February 10, 2017

Radio Equipment Directive (RED)

Many manufacturers of wireless devices are beginning to explore the labyrinth of requirements for radio transmitters going to Europe. Let CKC Laboratories help demystify your approval path for Europe’s new Radio Equipment Directive (RED)! The requirements apply not only to any new products first entering the EU market, but to all radio products sold in the EU. All radio products must meet the relevant requirements as of the “date of placement” onto the market. For US manufacturers, this is typically the date the products clear the EU importation requirements at customs (Blue Book Section 2.3).

At the time of writing, radio products can declare compliance to either the Radio and Telecommunication Terminal Equipment Directive 99/5/EC (R&TTED) or the Radio Equipment Directive 2014/50/EU (RED). The transition period for radio product approval from R&TTED to the RED has been fixed by EU regulators at June 12th, 2017. Per the Official Journal: “… Article 48 of the Directive 2014/53/EU, a transitional period between Directive 1999/5/EC and Directive 2014/53/EU has been granted, making Directive 1999/5/EC applicable at the choice of the economic operator until 12 June 2017.” Therefore, manufacturers can still declare compliance to the R&TTED until June 12th, 2017. After that, all radio products entering the EU will be required to have a Declaration of Conformity (DoC) to the RED. This means all manufacturers will have to plan in advance so that their product distribution chain isn’t disrupted by importation authorities due to an incorrect DoC.

One of the most obvious obstacles to full RED implementation is the lack of approved Harmonized Standards under the Directive. If manufacturers want to conform with the RED, few would be able to demonstrate compliance via the harmonized standard route and apply a CE Mark without Notified Body involvement. Another related obstacle is that the scope of radio products included under the RED has expanded and now encompasses radio determination (e.g. distance finding equipment and some perimeter protection systems) and devices operating below 9kHz (e.g. metal detectors). These devices may have been previously authorized under the EMC directive, but are now required to declare compliance under the RED.

The approval pathway for the RED, where no Harmonized Standards have been adopted, requires a Notified Body (such as CKC Certification Services) who works alongside the manufacturer to establish the compliance requirements. The end result of a successful evaluation is the issuance of an RED EU-Type Examination Certificate. The approval pathway when there exists a lack of harmonized standards may employ draft standards, other national or international requirements or in some cases requirements defined by the Notified Body. In this case compliance assessment is required to be monitored for changes to the “state of the art” (RED Annex III B.7). This means that many manufacturers will be required to periodically re-assess product compliance throughout the turmoil of continual changes to the adopted harmonized standards list. Regardless of directive or approval pathway, the product compliance for all products is required to be monitored for changes in the state of the art. Therefore, as requirements change (e.g. new Harmonized Standard), products will be required to meet the latest requirements as of the date of placement on the market.

The large majority of radio products will require additional testing in order to meet the latest requirements of compliance testing. Among the new requirements are extended frequency ranges for Radiated Immunity to 6GHz and Receiver Blocking tests.

Don’t wait for the deadline; secure your radio product’s future on the EU market by acting now.

Please contact CKC Laboratories to learn more about our ability to provide start to finish testing and compliance services for your transmitter products.