Are RF modules covered by the Radio Equipment Directive?
Yes. The Commission RED Guide treats RF modules and components with an embedded as where they meet the RED definition and are placed on the EU market before integration into another product. The guide also treats an integrated circuit as radio equipment when it has the capacity to receive or transmit radio signals and is intended to be integrated into another product as a standalone radio function. This is Commission guidance on applying the Article 2 definition, not a separate certification category in the Directive.
Integration can create further obligations. The guide says its component analysis is without prejudice to new obligations that may arise when radio components are integrated into another product.
- Identify whether the item being bought, sold, or imported is an , a component with an embedded RF module, an integrated circuit with radio transmit or receive capability, or a finished .
- For a module placed on the EU market before integration, keep the module's RED conformity evidence and integration instructions, tied to its hardware, firmware, antenna, power, and operating limits.
- For the , run a final-product assessment instead of relying only on the module label, supplier declaration, or certificate.
Can a host manufacturer rely on a certified radio module without further RED work?
No. Module evidence is useful input, but the final placed on the EU market still needs its own RED assessment. The manufacturer may use assessments already performed for components or parts, while remaining responsible for the conformity of the whole product; the RED Guide states that reused component assessments may not be sufficient to demonstrate conformity of the whole radio equipment.
What should the module supplier provide?
For a radio module placed on the EU market before integration, keep the supplier's RED evidence, declaration information, test evidence, and instructions. The Commission guide says the module manufacturer should assess risks identifiable at the stage of placing the module on the EU market and provide instructions which, if followed, will ensure that the module remains compliant.
Primary RED source for the definition of radio equipment and the Article 3 essential requirements that apply to radio equipment.
Commission guidance identifying RF modules and embedded RF modules as radio equipment when placed on the EU market before integration, and warning that integration can create further obligations.