---
title: "RED standards not cited in the OJEU: can you use them?"
canonical_url: "https://www.sorena.io/artifacts/eu/radio-equipment-directive/faq/standards-not-cited-in-ojeu"
source_url: "https://www.sorena.io/artifacts/eu/radio-equipment-directive/faq/standards-not-cited-in-ojeu"
author: "Sorena AI"
description: "FAQ answer for Radio Equipment Directive products when a standard is useful but not OJEU-cited, including presumption of conformity, Article 17 route selection, and technical-file evidence."
published_at: "2026-05-09"
updated_at: "2026-05-09"
keywords:
  - "RED standards not cited in OJEU"
  - "Radio Equipment Directive harmonised standards"
  - "RED presumption of conformity"
  - "RED Article 17 notified body"
  - "EU Radio Equipment Directive"
  - "RED"
  - "OJEU"
  - "Harmonised standards"
---
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---

# RED standards not cited in the OJEU: can you use them?

FAQ answer for Radio Equipment Directive products when a standard is useful but not OJEU-cited, including presumption of conformity, Article 17 route selection, and technical-file evidence.

*FAQ* *EU*

## RED standards not cited in the OJEU

Under the Radio Equipment Directive, presumption of conformity comes from harmonised standards or parts of standards whose references have been published in the Official Journal of the European Union.

This FAQ explains how to use an uncited standard as technical evidence without overstating the legal effect of that standard.

A standard that is relevant to radio equipment can still be useful engineering evidence, but if its reference is not published in the OJEU for the applicable RED requirement, it does not by itself give presumption of conformity. The compliance file should show which Article 3 essential requirement is being assessed, whether any OJEU-cited harmonised standard covers it, what evidence is used for any remaining gap, and whether Article 17 requires a notified-body route for Article 3(2) or Article 3(3).

## Short answer: can you use a RED standard that is not OJEU-cited?

Yes, but use it carefully. An uncited standard, a draft standard, a withdrawn standard, or a standard cited for a different scope can support the technical rationale, test plan, or design file. It should not be described as giving RED presumption of conformity unless the relevant reference, or relevant part of the reference, has been published in the Official Journal for the essential requirement you are claiming.

For RED, the practical consequence is route selection. Article 17 allows internal production control for some Article 3(1) assessments, but for Article 3(2) and Article 3(3), where OJEU-cited harmonised standards have not been applied, have only been applied in part, or do not exist, the equipment must be submitted to EU-type examination followed by conformity to type or to full quality assurance for those essential requirements.

- Separate the standard's engineering value from its legal effect under RED.
- Check the exact OJEU reference, version, date range, restrictions, and the Article 3 requirement covered.
- Do not copy an old declaration, certificate, or supplier claim that cites a non-current or differently scoped standard without explaining the gap.
- If the gap affects Article 3(2) spectrum use or Article 3(3) activated requirements, document the Article 17 route decision before release.
- Keep the uncited standard, test reports, design rationale, risk analysis, and any notified-body records in the technical documentation.

Sources for this answer:

- [Directive 2014/53/EU on radio equipment](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A32014L0053&ref=sorena.io) - Article 16 ties RED presumption of conformity to harmonised standards whose references are published in the OJEU, and Article 17 sets the conformity-assessment route when OJEU-cited standards are not applied for Article 3(2) or Article 3(3).
- [European Commission - radio equipment harmonised standards](https://single-market-economy.ec.europa.eu/single-market/goods/european-standards/harmonised-standards/radio-equipment_en?ref=sorena.io) - Commission RED standards page identifying the OJEU publication source and explaining that its summary list is informational, not itself legally effective.
- [Commission Implementing Decision (EU) 2022/2191 on RED harmonised standards](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L%5F2022.289.01.0007.01.ENG&toc=OJ%3AL%3A2022%3A289%3ATOC&ref=sorena.io) - OJEU implementing decision listing harmonised standards for radio equipment and notices where only limited or conditional presumption of conformity is available.

## How to document the OJEU citation gap

Start with the requirement, not with the standard number. Identify whether the point is Article 3(1)(a) safety, Article 3(1)(b) EMC, Article 3(2) efficient spectrum use, or an activated Article 3(3) requirement. Then map each requirement to the OJEU-cited standard used, the parts applied, and any missing coverage.

Where the cited standard has a notice or restriction, treat the restriction as part of the record. A standard may be listed while still not conferring presumption for a particular clause, parameter, test condition, antenna configuration, receiver parameter, or other limited point. The technical file should explain how that excluded point is assessed.

- Record the exact standard reference and version used by engineering, the OJEU reference checked, and the date of the check.
- Say whether the standard is not cited, cited for another requirement, cited with limitations, withdrawn, or applied only in part.
- For each gap, attach the alternative evidence: test report, design review, calculations, supplier module data, risk analysis, or notified-body certificate.
- Keep a clean distinction between Article 3(1), Article 3(2), and Article 3(3) because Article 17 treats missing harmonised standards differently for those requirements.
- Update the standards list when the product, firmware, radio module, antenna, intended use, or OJEU citation status changes.

Sources for this answer:

- [Directive 2014/53/EU on radio equipment](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A32014L0053&ref=sorena.io) - Article 3 defines the essential requirements that the standards map must cover, while Article 21 requires technical documentation to contain the means used to ensure compliance.
- [Commission Implementing Decision (EU) 2022/2191 on RED harmonised standards](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L%5F2022.289.01.0007.01.ENG&toc=OJ%3AL%3A2022%3A289%3ATOC&ref=sorena.io) - Shows that RED harmonised-standard citations can include notices limiting the presumption of conformity for specific clauses, tests, or parameters.
- [European Commission - radio equipment harmonised standards](https://single-market-economy.ec.europa.eu/single-market/goods/european-standards/harmonised-standards/radio-equipment_en?ref=sorena.io) - Commission page for RED OJEU publications, amendments, RSS feed, and summary list context used to check current harmonised-standard references.

## When the notified-body route becomes relevant

For Article 3(2) and Article 3(3), Article 17 is explicit: if the manufacturer has not applied OJEU-cited harmonised standards, has applied them only in part, or no such standards exist, the equipment is submitted to either EU-type examination followed by conformity to type or full quality assurance for those essential requirements.

This does not mean every uncited standard automatically forces the same route. The route depends on which essential requirement the gap concerns and whether an OJEU-cited harmonised standard fully covers the relevant requirement for the exact equipment. The record should identify the gap before choosing the route.

- Use internal production control only where the selected Article 17 path allows it for the requirements being assessed.
- Escalate Article 3(2) spectrum-use gaps early because they commonly affect radio test planning and market release evidence.
- Escalate Article 3(3) gaps where a delegated act has activated the requirement for the product category or class.
- Keep the notified-body certificate, annexes, scope, and any conditions with the RED technical documentation when EU-type examination is used.
- If Annex IV full quality assurance is used, keep evidence for the notified-body identification number that follows the CE marking.

Sources for this answer:

- [Directive 2014/53/EU on radio equipment](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A32014L0053&ref=sorena.io) - Article 17 specifies the RED conformity-assessment procedures and the notified-body-triggering conditions for Article 3(2) and Article 3(3) when harmonised standards are missing, partial, or not applied.
- [Commission Notice - Blue Guide on EU product rules (2022)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A52022XC0629%2804%29&ref=sorena.io) - General EU product-law guidance supporting manufacturer responsibility for choosing and documenting the applicable conformity assessment before CE marking.

## Common wording mistakes in declarations and reports

The risky wording is usually not the use of the standard; it is the claim attached to it. A file can say that an uncited standard informed the test method or design rationale. It should not say that the product is presumed compliant under RED because of that standard unless the relevant OJEU citation supports that claim.

Supplier radio-module reports can be especially easy to overread. They may support part of the assessment, but the finished equipment file still needs to cover the actual host product, antenna configuration, software, intended use, instructions, and any Article 3 requirement not covered by the supplier evidence.

- Avoid: presumed compliant with RED based on EN X, when EN X is not OJEU-cited for the claimed requirement.
- Use instead: EN X was used as supporting technical evidence; presumption of conformity is claimed only for the OJEU-cited standards and parts listed in the standards matrix.
- Avoid: all RED requirements covered by module test report, unless the report covers the finished equipment configuration and every applicable Article 3 requirement.
- Use instead: module evidence supports the listed radio characteristics; the host product file separately addresses integration, antenna, software, instructions, and remaining essential requirements.
- Avoid: standards list current, unless the record names the OJEU source checked and preserves the citation status behind the release decision.

Sources for this answer:

- [Directive 2014/53/EU on radio equipment](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A32014L0053&ref=sorena.io) - Article 10 requires manufacturers to ensure radio equipment is designed and manufactured according to Article 3, draw up technical documentation, perform conformity assessment, and keep records that demonstrate conformity.
- [European Commission - radio equipment harmonised standards](https://single-market-economy.ec.europa.eu/single-market/goods/european-standards/harmonised-standards/radio-equipment_en?ref=sorena.io) - Commission source for checking RED OJEU publication status instead of relying on a supplier or legacy standards list alone.

## Primary sources

- [Directive 2014/53/EU on radio equipment](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A32014L0053&ref=sorena.io) - Primary RED source for Article 3 essential requirements, Article 16 presumption of conformity, Article 17 conformity assessment routes, Article 21 technical documentation, and CE marking responsibilities.
  - Quote: "references of which have been published in the Official Journal"
- [European Commission - radio equipment harmonised standards](https://single-market-economy.ec.europa.eu/single-market/goods/european-standards/harmonised-standards/radio-equipment_en?ref=sorena.io) - Commission RED harmonised-standards page listing OJEU publications, amendments, RSS feed, and the status of the summary list used to check current references.
  - Quote: "The summary below consolidates the references"
- [Commission Implementing Decision (EU) 2022/2191 on RED harmonised standards](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L%5F2022.289.01.0007.01.ENG&toc=OJ%3AL%3A2022%3A289%3ATOC&ref=sorena.io) - OJEU decision publishing RED harmonised-standard references and notices that limit presumption of conformity for specific standards or clauses.
  - Quote: "shall not confer a presumption of conformity"
- [Commission Notice - Blue Guide on EU product rules (2022)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A52022XC0629%2804%29&ref=sorena.io) - General EU product-law guidance for manufacturer responsibility, conformity assessment, CE marking, and technical documentation concepts used alongside RED-specific rules.
  - Quote: "The manufacturer is responsible for the conformity assessment."

## Topic Guides

- [Are radio kits and evaluation boards covered by the RED? | RED FAQ](/artifacts/eu/radio-equipment-directive/faq/kits.md): RED FAQ for radio kits, construction kits, amateur-radio kits, and custom-built professional R&D evaluation boards under Directive 2014/53/EU.
- [EU Radio Equipment Directive Timeline: practical guide](/artifacts/eu/radio-equipment-directive/timeline.md): EU Radio Equipment Directive guide to Timeline with scope decisions, owner actions, evidence records, source-linked citations, and practical next steps.
- [EU RED Applicability Test for Radio Equipment](/artifacts/eu/radio-equipment-directive/applicability-test.md): Decide whether Directive 2014/53/EU applies to a connected product, which RED requirements are triggered, and what evidence belongs in the technical file.
- [EU RED Common Charger FAQ: Which devices need USB-C?](/artifacts/eu/radio-equipment-directive/faq/common-charger.md): FAQ on EU RED common charger scope, 28 December 2024 and 28 April 2026 dates, USB-C, USB Power Delivery, charger unbundling, labels, pictograms, and evidence.
- [EU RED Common Charger Obligations: USB-C scope, dates, labels](/artifacts/eu/radio-equipment-directive/common-charger-obligations.md): source-linked RED common charger guide covering in-scope device categories, 28 December 2024 and 28 April 2026 dates, USB-C, USB PD, charger unbundling, labels, pictograms, and evidence.
- [EU RED compliance evidence guide](/artifacts/eu/radio-equipment-directive/compliance.md): Build a Radio Equipment Directive compliance file with Article 3 requirement mapping, harmonised-standard checks, conformity assessment evidence, EU declarations, CE marking, and RED source links.
- [EU RED Cybersecurity Product Categories: 2022/30 scope](/artifacts/eu/radio-equipment-directive/cybersecurity-delegated-act-product-categories.md): source-linked guide to RED Delegated Regulation (EU) 2022/30 product categories for Article 3(3)(d), (e), and (f), carve-outs, 1 August 2025 application, and release evidence.
- [EU RED FAQ: Scope, CE and USB-C](/artifacts/eu/radio-equipment-directive/faq.md): Answers to common EU RED questions on radio equipment scope, Article 3 requirements, cybersecurity, USB-C common charger rules, CE marking, and technical-file evidence.
- [EU RED Radio Equipment Scope: products and exclusions](/artifacts/eu/radio-equipment-directive/radio-equipment-scope.md): Decide whether a product is radio equipment under Directive 2014/53/EU, with RED scope tests, exclusions, examples, and evidence records.
- [EU RED Requirements Map: CE and Article 3](/artifacts/eu/radio-equipment-directive/requirements.md): Map Radio Equipment Directive requirements for radio products: Article 3 safety, EMC, spectrum, selected Article 3(3) duties, common charger rules, conformity assessment, CE marking, EU declaration, and technical documentation.
- [EU RED Scope and Classification](/artifacts/eu/radio-equipment-directive/scope-and-classification.md): Classify products under the EU Radio Equipment Directive with source-linked tests for radio equipment scope, exclusions, Article 3 requirement buckets, cybersecurity, common charging, and evidence records.
- [EU RED Scope Classification Workflow](/artifacts/eu/radio-equipment-directive/red-scope-classification-workflow.md): Classify products under the EU Radio Equipment Directive with a source-linked workflow for RED scope, exclusions, Article 3 requirements, standards, CE evidence, cybersecurity, and common-charger triggers.
- [RED Article 10 labelling, instructions, and restrictions](/artifacts/eu/radio-equipment-directive/article-10-labelling-and-restrictions.md): source-linked RED Article 10 guide for radio equipment labels, manufacturer contact details, instructions, DoC statements, frequency information, and use restrictions.
- [RED Article 3 requirement selection workflow](/artifacts/eu/radio-equipment-directive/article-3-requirement-selection-workflow.md): Select the right RED Article 3 branches for radio equipment: safety, EMC, spectrum, delegated Article 3(3) duties, cybersecurity, common charging, evidence, and conformity assessment.
- [RED Article 3 Requirements: Safety, EMC, Spectrum and Cyber](/artifacts/eu/radio-equipment-directive/article-3-1-3-2-and-3-3-requirements.md): Map Radio Equipment Directive Article 3(1), 3(2), and 3(3) requirements to safety, EMC, spectrum, interoperability, emergency, software, and cyber evidence.
- [RED Compliance Checklist for Radio Equipment](/artifacts/eu/radio-equipment-directive/checklist.md): source-linked RED checklist for radio equipment scope, Article 3 requirements, technical documentation, DoC, CE marking, cybersecurity, common charger, and notified-body decisions.
- [RED compliance deadlines calendar: 2016, 2024, 2025 and 2026 dates](/artifacts/eu/radio-equipment-directive/deadlines-and-compliance-calendar.md): Calendar the EU Radio Equipment Directive deadlines that affect launches: RED applicability, transition end, common charger dates, cybersecurity requirements, OJEU standards, CE marking, declarations and technical files.
- [RED conformity assessment and CE marking](/artifacts/eu/radio-equipment-directive/conformity-assessment-and-ce.md): EU Radio Equipment Directive guide to Article 17 conformity modules, notified-body triggers, technical documentation, EU declarations, and CE marking.
- [RED Conformity Assessment Template](/artifacts/eu/radio-equipment-directive/red-conformity-assessment-template.md): Template fields for documenting RED Article 3 requirements, Article 17 route selection, harmonised standards, notified-body evidence, technical documentation, EU declaration, CE marking, cybersecurity, and common-charger checks.
- [RED Cyber Compliance Workflow for Article 3(3)(d/e/f)](/artifacts/eu/radio-equipment-directive/cyber-compliance-workflow.md): A source-linked RED cybersecurity workflow for internet-connected radio equipment, privacy and data safeguards, payment-fraud features, evidence packs, and CE release gates.
- [RED Cybersecurity Delegated Act Guide | Article 3(3)(d/e/f)](/artifacts/eu/radio-equipment-directive/red-cybersecurity-delegated-act-guide.md): Practical guide to Delegated Regulation (EU) 2022/30 under the Radio Equipment Directive, covering Article 3(3)(d), (e), and (f) cybersecurity scope, 1 August 2025 application, evidence, standards, and notified-body checkpoints.
- [RED Cybersecurity Requirements for Radio Equipment](/artifacts/eu/radio-equipment-directive/cybersecurity-requirements.md): EU RED cybersecurity requirements under Article 3(3)(d), (e), and (f): scope, affected radio equipment, application date, standards, notified bodies, and evidence.
- [RED DoC and CE marking file: what to include](/artifacts/eu/radio-equipment-directive/faq/doc-and-ce.md): FAQ answer for Radio Equipment Directive declarations of conformity, CE marking evidence, technical documentation, notified-body records, and related labels.
- [RED EMC and LVD Safety Interplay for Radio Equipment](/artifacts/eu/radio-equipment-directive/emc-and-lvd-safety-interplay.md): Explain how EU RED Article 3 applies LVD safety objectives and EMC requirements to radio equipment, with evidence, test-plan, and technical-file guidance.
- [RED Harmonised Standards and Test Plans: OJEU evidence guide](/artifacts/eu/radio-equipment-directive/harmonized-standards-and-test-plans.md): Build a Radio Equipment Directive standards matrix and test plan around OJEU-cited harmonised standards, Article 3 requirements, Article 17 route triggers, and Annex V technical-file evidence.
- [RED importer obligations FAQ | Directive 2014/53/EU](/artifacts/eu/radio-equipment-directive/faq/importers.md): What importers must check before placing radio equipment on the EU market: conformity assessment, spectrum use, technical documentation, EU declaration, CE marking, traceability, instructions, restrictions, storage, corrective action, and authority cooperation.
- [RED notified body route selection under Article 17](/artifacts/eu/radio-equipment-directive/notified-body-route-selection.md): Decide when RED radio equipment can use internal production control and when Article 17 requires Annex III EU-type examination or Annex IV full quality assurance.
- [RED Notified Body Trigger Workflow: Article 17 evidence guide](/artifacts/eu/radio-equipment-directive/notified-body-trigger-workflow.md): Decide when the EU Radio Equipment Directive needs a notified body by mapping Article 3 requirements, OJEU-cited harmonised standards, Annex III EU-type examination, and Annex IV full quality assurance evidence.
- [RED penalties, fines, and enforcement actions](/artifacts/eu/radio-equipment-directive/penalties-and-fines.md): EU Radio Equipment Directive penalties guide covering Article 46, Member State penalty rules, recalls, withdrawals, formal non-compliance, and enforcement evidence.
- [RED radio modules FAQ: host product assessment](/artifacts/eu/radio-equipment-directive/faq/radio-modules.md): FAQ on how Directive 2014/53/EU treats RF modules and host products, including module evidence, final-product responsibility, Article 3 assessment, technical documentation, instructions, antennas, software, and DoC records.
- [RED SAR and RF Exposure Evidence FAQ](/artifacts/eu/radio-equipment-directive/faq/sar-and-wireless-exposure.md): What SAR and RF exposure evidence to keep under the EU Radio Equipment Directive, including Article 3(1)(a), foreseeable use, frequency, power, antenna, and standards evidence.
- [RED software update impact for radio equipment](/artifacts/eu/radio-equipment-directive/software-update-impact.md): Assess when firmware, app, and software updates can affect EU Radio Equipment Directive conformity, technical documentation, DoC, standards, and notified-body evidence.
- [RED vs Cyber Resilience Act: radio equipment cyber scope](/artifacts/eu/radio-equipment-directive/red-vs-cyber-resilience-act.md): Compare RED cybersecurity duties with Cyber Resilience Act planning for connected radio equipment, using grounded RED scope, evidence, dates, and caveats.
- [RED vs EMC Directive: when radio equipment uses RED instead of EMCD](/artifacts/eu/radio-equipment-directive/red-vs-emc.md): Compare the EU Radio Equipment Directive and EMC Directive for radio products, EMC evidence, CE marking, declarations, technical files, and scope boundaries.
- [RED vs ETSI EN 303 645: IoT cyber evidence comparison](/artifacts/eu/radio-equipment-directive/red-vs-etsi-en-303-645.md): Compare EU RED cybersecurity duties with ETSI EN 303 645 evidence reuse for connected radio products, OJEU standards, CE files, and 1 August 2025 planning.
- [RED vs LVD: when radio equipment uses RED for electrical safety](/artifacts/eu/radio-equipment-directive/red-vs-lvd.md): Compare the EU Radio Equipment Directive and Low Voltage Directive for radio-product safety, voltage limits, CE marking, technical files, and declarations.
- [RED vs Market Surveillance Regulation: radio equipment compliance roles](/artifacts/eu/radio-equipment-directive/red-vs-msr.md): Compare RED product conformity duties with EU Market Surveillance Regulation controls for radio equipment, online sales, responsible operators, customs holds, and evidence.
- [RED vs UK PSTI for connected radio products](/artifacts/eu/radio-equipment-directive/red-vs-uk-psti.md): Compare EU RED duties with UK PSTI planning for connected radio products: scope, actors, evidence, cybersecurity overlap, CE marking, and separate UK product-security workstreams.
- [When do RED cybersecurity requirements apply to connected radio equipment? | RED FAQ](/artifacts/eu/radio-equipment-directive/faq/cybersecurity-applicability.md): RED FAQ explaining when Article 3(3)(d), (e), and (f) cybersecurity requirements apply to internet-connected, childcare, toy, wearable, and payment-capable radio equipment.
- [Which receivers and transmitters are covered by RED? | Directive 2014/53/EU FAQ](/artifacts/eu/radio-equipment-directive/faq/receivers-and-transmitters.md): RED scope FAQ for products that intentionally emit or receive radio waves for radio communication or radiodetermination, including receiver-only products, transmitters, accessory-dependent products, and common exclusions.
- [Wi-Fi and Bluetooth Products Under the EU RED](/artifacts/eu/radio-equipment-directive/faq/wi-fi-and-bluetooth-products.md): FAQ for assessing Wi-Fi, Bluetooth, BLE and other short-range wireless products under the EU Radio Equipment Directive, including Article 3, CE, technical file, cybersecurity and notified-body triggers.

*Recommended next step*

*Placement: after implementation section*

## Check the RED standards matrix before release

Use Sorena to map each RED Article 3 requirement to OJEU-cited standards, uncited technical evidence, notified-body triggers, and technical-file records.

- [Open Research Copilot](/solutions/research-copilot.md): Check RED standards, scope, and conformity-assessment questions with cited outputs.
- [Talk through implementation](/contact.md): Review your standards matrix, Article 17 route, evidence model, and release blockers.


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