Artifact GuideEU

RED Article 3 Essential requirements

Article 3 of Directive 2014/53/EU is the core requirements map for radio equipment: Article 3(1) covers health, safety, property protection, and EMC; Article 3(2) covers effective and efficient spectrum use; Article 3(3) adds specific feature-based requirements when the relevant category or class has been activated.

This page helps separate always-applicable RED requirements from conditional Article 3(3) duties, then capture the standards, tests, notified-body route, and technical-file evidence for each decision.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 26, 2026
Overview

RED Article 3 sets the that the manufacturer must map to the exact radio equipment, intended and reasonably foreseeable use, software, accessories, charging features, radio interfaces, and every marketed configuration. Apply Article 3(1)(a), 3(1)(b), and 3(2) as the baseline, then add only the Article 3(3) points activated for the category and Article 3(4) charging specifications that apply.

Section 1

What Article 3 requires

Article 3(1)(a) requires protection of health and safety of persons, domestic animals, and property, including the safety objectives of the Low Voltage Directive but without applying a voltage limit. Article 3(1)(b) requires an adequate level of electromagnetic compatibility by reference to the EMC Directive.

Article 3(2) requires radio equipment to be constructed so that it both effectively uses and supports efficient use of radio spectrum to avoid harmful interference. Evidence should cover transmitter behaviour and receiver performance where the product has a receiver; passive receiver functions are not exempt merely because they do not transmit.

Article 3(3) is conditional. It lists additional requirements for interworking, network protection, personal-data and privacy safeguards, fraud protection, emergency access, accessibility, and compliant software loading, but each point depends on the categories or classes specified by Commission acts.

  • Treat Article 3(1)(a), Article 3(1)(b), and Article 3(2) as separate baseline rows for in-scope radio equipment.
  • Check Article 3(3) point by point instead of assuming every listed feature applies to every radio product.
  • Keep common-charger requirements distinct: Directive (EU) 2022/2380 amended Article 3(3)(a) and added Article 3(4) plus Annex Ia for specified rechargeable categories.
Section 2

How to map Article 3(1) and Article 3(2)

For Article 3(1)(a), assess all intended operating conditions and reasonably foreseeable conditions of use. Do not limit the analysis to electrical voltage bands: RED imports the Low Voltage Directive safety objectives without its voltage limits. Depending on the product, evidence may need to address electrical, thermal, mechanical, chemical, fire, battery, acoustic, and radio-frequency exposure risks.

For Article 3(1)(b), document the EMC route, standards or other specifications used, immunity and emissions evidence, operating modes, ports, cables, accessories, and installation conditions for the radio equipment configuration being declared. EMC evidence does not replace Article 3(2) spectrum evidence.

For Article 3(2), document the radio technology, operating bands, transmitter emissions, receiver performance, intended installation and antenna conditions, and spectrum standards used. If a cited harmonised standard is not applied, is only partly applied, does not cover the configuration, or does not exist, Article 17 removes internal production control for the affected Article 3(2) requirement; use Annex III EU-type examination plus conformity to type or Annex IV full quality assurance.

  • List each radio function separately, including Wi-Fi, Bluetooth, cellular, GNSS receiver, RFID, short-range device, or satellite radio functionality.
  • Tie every applied harmonised standard to the Article 3 requirement it covers and to the exact product variant, firmware version, accessories, and antenna configuration tested.
  • Record why any non-OJEU, draft, legacy, partial, or alternative specification is sufficient, and route the decision through the applicable conformity-assessment procedure.
Section 3

How to handle Article 3(3) feature requirements

Review Article 3(3) as a conditional trigger table. Its points cover interworking with accessories other than the charging devices covered by Article 3(4), interworking through networks, connection to appropriate interfaces throughout the Union, protection of networks and service, personal data and privacy, fraud protection, emergency-service access, accessibility, and software loading only where compliance of the equipment-software combination has been demonstrated. A Commission delegated act must specify the categories or classes concerned by each point; the list alone does not activate every point for every product.

For cybersecurity, Delegated Regulation (EU) 2022/30 activates Article 3(3)(d), (e), and (f) for specified categories. Article 3(3)(d) applies to internet-connected radio equipment. Article 3(3)(e) applies to listed equipment capable of processing personal data, traffic data, or location data, including internet-connected radio equipment, childcare radio equipment, toy radio equipment, and wearable radio equipment. Article 3(3)(f) applies to internet-connected radio equipment that enables transfer of money, monetary value, or virtual currency.

Delegated Regulation (EU) 2023/2444 amended the application date for the 2022/30 cyber requirements to 1 August 2025. Commission Implementing Decision (EU) 2025/138 cites EN 18031-1:2024 for point (d), EN 18031-2:2024 for point (e), and EN 18031-3:2024 for point (f), but each citation carries notices that restrict presumption of conformity. Do not use the earlier 1 August 2024 date or treat an EN 18031 report as complete coverage without checking those notices. Delegated Regulation (EU) 2026/339 repeals Delegated Regulation (EU) 2022/30 from 11 December 2027 while preserving RED surveillance for covered equipment placed on the market from 1 August 2025 through 10 December 2027.

  • Create a yes/no/not-yet-activated row for Article 3(3)(a) through Article 3(3)(i), with the product facts and delegated or implementing act that makes the point applicable or supports the conclusion that it is not activated.
  • For cyber rows, identify internet connectivity, data processing, childcare, toy, wearable, payment, and exclusion facts before selecting controls or standards.
  • For software-loaded radio equipment, document intended combinations, version identifiers, update paths, and evidence that the combination remains compliant with applicable Article 3 requirements.
Section 4

Evidence to keep in the technical file

The technical documentation should let a reviewer trace every Article 3 conclusion from product facts to standards, tests, risk assessments, conformity-assessment outputs, and the EU declaration of conformity. Prepare it before market placement and update it when design, manufacturing, standards, software, or product characteristics change.

For Article 3(1), retain safety, health, exposure, property-protection, and EMC evidence. For Article 3(2), retain spectrum-use evidence, including transmitter and receiver performance as relevant. For Article 3(3), retain the trigger analysis and the feature-specific evidence for only the points that apply.

When relying on harmonised standards, confirm that the cited parts are published for RED in the Official Journal and cover the exact essential requirement. A standard, test report, or supplier statement that does not map to the applicable Article 3 point is not enough by itself.

  • Keep a dated Article 3 matrix with columns for requirement, applicability, source, standard or specification, test evidence, owner, open issues, and review trigger.
  • Attach EU-type examination certificates, certificate additions, or quality-system approvals where the chosen conformity-assessment route produces those outputs.
  • Reopen the matrix after radio design, firmware, antenna, accessory, charger, installation, intended-use, data-processing, payment, market, harmonised-standard, delegated-act, complaint, incident, or authority-feedback changes.
  • If a change affects an approved type or the conditions of a notified-body certificate, inform the notified body and obtain any required additional approval before relying on the certificate for the changed equipment.
Recommended next step

Turn Article 3 into a release-ready evidence map

Use Sorena to map RED Article 3 requirements to product facts, standards, tests, supplier evidence, notified-body routes, and technical-file records before EU market placement.

Primary sources

References and citations

eur-lex.europa.eu5 citations
Referenced sections
  • Binding RED source for Article 3 essential requirements, conformity assessment, technical documentation, EU declaration, and CE marking.
  • Binding RED source for Article 3(1), Article 3(2), Article 3(3), conformity assessment, technical documentation, EU declaration, and CE marking.
  • Binding source for Article 3(1), Article 3(2), harmonised-standard presumption of conformity, and Article 17 conformity assessment.
Show 2 more
  • Binding RED source for the Article 3(3)(a) through Article 3(3)(i) additional essential requirements.
  • Binding source for technical documentation, harmonised-standard presumption of conformity, conformity assessment, and EU declaration obligations.
"Essential requirements"
More quoted passages
"Radio equipment shall be so constructed"
"technical documentation shall contain all relevant data"
eur-lex.europa.eu2 citations
Referenced sections
  • Delegated source specifying categories and classes subject to Article 3(3)(d), (e), and (f).
  • Delegated source specifying the categories or classes of radio equipment subject to Article 3(3)(d), (e), and (f).
"internet-connected radio equipment"
eur-lex.europa.eu2 citations
Referenced sections
  • Repeals Delegated Regulation (EU) 2022/30 from 11 December 2027 and preserves surveillance of covered equipment placed on the market during the RED cybersecurity period.
  • Binding source for repeal from 11 December 2027 and continued RED surveillance of covered equipment placed on the market from 1 August 2025 through 10 December 2027.
"10 December 2027"
More quoted passages
"repealed with effect from 11 December 2027"
eur-lex.europa.eu2 citations
Referenced sections
  • Binding amendment relevant to common-charger changes to RED Article 3 and Annex Ia.
  • Binding amendment that moved common-charger obligations into Article 3(4), Article 3a, Article 10(8), and Annex Ia for specified radio equipment categories.
"Article 3 is amended"
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