Artifact GuideEU

EU Radio Equipment Directive Notified Body Route Selection

Article 17 lets manufacturers use internal production control for Article 3(1) and Article 3(4), and for Article 3(2) or 3(3) only when the relevant OJEU-cited harmonised standards are applied.

This page helps choose between internal production control, Annex III EU-type examination plus conformity to type, and Annex IV full quality assurance without treating voluntary certificates as RED evidence.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 25, 2026
Sections
4

Structured answer sets in this page tree.

Primary sources
6

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 25, 2026
Overview

RED route selection starts with Article 17. For Article 3(1) safety and EMC and Article 3(4) common-charger requirements, internal production control remains one available route. For Article 3(2) efficient spectrum use and Article 3(3) activated requirements, the route changes when OJEU-cited harmonised standards are missing, not applied, or only partly applied: the radio equipment must go through Annex III or Annex IV for those essential requirements, unless the conditional Article 43c procedure applies to designated crisis-relevant equipment during an activated internal market emergency.

Section 1

Article 17 route decision

First split the assessment by essential requirement. Article 17(2) allows the manufacturer to demonstrate Article 3(1) and Article 3(4) compliance through Annex II internal production control, Annex III EU-type examination followed by conformity to type, or Annex IV full quality assurance.

For Article 3(2) and Article 3(3), internal production control is available only when the manufacturer has applied harmonised standards whose references are published in the Official Journal for the requirements being assessed. If those standards are not applied, are only partly applied, or do not exist for the relevant requirement, Article 17(4) removes Annex II for that part of the assessment and requires either Annex III or Annex IV.

  • Map each radio, receiver, transmitter, module, or kit configuration to Article 3(1), Article 3(2), any applicable Article 3(3) requirement, and Article 3(4) where applicable.
  • For Article 3(2) and Article 3(3), record the exact OJEU-cited harmonised standard, edition, covered clauses, and whether it is applied in full or in part.
  • If the standards position is incomplete for a relevant Article 3(2) or 3(3) requirement, choose Annex III or Annex IV before market placement.
Section 2

Choosing Annex III or Annex IV

Annex III is the product-design route: a single of the manufacturer's choice examines the adequacy of the technical design through the technical documentation and supporting evidence, without examination of a specimen. When the type meets the applicable RED requirements, the notified body issues an EU-type examination certificate; the manufacturer then uses internal production control to ensure each item conforms to the approved type and applicable requirements.

Annex IV is the quality-system route: the manufacturer uses an approved quality system for design, manufacture, final inspection, and testing, and the assesses and surveils that system. Annex IV also affects marking because the CE marking is followed by the notified body's identification number when Annex IV is applied.

  • Use Annex III when the compliance question is mainly whether the technical design and supporting evidence demonstrate the applicable Article 3 requirement.
  • Use Annex IV when the release model depends on an approved design and manufacturing quality system with notified-body surveillance.
  • Do not lodge the same Annex III or Annex IV application with more than one ; both annexes require a written declaration on that point.
  • Check the selected body's current RED designation and notified tasks in the Commission listing. A body designated under another EU act, or for a different RED task, is not enough.
Section 3

Evidence to keep in the technical file

The route-selection memo should be readable without project history. It should show the product configuration assessed, the Article 3 requirements in scope, the harmonised-standard status for each requirement, and the reason Annex II, Annex III, or Annex IV was selected.

Annex III evidence should include the EU-type examination application package, the technical documentation, supporting evidence, the 's evaluation outcome, the EU-type examination certificate and annexes if issued, and later approvals for modifications that affect conformity or certificate validity. Annex IV evidence should include the quality-system documentation, technical documentation for each radio equipment type, notified-body decisions, audit reports, visit reports, and approved quality-system changes.

  • Keep the standards matrix specific: standard reference, OJEU status, requirement coverage, full or partial application, and any alternative technical specifications.
  • Keep test reports, calculations, risk assessment, firmware or software versions affecting compliance, user information, marking records, and EU declaration records with the route decision.
  • Reopen the record after design, firmware, component, radio function, intended operating condition, harmonised-standard, or quality-system changes.
Recommended next step

Turn the route decision into a technical-file record

This RED route guide helps document why Annex II, Annex III, or Annex IV was chosen for each Article 3 requirement, and keep the standards matrix, notified-body evidence, and review triggers together.

Section 4

Mistakes that create route risk

The most common mistake is treating a voluntary certificate or a generic test report as a substitute for the RED conformity-assessment route. The Commission warns that voluntary or other additional certificates are not a recognised means to prove compliance unless specific legislation provides for them.

A second mistake is assuming that any standard with a familiar title gives full presumption of conformity. Route selection depends on the references published in the Official Journal and on the exact Article 3 requirement covered. A partly applied or non-OJEU specification can still be useful evidence, but it does not by itself preserve the Annex II route for Article 3(2) or 3(3).

  • Do not choose a unless it is designated for RED and for the relevant tasks; check the Commission notified-body list rather than a marketing certificate.
  • Do not use Annex III certificate language for Annex IV quality-system approvals, or add a notified-body identification number to the CE marking except where the applied route requires it.
  • Do not leave the route decision stale after a new radio variant, firmware update, supplier change, standard withdrawal, or Article 3(3) requirement activation.
Primary sources

References and citations

eur-lex.europa.eu
Referenced sections
  • Article 20 and Annex IV explain when the notified body's identification number follows the CE marking.
"identification number of the notified body"
eur-lex.europa.eu
Referenced sections
  • Article 17 sets the ordinary RED conformity-assessment choices, including the Article 3(4) route, and the notified-body trigger when Article 3(2) or 3(3) harmonised standards are absent, partial, or not used; Article 43c provides the conditional internal-market-emergency derogation.
"radio equipment shall be submitted"
single-market-economy.ec.europa.eu
Referenced sections
  • Commission overview explaining that manufacturers may choose any legally designated notified body for the relevant conformity-assessment procedure.
"Manufacturers are free to choose"
single-market-economy.ec.europa.eu
Referenced sections
  • Commission RED overview warning that voluntary certificates are not a recognised means to prove compliance and pointing to RED notified bodies.
"not a recognised means"
webgate.ec.europa.eu
Referenced sections
  • Commission listed RED notified bodies source for checking designation before relying on a body for Annex III or Annex IV work.
"Notified bodies relating to the RED"
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