Artifact GuideEU

EU RED cybersecurity product categories

Commission Delegated Regulation (EU) 2022/30 activates RED Article 3(3)(d), (e), and (f) for defined categories of radio equipment, including internet-connected products, childcare equipment, toy radio equipment, wearables, and payment-capable internet-connected radio equipment.

Use this page to map a product to the correct cybersecurity, privacy, and fraud-protection category, check the exclusions, confirm the 1 August 2025 application date, and retain release evidence.

Author
Sorena AI
Published
May 9, 2026
Updated
May 27, 2026
Sections
4

Structured answer sets in this page tree.

Primary sources
5

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 27, 2026
Overview

The RED cybersecurity delegated act is not a blanket cyber rule for every electronic product. It applies Article 3(3)(d), (e), and (f) of Directive 2014/53/EU to specific categories of radio equipment. A useful product-category review starts with whether the item is radio equipment, then separately checks internet connectivity, personal-data or traffic/location-data processing, childcare or toy status, wearable design, payment-transfer functionality, and the listed sector carve-outs.

Section 1

Which product categories trigger Article 3(3)(d), (e), and (f)?

Delegated Regulation (EU) 2022/30 applies three different RED Article 3(3) points to different category triggers. Article 3(3)(d), the network-protection requirement, applies to radio equipment that can communicate over the internet, whether directly or through another device.

Article 3(3)(e), the personal-data and privacy requirement, applies only when the covered radio equipment can process personal data, traffic data, or location data. The covered categories are internet-connected radio equipment, radio equipment designed or intended exclusively for childcare, radio equipment covered by the Toy Safety Directive, and radio equipment designed or intended to be worn on, strapped to, or hung from the body or clothing.

Article 3(3)(f), the fraud-protection requirement, applies to internet-connected radio equipment that enables the holder or user to transfer money, monetary value, or virtual currency.

  • Use Article 3(3)(d) for internet-connected radio equipment, including products that reach the internet through other equipment.
  • Use Article 3(3)(e) only after confirming both a covered category and the ability to process personal data, traffic data, or location data.
  • Treat baby monitors and other exclusively childcare radio equipment as a separate Article 3(3)(e) category, even if they are not internet-connected.
  • Treat toy radio equipment covered by Directive 2009/48/EC and wearable radio equipment as Article 3(3)(e) categories when the data-processing condition is met.
  • Use Article 3(3)(f) for internet-connected radio equipment that enables transfers of money, monetary value, or virtual currency.
Section 2

What exclusions should be checked before scoping a product in?

The delegated act includes targeted exclusions, so a product-category decision should not stop at the first apparent match. Radio equipment covered by the Medical Devices Regulation or the In Vitro Diagnostic Medical Devices Regulation is excluded from the Article 3(3)(d), (e), and (f) requirements activated by Delegated Regulation (EU) 2022/30.

For Article 3(3)(e) and (f), the delegated act also excludes radio equipment covered by the civil aviation safety regulation, the motor vehicle general safety type-approval regulation, or the electronic road toll systems directive. Those exclusions do not erase RED generally; they narrow this delegated act's cybersecurity, privacy, and fraud category triggers.

  • Check Regulation (EU) 2017/745 and Regulation (EU) 2017/746 before applying Article 3(3)(d), (e), or (f) under this delegated act.
  • For Article 3(3)(e) and (f), also check Regulation (EU) 2018/1139, Regulation (EU) 2019/2144, and Directive (EU) 2019/520.
  • Record the exclusion analysis at product-family and variant level, because software, connectivity, payment, sensor, or market-positioning changes can alter the conclusion.
  • Do not use common-charger scope, CE-marking status, or generic IoT labels as substitutes for the delegated act category test.
Section 3

When do the cybersecurity category requirements apply?

Delegated Regulation (EU) 2022/30 originally deferred application so economic operators had time to adapt. Delegated Regulation (EU) 2023/2444 replaced the application sentence and now states that the delegated act applies from 1 August 2025.

Treat 1 August 2025 as the release-planning date for the Article 3(3)(d), (e), and (f) categories in this delegated act. Do not mix this date with the separate RED common-charger dates or with future Cyber Resilience Act milestones unless the product review explicitly compares those regimes.

  • Use 1 August 2025 for the Delegated Regulation (EU) 2022/30 cybersecurity category application date.
  • Keep the category decision, standards strategy, conformity assessment route, security test evidence, and EU declaration update aligned to that date.
  • Flag any product that is already in market but will continue to be made available after the application date for legal, regulatory, quality, and release-owner review.
  • Recheck the category decision when harmonised standards, product functions, payment flows, data processing, intended use, or exclusion status changes.
Section 4

What evidence should a product-category review retain?

The evidence should let a reviewer repeat the category decision without reconstructing the product history. For each product family and market variant, keep the radio-equipment basis, connectivity route, internet-communication analysis, data-processing analysis, intended-use claims, childcare or toy classification, wearable design assessment, payment-transfer analysis, exclusions checked, applicable Article 3(3) points, standards position, and conformity assessment route.

This page is a scope artifact, not a full security-control catalogue. The product file still needs the security design, test reports, standards mapping, supplier inputs, software-version evidence, EU declaration of conformity, and notified-body documentation where the chosen RED conformity assessment route requires it.

  • Keep a dated category matrix that separately answers Article 3(3)(d), (e), and (f), rather than one combined yes/no cybersecurity label.
  • Attach product specifications showing radio function, internet communication, sensors, microphones, cameras, location features, cloud paths, payment flows, and intended user group.
  • Keep the exclusion check with citations to the sector legislation considered and the reason it did or did not apply.
  • Tie the result to release gates for design, firmware, app, cloud service, packaging claims, instructions, supplier declarations, standards updates, and conformity assessment.
  • Reopen the record after material firmware, hardware, data-processing, payment, accessory, intended-use, supplier, market, or legal-source changes.
Recommended next step

Turn RED cybersecurity scope into release evidence

Use this RED category guide to align product, regulatory, security, quality, legal, and supplier teams around Article 3(3)(d), (e), and (f) scope, exclusions, application timing, standards strategy, and retained evidence.

Primary sources

References and citations

eur-lex.europa.eu
Referenced sections
  • Primary RED source for conformity assessment, EU declaration of conformity, CE marking, and technical documentation context.
"EU declaration of conformity"
single-market-economy.ec.europa.eu
Referenced sections
  • Commission RED overview noting the delegated act activation of Article 3(3)(d), (e), and (f) for certain categories of radio equipment.
"activating Articles 3(3)(d), (e) and (f)"
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