RED FAQ Radio Modules

Yes. The Commission RED Guide treats RF modules and components with an embedded RF module as radio equipment 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.

Start with the final product and intended market placement. If the host product is radio equipment because it intentionally emits or receives radio waves for radio communication or radiodetermination, map the final product to the applicable Article 3 requirements, not just to the module test report.

Article 17 requires conformity assessment to take into account all intended operating conditions. For Article 3(1)(a), the assessment also takes reasonably foreseeable conditions of use into account. The RED Guide adds that where radio equipment can take different configurations, the conformity assessment should confirm compliance in all possible configurations.

The technical documentation should let a reviewer connect the module evidence to the exact final radio equipment. Annex V requires a general product description, relevant photos or illustrations, marking and internal layout, software or firmware versions affecting compliance, user information, installation instructions, drawings, standards or other technical specifications, the EU declaration, and test or examination results where applicable.

When the host manufacturer reuses assessments performed for components or parts, the RED Guide says those assessments should be included in the technical documentation. The record should also explain why the host configuration stays inside the module supplier's conditions, or what added analysis or testing covers deviations.

Instructions matter because they define how the radio equipment is intended to be used. Article 10(8) requires instructions and safety information in a language easily understood by consumers and other end-users as determined by the Member State concerned. For intentional transmitters, the instructions also need frequency bands and maximum transmitted radio-frequency power information.

For accessories, components, and software that allow the radio equipment to operate as intended, the RED Guide focuses on items that influence conformity and are intended to be installed or changed by the user without the manufacturer's control. If the equipment is delivered without an antenna, the guide says the technical features of the antenna that may be used with the radio equipment should be provided to the user and mentioned in the DoC where needed.

Reopen the assessment when the product facts no longer match the evidence. A module test report or certificate is strongest when the host uses the same radio configuration, antenna conditions, software assumptions, installation limits, and intended environment that were assessed.

A change does not automatically mean the product fails, but it does need a documented review. The record should decide whether existing module and host evidence remains sufficient, whether additional testing or analysis is needed, whether a notified body route is triggered, and whether the DoC, instructions, labels, or technical documentation must be updated.