Richard, I agree with Charlie that testing is not mandated. However, as RF is complex, I fail to see how paperwork can confirm compliance for an RF device. I personally would always test.
Jim Bacher, WB8VSU [email protected] or [email protected] JBRC Consulting LLC Product EMC & Regulatory Consultant https://trc.guru/ email:[email protected] IEEE Life Senior Member On Mon, Sep 7, 2026, 7:05 AM Charlie Blackham <[email protected]> wrote: > Richard > > > > Whilst Directives such as EMCD, LVD and RED don’t explicitly mandate > “testing”, under the RED: Article 17(2) calls up Annex II which calls up > Article 21 > > > > The important thing about self-declaring, and not using a NB, is that the > article 3.2 and 3.3 assessments must demonstrate compliance with Harmonised > Standards published in the OJ, and Annex V requires test reports. > > > > As you note, if you are challenged and don’t have a “test report” the > product will still have to pass a test against the standard, and the only > real way that you can be confident of that outcome is to do some testing > 😊 > > > > Best regards > > Charlie > > > > > > *Charlie Blackham* > > *Sulis Consultants Limited* > > *Tel: +44 (0)7946 624317* > > *Web: https://sulisconsultants.com/ <https://sulisconsultants.com/>* > > Registered in England and Wales, number 05466247 > > > > > > *From:* Richard Georgerian <[email protected]> > *Sent:* 05 September 2026 03:57 > *To:* [email protected] > *Subject:* [PSES] Radio Equipment Directive (RED): Is testing to the > relevant OJ standards mandatory? Or is technical document sufficient? > > > > Greetings all, > > > > These questions may have been answered a few years back if my memory > serves me, but I don’t remember the details regarding the Radio Equipment > Directive (RED) 2014/53/EU. > > > > Is testing to the relevant Official Journal (OJ) standards mandatory? Or > is the technical document sufficient to show compliance? Can the > manufacture elect not to test, but to only use technical documentation (not > including test reports from a lab or internal to the manufacturer) be > sufficient to show compliance? > > > > My continued advice for certified radio equipment is to test whenever the > radio circuitry is affected, non-radio IC chip changes due to end-of-life > components, major non-radio circuitry changes, and changes to oscillators > to name a few examples. > > My continued advice for new radio equipment is to always test. > > Examples for not testing, plastic enclosure material (that has no carbon > material or shielding properties), adding non-metal labelling to the > enclosure, changing vent opening in plastic enclosures (enclosures that > don’t provide shielding) to name a few examples. > > > > It would be helpful to know for sure if the RED mandates testing to show > compliance; or if the manufacturer does a good enough job, that compliance > can be show through documentation only. Typically, the radio frequencies of > interest are 125 kHz, 13.56 MHz, and Bluetooth low energy (BLE). > > > > After reading the Radio Equipment Directive 2014/53/EU, I could not > confirm if testing is mandatory to show compliance. In short, to show > compliance it is to make sure it conforms to the essential requirements. > > I specifically focused on the following sections or paragraphs as it > relates to Annex II, Module A – > > 1. Legislative procedure outline in (40), page 6 of 45. > 2. Article 3, page 11 of 45. > 3. Article 17, page18 of 45. > 4. Article 21, page 20 of 45. > 5. In Annex V, section (h), page 41 of 45, it does mention test > reports. The technical documentation shall, wherever applicable, contain at > least the following elements. One of them is (h) test reports. However, if > the manufacturer determines that using only technical documents is > sufficient, whereas testing would be more absolute, the manufacturer may > then elect not to do the testing. > 6. In Article 21 (21.4), paragraph 4, page 20 of 45. Only if the > technical documentation does not comply with Articles 21.1, 21.2, and 21.3, > that the market surveillance authority can ask the manufacturer to have a > test performed. > > > > Any advice and recommendations would be greatly appreciated. > > > > Thank-you in-advance, > > > > …Richard Georgerian > ------------------------------ > > This message is from the IEEE Product Safety Engineering Society emc-pstc > discussion list. To post a message to the list, send your e-mail to > [email protected] > > All emc-pstc postings are archived and searchable on the web at: > https://www.mail-archive.com/[email protected]/ > <https://www.mail-archive.com/[email protected]/%20> > > Website: https://ewh.ieee.org/soc/pses/ > Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to > unsubscribe) <https://ewh.ieee.org/soc/pses/list.html> > List rules: > https://pses.ieee.org/wp-content/uploads/2024/12/EM-PSTC-List-Rules.pdf > > For help, send mail to the list administrators: > Mike Sherman at: [email protected] > Rick Linford at: [email protected] > > For policy questions, send mail to: > Jim Bacher at: [email protected] > ------------------------------ > > To unsubscribe from the EMC-PSTC list, click the following link: > https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC&A=1 > ------------------------------ > > This message is from the IEEE Product Safety Engineering Society emc-pstc > discussion list. To post a message to the list, send your e-mail to > [email protected] > All emc-pstc postings are archived and searchable on the web at: > https://www.mail-archive.com/[email protected]/ > > Website: https://ewh.ieee.org/soc/pses/ > Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to > unsubscribe) <https://ewh.ieee.org/soc/pses/list.html> > List rules: > https://pses.ieee.org/wp-content/uploads/2024/12/EM-PSTC-List-Rules.pdf > > For help, send mail to the list administrators: > Mike Sherman at: [email protected] > Rick Linford at: [email protected] > > For policy questions, send mail to: > Jim Bacher at: [email protected] > ------------------------------ > > To unsubscribe from the EMC-PSTC list, click the following link: > https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC&A=1 > - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to [email protected] All emc-pstc postings are archived and searchable on the web at: https://www.mail-archive.com/[email protected]/ Website: https://ewh.ieee.org/soc/pses/ Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to unsubscribe) List rules: https://pses.ieee.org/wp-content/uploads/2024/12/EM-PSTC-List-Rules.pdf For help, send mail to the list administrators: Mike Sherman at: [email protected] Rick Linford at: [email protected] For policy questions, send mail to: Jim Bacher: <[email protected]> _________________________________________________ To unsubscribe from the EMC-PSTC list, click the following link: https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC&A=1
