---
title: "RED Notified Body Trigger Workflow: Article 17 evidence guide"
canonical_url: "https://www.sorena.io/artifacts/eu/radio-equipment-directive/notified-body-trigger-workflow"
source_url: "https://www.sorena.io/artifacts/eu/radio-equipment-directive/notified-body-trigger-workflow"
author: "Sorena AI"
description: "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."
published_at: "2026-05-09"
updated_at: "2026-05-09"
keywords:
  - "RED notified body trigger"
  - "Radio Equipment Directive Article 17"
  - "EU-type examination"
  - "Annex III RED"
  - "Annex IV full quality assurance"
  - "OJEU harmonised standards"
  - "EU Radio Equipment Directive"
  - "RED"
  - "Directive 2014/53/EU"
  - "notified body"
  - "Article 17"
  - "conformity assessment"
---
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# RED Notified Body Trigger Workflow: Article 17 evidence guide

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.

*Workflow* *EU*

## 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.

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

A RED notified-body trigger decision should start with the exact Article 3 requirement being assessed. For Article 3(1) safety, health, and EMC 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.

## Start with the Article 3 requirement and standards coverage

Do not begin with the question, "Do we need a notified body?" Begin with the requirement row. Identify whether the issue belongs to Article 3(1)(a), Article 3(1)(b), Article 3(2), or an activated Article 3(3) requirement, 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) differently from Article 3(2) and Article 3(3). Missing or partial harmonised-standard coverage for Article 3(2) or Article 3(3) moves the affected requirement to Annex III EU-type examination followed by conformity to type, or Annex IV full quality assurance.

- 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.

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 and Article 17 connect RED presumption of conformity and conformity-assessment route selection to OJEU-cited harmonised standards.
- [European Commission RED Guide](https://ec.europa.eu/docsroom/documents/33162/attachments/1/translations/en/renditions/native?ref=sorena.io) - Commission RED guidance explains that Article 3(2) and Article 3(3) gaps require a conformity assessment involving a notified body.

## Use the Article 17 trigger test

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

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), or Article 3(3).
- 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.

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 states the route options and the conditions that trigger Annex III or Annex IV for Article 3(2) and 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 supports checking OJEU-published references and amendments before relying on a harmonised-standard conclusion.

## Document Annex III EU-type examination evidence

When Annex III is selected, the evidence file should show that the manufacturer applied to a single notified body, provided technical documentation and supporting evidence, and did not lodge the same application with another notified body. The notified body's role is to examine the technical design and issue, refuse, restrict, suspend, or withdraw the EU-type examination certificate as the case requires.

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 notified body'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.

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) - Annex III defines EU-type examination, the single-notified-body application, supporting evidence, certificate contents, and modification handling.
- [European Commission - notified bodies](https://single-market-economy.ec.europa.eu/single-market/goods/building-blocks/notified-bodies_en?ref=sorena.io) - Commission overview explains what notified bodies do and that manufacturers may choose any legally designated notified body for the procedure.

*Recommended next step*

*Placement: after implementation section*

## Turn the trigger decision into release evidence

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

- [Open Research Copilot](/solutions/research-copilot.md): Answer RED route, standards, and evidence questions with cited outputs.
- [Talk through implementation](/contact.md): Review your Article 17 trigger record, notified-body evidence, and launch controls.

## 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 notified body 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 notified body's identification number to follow the CE marking where Annex IV is applied. The file 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 notified body.
- Keep the notified body'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.

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) - Annex IV sets full quality assurance, notified-body assessment and surveillance, quality records, and CE marking with notified-body identification number.
- [Directive 2014/53/EU on radio equipment](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A32014L0053&ref=sorena.io) - Article 20 requires the notified-body identification number to follow the CE marking where Annex IV is applied.

## 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.

- Use 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 notified body 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.

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) - Annex III and Annex IV require notified bodies to inform authorities and other notified bodies about refused, suspended, withdrawn, or restricted certificates and approvals.
- [European Commission - notified bodies](https://single-market-economy.ec.europa.eu/single-market/goods/building-blocks/notified-bodies_en?ref=sorena.io) - Commission source for notified-body role, designation, NANDO listing, identification numbers, and tasks for which bodies are notified.

## 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 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.
  - Quote: "Conformity assessment procedures"
- [European Commission RED Guide](https://ec.europa.eu/docsroom/documents/33162/attachments/1/translations/en/renditions/native?ref=sorena.io) - 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.
  - Quote: "Module B+C (Annex III of the RED) or Module H"
- [European Commission - notified bodies](https://single-market-economy.ec.europa.eu/single-market/goods/building-blocks/notified-bodies_en?ref=sorena.io) - Commission source for notified-body designation, independence, tasks, manufacturer choice, NANDO listing, identification numbers, and notified-body task scope.
  - Quote: "when a third party is required"
- [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 used to check OJEU-published harmonised-standard references, amendments, and notices before relying on standards coverage for route decisions.
  - Quote: "published in the Official Journal"
- [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 procedure selection, notified-body involvement, and CE marking context.
  - Quote: "responsibility of the manufacturer"

## Related 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.
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- [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 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 standards not cited in the OJEU: can you use them?](/artifacts/eu/radio-equipment-directive/faq/standards-not-cited-in-ojeu.md): 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.
- [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.
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- [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.


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