests if the new standard calls for the testing. There could also be additional spectrum sharing transmitter tests in some cases. Also note that the EMC immunity testing requirements have changed, to require more testing, notably for radio receivers.

15. Q. What about EMC and Safety? Are they still required?

A. Yes. The standards for EMC and Safety would be applied to satisfy EMC and Safety requirements for the Radio Device. It may be appropriate for the manufacturer to take standards from the EMCD and LVD to show compliance with the EMC and Safety requirements of the RED.

16. Q. What are the new reporting requirements for NBs?

A. NBs must file copies of the EU TEC with their designating authority. NBs must also update a central database with details of any EU TEC that was not issued, refused or recalled.

17. Q. Can you use HS that are harmonized under the EMC Directive for the RED?

A. Not directly. You can do it; but it will not offer immediate presumption of conformity with the RED. EMC standards may be harmonized under the EMC Directive, it does not extend to the RED. It is possible that some EMC and Safety standards may become listed in the RED OJ in the future.

18. Q. I have more questions, who should I contact?

A. American Certification Body

Our RED Experts are here to answer your questions

Michael Derby
Michael Derby

Michael Derby is a Senior Review Engineer and Director at American Certification Body in Europe. He has been with ACB since November 2007. Michael is a TCB for the FCC, an FCB for Industry Canada and a Notified Body for the R&TTE, EMC and RE Directives. Michael is an active member of the REDCA and TCB Council; acting as the liaison between the two organizations. He is also the Chairman of the TCB Council Board of Directors. He is the Secretary of the EMC Test Lab Association, responsible for education on testing methods and standards development. Michael’s past experience includes product development, testing and certification for test laboratories and manufacturers. Michael provides worldwide services to ACB’s global customers from his office in the Hampshire area of the UK.

Pieter Robben
Pieter Robben

Pieter Robben is a regulatory review engineer at ACB Europe. He is a TCB for the FCC, an FCB for Industry Canada, an RCB for Japan and a Notified Body for the R&TTE and EMC Directives. Pieter’s experience as a Notified Body and Certification Body is a potent part of our Certification team. Pieter has been reviewing FCC applications since before the TCB program was created. He is well known in the European community as past chairman of the R&TTECA. Pieter has been working with MIC matters since the inauguration of the Japan-EU Mutual Recognition Arrangement. Pieter’s past experience includes EMC, Radio and Safety testing and certification for test laboratories and manufacturers. He has been in the industry for more than 20 years. Pieter provides worldwide services to our global customers from his office in the Groningen area of the Netherlands.

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