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FAQEU

RED FAQ Radio kits

Radio construction kits generally need a RED compliance path when the instructed assembly is . Annex I separately excludes qualifying amateur-radio kits and custom-built evaluation kits for professional facilities.

This FAQ helps separate covered construction kits from exempt evaluation boards and to document the facts, restrictions, and evidence behind the decision.

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Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
4 sections3 primary sources
Overview

A radio kit is not automatically outside the Directive. If a , when assembled according to its instructions, falls within the RED and is intended to be , the kit manufacturer is responsible for compliance for that instructed assembly. Treat an evaluation board as potentially exempt only when it is custom-built, destined for professionals, used solely at research and development facilities, and used for purposes.

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4 of 4 questions
Question 1

Are radio kits and evaluation boards covered by the RED?

Start with the market-placement facts. The Directive applies to 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 .

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 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.

  • Covered: a repeatable radio marketed or supplied for assembly into .
  • Potentially excluded: a for professional use solely at facilities and for R&D purposes.
  • Annex I treats radio kits for assembly and use by radio amateurs as not being made available on the market. Confirm that the kit fits that specific category rather than treating all hobby or developer kits as excluded.

Are radio kits and evaluation boards covered by the RED?

Usually yes for marketable construction kits: if the kit, when assembled according to its instructions, is and is intended to be , the RED compliance path belongs in the product file. An evaluation board is outside RED scope only if it meets the specific Annex I custom-built professional evaluation-kit conditions.

Can a radio amateur kit be treated as outside the RED?

Annex I expressly treats radio kits for assembly and use by radio amateurs as not being made available on the market. Confirm the intended assembly and amateur-radio use. For transfers of other amateur-, the RED Guide calls for a case-by-case assessment of regularity, product characteristics, supplier intentions, and any business context.

Question 2

How to test the evaluation-kit exclusion

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 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 departments where the equipment is always the same and is not custom-built.

  • Identify the specific customer or joint project that requested the board.
  • Show which unique design characteristics make the board suitable only for that project.
  • Restrict supply and documentation to professional facility use, not general development, training, resale, production testing, or conformity testing.
Question 3

What evidence should be kept for radio kits?

For a covered , 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 , keep a shorter but explicit scope record. It should show why the kit is custom-built, who the professional 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.

  • Record whether the kit is supplied commercially, free of charge, occasionally, or only under a project-specific arrangement.
  • Keep the assembly instructions and the compliance assumptions together; the kit manufacturer remains responsible when the kit is assembled according to those instructions.
  • Reopen the file if the board becomes a standard catalogue item, the firmware or radio module changes, the antenna options change, or the intended user group expands.
Recommended next step

Turn the kit decision into a RED scope memo

Document whether the board is a covered construction kit, a qualifying amateur-radio kit under Annex I, or a custom-built professional R&D evaluation kit, then attach the evidence and review triggers.

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Question 4

Common mistakes to avoid with RED kit decisions

Treating every developer board as exempt is a mistake. The exemption is limited to custom-built evaluation kits for professional 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 and the kit is intended for the EU market, the instructions, supplied radio components, antenna choices, and intended assembly drive the RED assessment.

  • Do not rely on an internal label such as prototype, engineering sample, or evaluation kit unless the RED Annex I facts are documented.
  • Do not use a radio module certificate as the full kit conclusion; it may be useful evidence, but the assembled configuration still needs its own assessment.
  • Do not demonstrate non-compliant at events unless the required visible notice and interference, disturbance, health, and safety measures are in place.
Primary sources

References and citations

Directive 2014/53/EU on radio equipment
eur-lex.europa.eu5 citations
Referenced sections
  • Binding RED source for market availability, essential requirements, conformity assessment, event display conditions, and Annex I kit exclusions.
  • Binding RED source for market availability, Annex I amateur-radio kit exclusions, and the custom-built evaluation-kit exclusion.
  • Binding RED source for the Annex I exclusion for custom-built evaluation kits destined for professional R&D facilities.
Show 2 more
  • Binding RED source for market availability, essential requirements, conformity assessment, EU declaration, technical documentation, and CE marking.
  • Binding RED source for free movement, event display conditions, market availability, and Annex I exclusions.
"radio kits for assembly and use by radio amateurs"
More quoted passages
"Custom-built evaluation kits destined for professionals"
"used solely at research and development facilities"
"making available on the market"
"visible sign clearly indicates"
European Commission - RED guide
ec.europa.eu5 citations
Referenced sections
  • Commission guidance for applying RED scope to custom-built evaluation kits, construction kits, radio components, and trade-fair demonstrations.
  • Commission guidance for applying the RED to custom-built evaluation kits, construction kits, radio components, and demonstrations.
  • Commission guidance explaining the custom-built evaluation-kit elements and examples that do not qualify.
Show 2 more
  • Commission guidance on construction kits, custom-built evaluation kits, and use of component assessments in technical documentation.
  • Commission guidance on trade-fair demonstrations, construction kits, custom-built evaluation kits, and component evidence limits.
"Custom-built evaluation kits"
More quoted passages
"Construction kits that when assembled fall within the scope"
"only if the products fulfil all the elements"
"The kit manufacturer is responsible for compliance"
"supply is regular or there is a business related context"
European Commission - harmonised standards for radio equipment
single-market-economy.ec.europa.eu2 citations
Referenced sections
  • Commission source for the RED harmonised standards references used to plan standards and test evidence for covered kits.
  • Commission source for RED harmonised standards references used when building the standards and test evidence plan.
"harmonised standards for radio equipment"

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