WorkflowEU

RED notified body trigger workflow

Under RED Article 17, notified-body involvement turns on the affected Article 3 requirement and whether OJEU-cited harmonised standards are applied in full, applied only in part, not applied, or unavailable.

This workflow helps document the trigger decision, select the Annex III or Annex IV route when needed, and keep evidence that explains the notified-body role.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 25, 2026
Overview

A RED trigger decision starts with the exact Article 3 requirement being assessed. For Article 3(1) safety, health, and EMC requirements and Article 3(4) common-charger requirements, Article 17 allows internal production control, EU-type examination followed by conformity to type, or full quality assurance. For Article 3(2) spectrum use and Article 3(3) activated requirements, a notified-body route is triggered when OJEU-cited harmonised standards are not applied, are applied only in part, or do not exist for the relevant essential requirement, unless the conditional Article 43c procedure applies to designated crisis-relevant equipment during an activated internal market emergency.

Section 1

Start with the Article 3 requirement and standards coverage

Do not begin with the question, "Do we need a ?" Begin with the requirement row. Identify whether the issue belongs to Article 3(1)(a), Article 3(1)(b), Article 3(2), an activated Article 3(3) requirement, or Article 3(4), then check whether the exact OJEU-cited harmonised standard or cited part covers that requirement for the finished radio equipment configuration.

This distinction matters because RED Article 17 treats Article 3(1) and Article 3(4) differently from Article 3(2) and Article 3(3). For Article 3(2) or Article 3(3), Annex III or Annex IV is ordinarily required when the manufacturer does not apply the relevant OJEU-cited harmonised standards, applies them only in part, or no such standards exist. Article 43c provides a conditional exception for designated crisis-relevant equipment during an activated internal market emergency. A standard may cover one essential requirement without covering another, so make the decision requirement by requirement.

  • Record the product model, radio technologies, frequency bands, antenna configuration, accessories, firmware or software version, intended operating conditions, and EU market role.
  • For each Article 3 requirement, state whether an OJEU-cited harmonised standard is applied in full, applied in part, not applied, or unavailable.
  • Treat a supplier report, module certificate, draft standard, or non-harmonised specification as supporting evidence, not as an automatic substitute for Article 17 route selection.
  • If the affected gap is Article 3(2) or Article 3(3), open a notified-body route decision before release evidence is marked complete.
Section 2

Use the Article 17 trigger test

Apply the trigger test requirement by requirement. For Article 3(1) and Article 3(4), RED Article 17 permits internal production control under Annex II even when the manufacturer demonstrates conformity by means other than harmonised standards. A may still be chosen, but the absence of a harmonised standard is not the trigger by itself for Article 3(1) or Article 3(4).

For Article 3(2) and Article 3(3), the trigger is stricter. If the manufacturer has not applied OJEU-cited harmonised standards, has applied them only in part, or no such standards exist, the radio equipment must be submitted for the affected essential requirements to Annex III or Annex IV.

  • Classify the requirement: Article 3(1)(a), Article 3(1)(b), Article 3(2), Article 3(3), or Article 3(4).
  • Check the standards status against OJEU-published RED harmonised-standard references, including any limitation or notice that narrows presumption of conformity.
  • If Article 3(2) or Article 3(3) is not fully covered by applied OJEU-cited harmonised standards, choose Annex III or Annex IV and document why Annex II is not the selected route for that requirement.
  • If standards are fully applied for Article 3(2) or Article 3(3), record the basis for using Annex II, Annex III, or Annex IV rather than treating the route as implicit.
  • Re-run the trigger test after hardware, antenna, firmware, software, intended-use, supplier, OJEU-citation, or standard-version changes.
Section 3

Document Annex III EU-type examination evidence

When Annex III is selected, the evidence file should show that the manufacturer applied to a single , provided technical documentation and supporting evidence, and did not lodge the same application with another notified body. EU-type examination assesses the adequacy of the radio equipment's technical design through examination of the technical documentation and supporting evidence, without examination of a specimen. If the type meets the applicable requirements, the notified body issues an EU-type examination certificate.

Keep the certificate evidence tied to the product type and to the exact Article 3 aspects covered. A certificate is weak evidence if the file does not show the tested configuration, the standards or technical specifications used, the conditions for validity, and the changes that would require additional approval.

  • Keep the application record, technical documentation, risk analysis, supporting evidence, standards or technical specifications used, and test results submitted for the design assessment.
  • Keep the EU-type examination certificate, annexes, additions, conditions for validity, evaluation-report reference, and the 's name and identification details.
  • Record any modifications to the approved type that may affect essential-requirement conformity or certificate validity, and whether additional approval was obtained.
  • Make the EU declaration of conformity point to the notified-body intervention where applicable, including the certificate reference.
Recommended next step

Turn the trigger decision into release evidence

This RED workflow helps connect Article 3 requirement gaps, harmonised-standard coverage, Annex III or Annex IV route decisions, notified-body records, and CE marking evidence before launch.

Section 4

Document Annex IV full quality assurance evidence

When Annex IV is selected, the evidence is broader than a one-time certificate. The manufacturer applies for assessment of the quality system for the radio equipment concerned, keeps the informed of intended quality-system changes, and remains under notified-body surveillance.

The CE marking evidence also changes under Annex IV: RED Article 20 requires the 's identification number to follow the CE marking where Annex IV is applied. The record should therefore connect the approved quality-system scope, notified-body surveillance records, and CE marking artwork or label controls.

  • Keep quality-system documentation, technical documentation for each covered radio equipment type, and the written declaration that the same application was not lodged with another .
  • Keep the 's quality-system approval, reasoned assessment decision, audit reports, visit reports, test reports where relevant, and records of approved quality-system changes.
  • Verify that the notified-body identification number is used only where Annex IV applies and is controlled with the CE marking evidence.
  • Preserve evidence that the quality system covers design, manufacture, inspection, testing, storage, responsibilities, records, and monitoring for the equipment type.
Section 5

Keep a reviewer-ready trigger record

The final workflow output should be a short trigger record that a product, regulatory, quality, legal, procurement, or market-surveillance reviewer can follow without reconstructing the project history. It should explain the yes, no, or escalate answer for each affected Article 3 requirement.

Avoid closing the workflow with a meeting note. The record should link the requirement, standards coverage, route decision, notified-body scope, certificate or quality-system evidence, EU declaration text, CE marking controls, and unresolved assumptions.

  • Keep one row per requirement gap: requirement, product configuration, standard coverage, trigger outcome, selected route, owner, evidence location, source URL, and next review trigger.
  • Keep Annex III certificates and Annex IV quality-system decisions with the technical documentation and EU declaration of conformity retention file.
  • Use NANDO or the Commission notified-body listing to confirm that the selected body is designated for the relevant legislation and tasks before relying on its intervention.
  • Reopen the decision when a restricts, suspends, refuses, or withdraws a certificate or approval, or when the product changes in a way that affects the approved type or quality-system scope.
Primary sources

References and citations

eur-lex.europa.eu5 citations
Referenced sections
  • Primary RED source for Article 16 presumption of conformity, Article 17 conformity-assessment procedures, Annex III EU-type examination, Annex IV full quality assurance, Article 20 notified-body identification number rules, and technical-documentation evidence.
  • Article 17 states the route options and the conditions that trigger Annex III or Annex IV for Article 3(2) and Article 3(3).
  • Annex III defines EU-type examination, the single-notified-body application, supporting evidence, certificate contents, and modification handling.
Show 2 more
  • Annex IV sets full quality assurance, notified-body assessment and surveillance, and quality records; Article 20 requires the notified-body identification number to follow the CE marking where Annex IV is applied.
  • Annex III and Annex IV require notified bodies to inform authorities and other notified bodies about refused, suspended, withdrawn, or restricted certificates and approvals.
"Conformity assessment procedures"
More quoted passages
"has applied only in part"
"single notified body of his choice"
"where the conformity assessment procedure set out in Annex IV is applied"
"refused, suspended or otherwise restricted"
single-market-economy.ec.europa.eu3 citations
Referenced sections
  • Commission source for notified-body designation, independence, tasks, manufacturer choice, NANDO listing, identification numbers, and notified-body task scope.
  • Commission overview explains what notified bodies do and that manufacturers may choose any legally designated notified body for the procedure.
  • Commission source for notified-body role, designation, NANDO listing, identification numbers, and tasks for which bodies are notified.
"when a third party is required"
More quoted passages
"legally designated to carry out"
"include the tasks for which it has been notified"
single-market-economy.ec.europa.eu2 citations
Referenced sections
  • Commission RED standards page used to check OJEU-published harmonised-standard references, amendments, and notices before relying on standards coverage for route decisions.
  • Commission RED standards page supports checking OJEU-published references and amendments before relying on a harmonised-standard conclusion.
"published in the Official Journal"
single-market-economy.ec.europa.eu2 citations
Referenced sections
  • Commission guidance explaining the RED Article 17 distinction between Article 3(1) requirements and Article 3(2)/3(3) notified-body triggers when harmonised standards are partial, not applied, or unavailable.
  • Commission RED guidance explains that Article 3(2) and Article 3(3) gaps require a conformity assessment involving a notified body.
"Module B+C (Annex III of the RED) or Module H"
More quoted passages
"a conformity assessment involving a notified body"
eur-lex.europa.eu
Referenced sections
  • General EU product-law guidance for manufacturer responsibility, conformity-assessment procedure selection, notified-body involvement, and CE marking context.
"responsibility of the manufacturer"
eur-lex.europa.eu
Referenced sections
  • Articles 16 and 17 connect ordinary RED presumption of conformity and conformity-assessment route selection to OJEU-cited harmonised standards; Articles 43c and 43d provide conditional emergency procedures for designated crisis-relevant equipment.
"references of which have been published"
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