Wi-Fi and Bluetooth products under the RED

Usually yes. A product with Wi-Fi, Bluetooth, BLE or another intentional radio communication function fits the RED concept of radio equipment when it intentionally emits or receives radio waves for radio communication. The assessment should cover the complete finished product placed on the EU market, including accessories, antennas, software and firmware needed for the radio equipment to operate as intended.

Do not reduce the file to a module certificate. A pre-certified radio module can be useful evidence, but the manufacturer or importer still needs a product-level RED decision for the final configuration, enclosure, antenna, power supply, firmware, host interface, instructions, restrictions, EU declaration and CE marking.

The baseline obligations are not optional: health and safety, EMC and efficient spectrum use apply to radio equipment. For Wi-Fi and Bluetooth products this normally means safety and exposure evidence, EMC evidence, radio test evidence for each supported band and mode, and a standards matrix showing which essential requirements are covered.

Article 10 also matters in day-to-day product work. Instructions for intentional transmitters must include the frequency bands and maximum radio-frequency power. If the product is subject to restrictions on putting into service or authorisation-of-use requirements in at least one Member State, packaging and instructions need the required restriction information.

A Wi-Fi or Bluetooth product needs a cybersecurity applicability decision, not a generic yes/no label. Delegated Regulation (EU) 2022/30 applies Article 3(3)(d) to radio equipment that can communicate itself over the internet, directly or through other equipment. It applies Article 3(3)(e) to listed categories when they can process personal, traffic or location data, and Article 3(3)(f) to internet-connected radio equipment that enables transfers of money, monetary value or virtual currency.

The application date was moved to 1 August 2025 by Delegated Regulation (EU) 2023/2444. For Wi-Fi products this often means the cybersecurity file is in scope. For Bluetooth-only products, the answer depends on the actual architecture: for example, whether the equipment itself can communicate over the internet via a phone, gateway or other equipment, whether it is childcare, toy or wearable radio equipment, what data it processes, and whether it enables payment or value transfer.

Check the delegated regulation's exclusions before reaching a final answer. Article 3(3)(d), (e), and (f) do not apply through Delegated Regulation (EU) 2022/30 to radio equipment also governed by the EU medical-device or in vitro diagnostic medical-device regulations. Its Article 3(3)(e) and (f) requirements also exclude radio equipment governed by the listed EU civil-aviation, motor-vehicle type-approval, or electronic-road-toll legislation. Other obligations under those regimes may still apply.

Delegated Regulation (EU) 2026/339 repeals Delegated Regulation (EU) 2022/30 from 11 December 2027. RED market surveillance continues for covered equipment placed on the Union market from 1 August 2025 through 10 December 2027. Record the placement date and reassess equipment first placed from 11 December 2027 under the Cyber Resilience Act and the remaining RED requirements.

Harmonised standards are voluntary, but when their references are published in the Official Journal and they are fully applied for the relevant requirement, they can give presumption of conformity for the requirement they cover. For Wi-Fi and Bluetooth products, keep the OJEU-cited standard reference, version, cessation date if relevant, and the exact requirement coverage in the standards matrix.

A notified body becomes relevant to the Article 3(2) spectrum and Article 3(3) routes when the Article 17 conditions are met. If relevant OJEU-cited harmonised standards for Article 3(2) or 3(3) are not applied, are applied only in part, or do not exist, Article 17 requires EU-type examination followed by conformity to type or full quality assurance for those requirements. For cybersecurity, EN 18031-1:2024, EN 18031-2:2024, and EN 18031-3:2024 are cited with restrictions, so check the applicable notice before claiming full presumption of conformity.

A module purchase does not settle wireless-product compliance. RED compliance belongs to the finished radio equipment placed on the EU market, so the file should show how the module evidence, host design, antenna, power supply, enclosure, software, installation instructions and intended use fit together.

Another recurring issue is stale evidence after software or configuration changes. If an update changes radio behavior, cybersecurity behavior, software loaded into the equipment, restrictions, user information or the standards relied on, reopen the RED file before shipping the changed configuration.