Use both workstreams when the placed product is machinery and is also radio equipment because it intentionally emits or receives radio waves for communication or radiodetermination.
Machinery covers the complete machine's safety case. RED separately covers radio-equipment health and safety, electromagnetic compatibility, efficient spectrum use, conformity assessment, technical documentation, instructions, declaration, and CE marking.
A wireless machine can fall under both the Machinery Regulation and Directive 2014/53/EU. RED applies when the assessed product is : an electrical or electronic product that intentionally emits or receives radio waves for radio communication or radiodetermination, including a product that needs an accessory such as an antenna to do so. Define whether the placed product is the complete radio-enabled machine or a separately supplied module, then complete the machinery safety assessment and the RED assessment for that same boundary. A module supplier's declaration does not by itself establish conformity of the final machine.
Side-by-side comparison
Machinery vs RED: side-by-side comparison
A cited-source comparison for radio-enabled machinery: keep machinery safety/EHSR work separate from RED-side radio-equipment scope and evidence.
This side supports products within Regulation (EU) 2023/1230: machinery, related products, and partly completed machinery, including the EHSR, technical documentation, conformity assessment, instructions, declaration, and CE marking file.
Second framework
Radio Equipment Directive
Regime for an electrical or electronic product that intentionally emits or receives radio waves for communication or radiodetermination, covering health and safety, EMC, spectrum use, conformity assessment, technical documentation, instructions, declaration, and CE marking.
Machinery covers machinery, listed related products, and partly completed machinery. The Machinery Regulation also contains exclusions for specified electrical and electronic products when they fall within Directive 2014/35/EU or Directive 2014/53/EU.
RED applies to an electrical or electronic product that intentionally emits or receives radio waves for radio communication or radiodetermination, including a product that needs an accessory such as an antenna to do so, subject to Article 1 and Annex I exclusions.
Define the placed product. If the complete machine has the intentional radio function, assess that complete product under RED; if a module is separately placed, its RED file remains supplier input to the final-machine assessment.
Machinery evidence should show how the machine or related product meets applicable essential health and safety requirements, including risks created by control systems or components that affect the safe operation of the machine.
RED requires the manufacturer of the to address health and safety, electromagnetic compatibility, and efficient spectrum use. Importers and distributors have separate verification, traceability, storage, cooperation, and corrective-action duties.
Assign roles for the complete placed product. A module manufacturer remains responsible for its module, while the final-machine manufacturer must assess whether integration changes the configuration or compliance claims.
For machinery or related products, the manufacturer file should include the risk assessment, EHSR matrix, technical documentation, instructions, conformity assessment route, EU declaration of conformity, and CE marking review.
The RED manufacturer file should identify intended use, software affecting compliance, frequency bands and maximum radio-frequency power, risk assessment, design and test evidence, conformity route, instructions, EU declaration, and CE marking.
Keep supplier module declarations and tests, then document integration changes such as antenna, enclosure, power, host software, simultaneous transmission, and environment before deciding what can be reused.
Machinery remains the controlling workstream for machinery hazards and EHSRs unless a more specific EU law covers the relevant risk for the relevant product boundary.
RED Article 3 requires health and safety using LVD safety objectives without a voltage limit, EMC, and efficient spectrum use. Extra Article 3(3) requirements apply only to product categories or classes covered by a Commission measure.
Apply RED to the and Machinery to the machine. Allocate overlapping risks explicitly, but do not drop non-overlapping machinery hazards or RED spectrum requirements.
The machinery file needs its risk assessment, EHSR matrix, design and test evidence, instructions, conformity route, technical documentation, and declaration for the machine boundary.
The RED technical documentation must allow conformity with applicable essential requirements to be assessed and cover the 's design, manufacture, operation, versions, standards, calculations, tests, and risk assessment.
Tag evidence by both product boundary and legal requirement. A radio module report supports the final machine only within its tested configuration and stated integration conditions.
The Machinery Regulation's main manufacturer regime applies from 20 January 2027; machinery placed before then remains under the Directive transition rules.
RED has applied through Member State measures since 13 June 2016. Product-specific delegated requirements can have later application dates, so confirm whether the assessed category is covered before adding them.
For releases from 20 January 2027, plan the Machinery Regulation file and the already-applicable RED file together. Track any later RED delegated requirement separately by product category.
Machinery authorities assess the machine against its machinery scope, EHSRs, conformity route, documentation, instructions, declaration, markings, and corrective-action duties.
RED authorities can require corrective action for that presents a risk or is formally non-compliant, including bringing it into conformity, withdrawal, or recall as the Directive's conditions require.
A problem in a radio-enabled safety function can trigger both files. Coordinate the technical correction, stock and customer measures, authority notices, and revised declarations without assuming one authority response settles the other.
Machinery and RED can share product descriptions, drawings, software identifiers, risk controls, test configurations, standards registers, and corrective-action records.
RED module evidence remains bounded by the assessed module configuration and integration conditions; the final radio-enabled machine may need additional assessment when the host changes radio, EMC, or safety performance.
Reuse facts and reports by reference, but record gaps for antenna, enclosure, power, software, simultaneous transmitters, environment, and safety-function integration.
Use Machinery for the complete machine's hazards, EHSRs, safety functions, instructions, conformity route, technical documentation, and machinery declaration.
Use RED when the assessed product intentionally emits or receives radio waves. Internal production control is available only under the Article 17 conditions; otherwise Article 3(2) and 3(3) assessment requires EU-type examination or full quality assurance.
If the complete machine meets both definitions, neither file merely leads: complete both applicable assessments for the same release and show both legal bases in the declaration package.
Machinery covers machinery, listed related products, and partly completed machinery. The Machinery Regulation also contains exclusions for specified electrical and electronic products when they fall within Directive 2014/35/EU or Directive 2014/53/EU.
Radio Equipment Directive
RED applies to an electrical or electronic product that intentionally emits or receives radio waves for radio communication or radiodetermination, including a product that needs an accessory such as an antenna to do so, subject to Article 1 and Annex I exclusions.
Operational implication
Define the placed product. If the complete machine has the intentional radio function, assess that complete product under RED; if a module is separately placed, its RED file remains supplier input to the final-machine assessment.
Machinery evidence should show how the machine or related product meets applicable essential health and safety requirements, including risks created by control systems or components that affect the safe operation of the machine.
Radio Equipment Directive
RED requires the manufacturer of the to address health and safety, electromagnetic compatibility, and efficient spectrum use. Importers and distributors have separate verification, traceability, storage, cooperation, and corrective-action duties.
Operational implication
Assign roles for the complete placed product. A module manufacturer remains responsible for its module, while the final-machine manufacturer must assess whether integration changes the configuration or compliance claims.
For machinery or related products, the manufacturer file should include the risk assessment, EHSR matrix, technical documentation, instructions, conformity assessment route, EU declaration of conformity, and CE marking review.
Radio Equipment Directive
The RED manufacturer file should identify intended use, software affecting compliance, frequency bands and maximum radio-frequency power, risk assessment, design and test evidence, conformity route, instructions, EU declaration, and CE marking.
Operational implication
Keep supplier module declarations and tests, then document integration changes such as antenna, enclosure, power, host software, simultaneous transmission, and environment before deciding what can be reused.
Machinery remains the controlling workstream for machinery hazards and EHSRs unless a more specific EU law covers the relevant risk for the relevant product boundary.
Radio Equipment Directive
RED Article 3 requires health and safety using LVD safety objectives without a voltage limit, EMC, and efficient spectrum use. Extra Article 3(3) requirements apply only to product categories or classes covered by a Commission measure.
Operational implication
Apply RED to the and Machinery to the machine. Allocate overlapping risks explicitly, but do not drop non-overlapping machinery hazards or RED spectrum requirements.
The machinery file needs its risk assessment, EHSR matrix, design and test evidence, instructions, conformity route, technical documentation, and declaration for the machine boundary.
Radio Equipment Directive
The RED technical documentation must allow conformity with applicable essential requirements to be assessed and cover the 's design, manufacture, operation, versions, standards, calculations, tests, and risk assessment.
Operational implication
Tag evidence by both product boundary and legal requirement. A radio module report supports the final machine only within its tested configuration and stated integration conditions.
The Machinery Regulation's main manufacturer regime applies from 20 January 2027; machinery placed before then remains under the Directive transition rules.
Radio Equipment Directive
RED has applied through Member State measures since 13 June 2016. Product-specific delegated requirements can have later application dates, so confirm whether the assessed category is covered before adding them.
Operational implication
For releases from 20 January 2027, plan the Machinery Regulation file and the already-applicable RED file together. Track any later RED delegated requirement separately by product category.
Machinery authorities assess the machine against its machinery scope, EHSRs, conformity route, documentation, instructions, declaration, markings, and corrective-action duties.
Radio Equipment Directive
RED authorities can require corrective action for that presents a risk or is formally non-compliant, including bringing it into conformity, withdrawal, or recall as the Directive's conditions require.
Operational implication
A problem in a radio-enabled safety function can trigger both files. Coordinate the technical correction, stock and customer measures, authority notices, and revised declarations without assuming one authority response settles the other.
Machinery and RED can share product descriptions, drawings, software identifiers, risk controls, test configurations, standards registers, and corrective-action records.
Radio Equipment Directive
RED module evidence remains bounded by the assessed module configuration and integration conditions; the final radio-enabled machine may need additional assessment when the host changes radio, EMC, or safety performance.
Operational implication
Reuse facts and reports by reference, but record gaps for antenna, enclosure, power, software, simultaneous transmitters, environment, and safety-function integration.
Use Machinery for the complete machine's hazards, EHSRs, safety functions, instructions, conformity route, technical documentation, and machinery declaration.
Radio Equipment Directive
Use RED when the assessed product intentionally emits or receives radio waves. Internal production control is available only under the Article 17 conditions; otherwise Article 3(2) and 3(3) assessment requires EU-type examination or full quality assurance.
Operational implication
If the complete machine meets both definitions, neither file merely leads: complete both applicable assessments for the same release and show both legal bases in the declaration package.
Start with Machinery when the main question is whether the complete machine, related product, or partly completed machinery meets the Machinery Regulation's safety and documentation requirements.
Apply RED to the placed product that intentionally emits or receives radio waves; do not limit the RED assessment to a module when the complete machine is the placed on the market.
If both apply, complete both assessments, list both legal bases in the declaration package, and reuse records only when the law, product boundary, configuration, and claim are explicit.
Regulation (EU) 2023/1230 applies to machinery, listed related products, and partly completed machinery. Its manufacturer evidence is built around design and construction against the applicable essential health and safety requirements, conformity assessment, technical documentation, instructions, EU declaration of conformity, and CE marking.
RED applies to placed on the Union market, subject to its exclusions. Its essential requirements cover health and safety using the LVD safety objectives without a voltage limit, electromagnetic compatibility using the EMC Directive's essential requirements, and effective and efficient use of radio spectrum to avoid harmful interference. Additional Article 3(3) requirements apply only to categories or classes covered by a Commission measure.
Use the Machinery column for machine hazards, EHSR mapping, instructions, technical documentation, and machinery CE conformity.
Use the RED column when the assessed product intentionally transmits or receives radio waves for communication or radiodetermination; ordinary electronics with no intentional radio function do not enter RED on that fact alone.
Do not treat a CE mark, supplier declaration, wireless module certificate, or test report as automatically covering both regimes unless the evidence states which law and risk it supports.
Use the comparison to separate machinery EHSR evidence from radio-equipment scope and declaration evidence before release, supplier approval, or customer documentation review.
Keep a single evidence index if that is operationally easier, but tag each record by the law, hazard, product boundary, and conformity step it supports. A machinery risk assessment or EHSR matrix should not be relabelled as RED evidence unless it actually addresses the RED-side radio-equipment issue.
For a radio-enabled machine, keep a machinery risk assessment and EHSR matrix for the complete machine. The RED file for the placed should include the radio design, intended use, operating software, frequency bands, maximum radio-frequency power, risk assessment, standards, calculations and tests, instructions, EU declaration, and conformity route. Supplier module records are inputs; assess integration effects such as antenna, enclosure, power, host software, simultaneous transmitters, and intended operating environment.
Record whether the wireless element is a component inside the machinery, a safety component, partly completed machinery, or a separate radio-equipment item.
For machinery evidence, keep the EHSR matrix, risk assessment, instructions, technical documentation, conformity assessment route, EU declaration, and CE marking review together.
For RED evidence, record the assessed configuration, software and firmware versions, frequency bands, maximum transmitted power, antenna and host conditions, radio/EMC/safety tests, conformity route, and whether each supplier record covers the module, the complete product, or both.
Run both workstreams when the complete placed product meets both definitions. The Machinery Regulation excludes only its named electrical and electronic categories insofar as they fall within LVD or RED; it does not exclude every machine that contains a radio module. Article 9 allocates an EHSR risk to a more specific Union law only to the extent that law covers that risk.
That means the comparison should not end with a label. It should end with a boundary decision: which physical item is being assessed, which hazards belong to machinery EHSRs, which radio/EMC/safety claims are handled under radio-equipment work, and which documents can be reused without overstating their coverage.
If the wireless function is part of a safety function, keep the machinery safety analysis explicit before relying on radio-module evidence.
If the radio-enabled part is independently supplied, record whether it is being assessed as a component, safety component, partly completed machinery, or separate .
If one EU declaration covers both laws, list each legal act and keep the supporting assessments separately traceable.
If harmonised standards covering RED Article 3(2) or 3(3) are not applied, are only partly applied, or do not exist, use a RED conformity route that includes EU-type examination or full quality assurance rather than internal production control for those requirements.