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Start with the market-placement facts. The Directive applies to radio equipment made available on the Union market, and the Commission RED Guide says construction kits are covered when the assembled kit falls within RED scope and is intended to be made available on the EU market.

A development board is outside RED only if it fits the narrow Annex I evaluation-kit exclusion. The binding text requires a custom-built kit destined for professionals, for use solely at research and development facilities for R&D purposes. The RED Guide further describes custom-built status through a specific professional customer or joint R&D project and unique design characteristics suited to that project.

Do not call a board an evaluation kit just because it is unfinished, developer-focused, or sold with sample firmware. The RED Guide says all elements of the exemption must be met, including custom-built status, professional destination, sole use at R&D facilities, and R&D purpose.

The same guidance gives examples that do not benefit from the exemption: equipment used on a regular basis as laboratory equipment and generic evaluation equipment for users in R&D departments where the equipment is always the same and is not custom-built.

For a covered construction kit, keep the RED evidence that proves the instructed assembly can meet the applicable essential requirements. At minimum, the record should identify the assembled configuration, antenna assumptions, software or firmware, instructions, applicable standards or other specifications, test evidence, conformity assessment route, EU declaration position, labelling, and market restrictions.

For an excluded custom-built evaluation kit, keep a shorter but explicit scope record. It should show why the kit is custom-built, who the professional R&D recipient is, where it may be used, what it may be used for, and what event would end the exemption, such as regular supply, generic sale, resale, or use outside the specific R&D purpose.

Treating every developer board as exempt is a mistake. The exemption is limited to custom-built evaluation kits for professional R&D facility use; it is not a general exemption for prototypes, lab equipment, or engineering samples.

The second mistake is treating a kit as only a bundle of parts. If the assembled product is radio equipment and the kit is intended for the EU market, the instructions, supplied radio components, antenna choices, and intended assembly drive the RED assessment.

The common-charger amendment concerns the Annex Ia categories with a removable or embedded rechargeable battery. Within those categories, the USB-C interface and cable requirements apply when the equipment can be recharged by wired charging. The listed categories are handheld mobile phones, tablets, digital cameras, headphones, headsets, handheld videogame consoles, portable speakers, e-readers, keyboards, mice, portable navigation systems, earbuds, and laptops.

For Annex Ia points 1.1 to 1.12, Member States apply the common charger measures from 28 December 2024. For laptops, listed in point 1.13, the application date is 28 April 2026.

Digital cameras designed exclusively for the audiovisual sector or the security and surveillance sector are not meant to be covered by the common charger scope for digital cameras. Earbuds are assessed together with their dedicated charging case or box, because the case is part of how that product is used.

For in-scope wired-charging equipment, the design record should show the USB Type-C receptacle, cable compatibility, and whether the receptacle stays accessible and operational in the shipped configuration.

For equipment above 5 V, above 3 A, or above 15 W, keep a separate USB Power Delivery and additional-protocol review. Commission Delegated Regulation (EU) 2023/1717 updated the technical specification references to EN IEC 62680-1-3:2022 for USB Type-C and EN IEC 62680-1-2:2022 for USB Power Delivery.

If an economic operator offers in-scope radio equipment together with a charging device, it must also offer consumers and other end-users the possibility to acquire that equipment without any charging device.

The product must use the required pictogram to show whether a charging device is included. Manufacturers must include charging-capability and compatible-charger information in the instructions and display the required label. Importers and distributors must verify the required information and presentation before making the product available. For distance selling, the pictogram and label must be visible and legible close to the price indication.

The label states the minimum power required to charge the equipment and the maximum power required to reach the maximum charging speed, expressed in watts. It also shows 'USB PD' when the equipment supports USB Power Delivery. These values describe the radio equipment's charging needs; they are not a generic wattage claim for every adapter in the product family.

Keep evidence that lets a reviewer follow the decision without project history. Tie the product variant to the Annex Ia category, application date, wired-charging capability, USB-C and USB Power Delivery assessment, charger-in-box choice, consumer information, and retained source URLs.

Reopen the decision when hardware, firmware, charging protocol, supplier, packaging, marketplace listing, standard reference, category interpretation, or legal text changes.

Keep the EU declaration of conformity or simplified declaration, the Annex V technical documentation, the conformity assessment record under Article 17, proof of CE marking under Articles 19 and 20, and the product identification that links those records to the exact radio equipment type.

The EU declaration itself should follow the Annex VI structure: radio equipment identification, manufacturer or authorised representative details, statement that the declaration is issued under the manufacturer's sole responsibility, object of the declaration, Directive 2014/53/EU and other applicable Union harmonisation legislation, standards or technical specifications used, notified-body intervention where applicable, covered accessories, components, and software where applicable, and signature details.

Each item must be accompanied by either the full EU declaration or the simplified declaration in Annex VII. If the simplified form is used, reproduce the Annex VII wording and provide the exact internet address where the full EU declaration can be obtained; keep that full declaration available at the stated address.

Article 21 requires technical documentation to contain the relevant data or means used to ensure the radio equipment complies with the essential requirements. Annex V lists the minimum elements wherever applicable, so the record should be organized around those elements rather than around a generic compliance checklist.

The technical documentation should also make the DoC traceable. A reviewer should be able to match the declaration to the product identity, test reports, standards list, drawings, software or firmware versions that affect conformity, user information, installation instructions, and any Article 10(10) restriction information.

For RED products, the CE marking evidence should show that the mark was affixed before the radio equipment was placed on the market, was visible, legible, and indelible on the equipment or data plate where possible, and was also visible and legible on the packaging.

Not every RED file has the same notified-body evidence. A notified body is involved only when the selected conformity assessment route requires one. If harmonised standards are not applied, only partly applied, or do not exist for Article 3(2) or Article 3(3) requirements, Article 17 points to EU-type examination followed by conformity to type or full quality assurance for those essential requirements. If Annex IV full quality assurance is used, the notified-body identification number follows the CE marking.

Some RED products need additional records alongside the DoC and CE marking file because the declaration and technical documentation must cover the actual equipment configuration placed on the market.

For equipment covered by the common-charger amendment, keep the charging-capability specifications, compatible charging-device information, required label, and pictogram records with the same product file. For radio equipment covered by the Article 3(3)(d), (e), or (f) cybersecurity delegated act, keep the evidence showing how those activated essential requirements were assessed.

Before placing on the market, Article 12 of Directive 2014/53/EU requires an importer to confirm that the radio equipment is compliant. The importer does not redo the manufacturer's conformity assessment, but it must check that the appropriate Article 17 procedure has been carried out and that the radio equipment is constructed so it can be operated in at least one Member State without infringing applicable radio-spectrum requirements.

The importer must also check that the manufacturer has drawn up technical documentation, applied the CE marking, supplied the Article 10(8), 10(9), and 10(10) information and documents, and met the product-identification and manufacturer-contact duties in Article 10(6) and 10(7).

The importer has its own traceability duty. It must indicate its name, registered trade name or registered trade mark, and postal contact address on the radio equipment. Where that is not possible, the information may appear on the packaging or in a document accompanying the equipment, including cases where the importer would otherwise have to open the packaging.

The importer must also verify manufacturer traceability and user information. Article 12 points importers back to the manufacturer's type, batch, serial-number or equivalent identification, manufacturer name and postal address, instructions and safety information, EU declaration information, and restriction information.

Importer duties continue after placement. While radio equipment is under the importer's responsibility, storage or transport conditions must not jeopardise compliance with the Article 3 essential requirements.

When appropriate for the risks presented by the equipment, the importer must carry out sample testing, investigate complaints, keep a register of complaints, non-conforming radio equipment and recalls where necessary, and keep distributors informed of monitoring. If an importer has reason to believe equipment it placed on the market is non-compliant, it must immediately take corrective measures to bring the equipment into conformity, withdraw it, or recall it as appropriate.