Manufacturers placing new or currently RTTED-compliant products on the market from 13 Jun 2017 onwards must ensure that products comply with the new RED requirements.
The European Union adopted a new set of rules for placing radio equipment on the European market, known as the Radio Equipment Directive (RED) (2014/53/EU which was published on 22 May 2014). RED supersedes the R&TTE Directive (RTTED), which was repealed on 13 Jun 2016.
If the product is already in the market (i.e. in stores or in the supply chain outside the manufacturer’s control prior to this date) then the RTTED compliance remains valid even after this date and can still be sold to end-users.
What remains unchanged from RTTED
Compliance is still based on self-declaration arrangement where the manufacturer / importer signs a Declaration of Conformity (DoC) once he is confident that the product complies to the essential requirements (RED and any other applicable Directives), labels the product with the CE-Mark before placing the product on the European market. The manufacturer / importer has the option to either test to harmonised standards (as published in the Official Journal of the European Union) or establish a technical file (demonstrating compliance to the essential requirement of RED). In the case where a technical file is used, a Type Examination by a Notified Body would be required.
Basic essential requirements related to the Low Voltage Directive (LVD) (but without any voltage limits) and the EMC Directive (EMCD) must still be met, and so radio equipment covered by RED (and the then RTTED) are not subject to the LVD or EMCD as the these would be addressed within RED (with certain modifications).
Additionally, equipment within the scope of RED must continue to ensure:
- That they are constructed to effectively uses the spectrum allocated to terrestrial / space radio communication and orbital resources so as to avoid harmful interference.
- That for certain classes of equipment:
- ensure network compatibility
- prevent harm to and misuse of network resources
- protect user privacy and the security of data
- prevent fraud
- provide access for the emergency services
- facilitate the use of equipment by disabled users.
Electronic labelling of equipment is still not allowed. For justifiable reasons, the physical CE-Marking of the product itself is still required.
Significant changes from RTTED
RED includes following radio equipment which were not included within RTTED:
- Radio equipment operating below 9kHz.
- Broadcast receivers (i.e. TV and radio).
- Radiodetermination equipment.
RED excludes following equipment which were included within RTTED:
- Wired telecommunications terminal equipment without any radio functions. These will now be regulated under LVD and EMCD requirements.
- Custom-built evaluation kits destined for professionals to be used solely at research and development facilities for such purposes.
RED teething problems during transitional period
The main difficulty is that the list of harmonised standards for RED is not complete at this current moment. In the absence of harmonised standards, the manufacturer will have to engage a Notified Body to undertake a Type Examination of the equipment for RED compliance.