RED FAQ Radio kits

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 different only if it fits the narrow Annex I evaluation-kit exclusion. The RED Guide describes this as a custom-built kit for a specific professional R&D customer or joint R&D project, with unique design characteristics that make it solely suitable for 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 file 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.

The biggest mistake is treating every developer board as exempt. The exemption is not a general prototype, lab, or engineering-sample safe harbour; it is limited to custom-built evaluation kits for professional R&D facility use.

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.