Your product must not be declared in conformity with the EMCD and/or LVD — if it contains any wireless or radio functions at all!
The Radio Equipment Directive (RED):
What it is, and why it will soon be applicable to almost everything
In 2016, the RED (2014-53-EU) replaced the old R&TTE Directive, making sweeping changes that will impact most product manufacturers who provide equipment with radio functions.
In fact, in a few years – due to the Internet of Things (IoT) – it will probably be quite a rare product that declares compliance with the EMCD or LVD. The RED will cover almost everything.
All products that have a radio function, whether transmitter or receiver, come within scope of the RED and are required to demonstrate compliance with its EMC and safety requirements, not the requirements of the EMC Directive or LVD themselves.
Even if the main function of the product is not a radio feature, or if the manufacturer has simply affixed a CE Marked radio module to it; the RED still applies to the final product.
For example: if a 1,000 tonne stamping press that consumes 1 MegaWatt of electrical power is fitted with even a single tiny Wi-Fi or Bluetooth module – then it can no longer be declared compliant with the EMCD. It must declare compliance to the RED’s EMC requirements, instead.
And that’s not all!
The RED has extended the definition of ‘radio function’ to cover equipment that uses wireless propagation for ‘radio determination’: i.e. using radiowave propagation to find things (e.g. stud finders, metal detectors, etc.), at any frequency up to 3,000 GHz.
So, the RED covers everything: from low-power short-range radiocommunications; GPS receivers; radio and TV receivers; cellular communication modules; ground-penetrating radar; many forms of wireless power transfer, etc.
We might expect that we could simply swap from applying harmonised EMC or safety test standards listed under the EMCD or LVD, to applying the equivalent harmonised EMC or safety test standards listed under the RED – but we would be wrong!
Unfortunately, there are very few EMC or safety test standards listed so far under the RED, and this will be the situation for many years to come. How to deal with this issue and others will be discussed in the RED workshop on Thursday May 21st from 09:00 – 10:30, part of the EMC & Compliance International event at Newbury Racecourse, www.emcuk.co.uk.
In the chair will be Michael Derby, TCB, CB, and RED Notified Body.
Photo by Stellan Johansson on Unsplash
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