Hello, Richard— FYI, if you’re diving back into EU RED after a time away, be aware of Essential Requirements for cybersecurity Article 3 (d) through (f). The EN 18031 cybersecurity standard series is available and harmonized to support your conformity assessment. Also, beginning December 11, 2027, the EU Cyber Resilience Act (CRA) takes full effect, replacing the RED cybersecurity articles; unfortunately we don’t get to “wait and see” and must continue to meet all RED in the interim period. EU CRA includes software in its definition of “digital elements” which may complicate your product’s conformity assessment.
Here’s a link to latest CRA draft guidance: European Commission Guidance on the Cyber Resilience Act · cyberresilienceact.eu<https://www.cyberresilienceact.eu/commission-guidance.html> Lean heavily on your wireless module suppliers to provide up to date cybersecurity claims. Good luck, Chet Summers From: Richard Georgerian <[email protected]> Sent: Monday, September 7, 2026 8:51 PM To: [email protected] Subject: Re: [PSES] Radio Equipment Directive (RED): Is testing to the relevant OJ standards mandatory? Or is technical document sufficient? Think Before You Click: This email originated outside our organization. Thank-you Charlie and Jim, It is always good to have confirmation of the interpretation of the RED and the practical point of view of meeting the intent of the RED… Best regards, …Richard Georgerian From: Jim Bacher <[email protected]<mailto:[email protected]>> Sent: Monday, September 7, 2026 6:37 AM To: [email protected]<mailto:[email protected]> Subject: Re: [PSES] Radio Equipment Directive (RED): Is testing to the relevant OJ standards mandatory? Or is technical document sufficient? 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]<mailto:[email protected]> or [email protected]<mailto:[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]<mailto:[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/ Registered in England and Wales, number 05466247 From: Richard Georgerian <[email protected]<mailto:[email protected]>> Sent: 05 September 2026 03:57 To: [email protected]<mailto:[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. 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To post a message to the list, send your e-mail to [email protected]<mailto:[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]<mailto:[email protected]> Rick Linford at: [email protected]<mailto:[email protected]> For policy questions, send mail to: Jim Bacher at: [email protected]<mailto:[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. 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