ComparisonEU RED / UK PSTI

RED vs UK PSTI for connected radio products

RED is the EU product-law route for radio equipment: scope starts with equipment that intentionally emits or receives radio waves, then moves through Article 3 safety, EMC, spectrum, selected cybersecurity requirements, conformity assessment, CE marking, and the technical file.

Use this comparison to separate RED evidence from a UK PSTI product-security workstream. Shared controls can help, but RED CE evidence and UK PSTI planning should not be merged without a source-linked bridge.

Author
Sorena AI
Published
May 9, 2026
Updated
May 27, 2026
Sections
3

Structured answer sets in this page tree.

Primary sources
6

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 27, 2026
Overview

RED and UK PSTI can both matter for a connected product portfolio, but they answer different compliance questions. RED decides whether radio equipment can be made available or put into service in the EU; UK PSTI planning addresses a separate UK connected-product security regime. This page keeps the RED side source-linked and treats PSTI claims narrowly where this RED grounding set does not include PSTI primary material.

Side-by-side comparison

RED vs UK PSTI for connected radio products

A practical comparison for teams shipping connected radio products into the EU and UK: where RED controls EU radio-equipment conformity, where PSTI planning should stay separate, and where evidence can be bridged without overclaiming.

Review all sources
First framework
EU RED

Use RED to decide EU radio-equipment scope, Article 3 requirements, harmonised standards, conformity assessment, CE marking, EU declaration, technical documentation, and market-surveillance readiness.

Second framework
UK PSTI

Use a separate UK PSTI workstream for connected-product security planning. Treat overlap as evidence reuse only after UK scope, actors, evidence, and customer-facing claims have been separately checked.

Comparison row 1

Scope and covered activity

EU RED

RED covers radio equipment made available on the EU market or put into service in the Union, starting with products that intentionally emit and/or receive radio waves for radio communication or radiodetermination.

UK PSTI

UK PSTI planning should start only after confirming the product is in a UK connected-product scope. Do not assume every RED radio product is a PSTI product, or that every PSTI product is RED radio equipment.

Operational implication

Write two scope findings: one for EU RED radio-equipment status and one for UK PSTI status. Reuse the product description, but keep the legal conclusion separate.

Comparison row 2

Who must act

EU RED

RED assigns duties across economic operators, including manufacturers, authorised representatives, importers, and distributors. The manufacturer remains responsible for conformity assessment and the EU declaration route.

UK PSTI

UK PSTI may assign duties to a different commercial actor for the same SKU, especially where the UK importer, distributor, brand owner, or online channel differs from the EU chain.

Operational implication

Map EU and UK operator roles separately before assigning owners for declarations, statements, labels, customer notices, supplier evidence, or corrective actions.

Comparison row 3

Trigger or threshold

EU RED

RED is triggered by making radio equipment available on the EU market or putting it into service, not by an incident or customer request. A radio module, antenna, wireless function, or software change can reopen the RED assessment.

UK PSTI

UK PSTI planning is triggered by UK connected-product placement facts and security claims. Treat UK product-security evidence as a separate checkpoint rather than a RED substitute.

Operational implication

Add intake questions for radio technologies, EU market placement, UK market placement, connected-product functionality, software update support, and security statements.

Comparison row 4

Core obligations

EU RED

RED obligations include meeting Article 3 essential requirements for health and safety, EMC, efficient spectrum use, and any activated Article 3(3) requirements; selecting the conformity-assessment route; preparing technical documentation; drawing up the EU declaration; and affixing CE marking.

UK PSTI

UK PSTI planning should focus only on the connected-product security obligations the UK regime actually imposes, using a UK source pack before naming specific evidence or statement duties.

Operational implication

Turn shared engineering controls into two deliverable lists: RED CE deliverables and UK PSTI deliverables. A penetration test, password design, or update policy may support both, but it should not replace either legal artifact set.

Comparison row 5

Evidence and records

EU RED

RED evidence should include the Article 3 matrix, risk analysis, harmonised-standards position, test reports, technical documentation, EU declaration of conformity, CE-marking and instruction records, and notified-body documents where the chosen route requires them.

UK PSTI

UK PSTI evidence should stay in its own pack, with specific UK statements, security records, supply-chain approvals, and customer claims included only where those have been separately sourced and approved.

Operational implication

Keep a shared evidence register with columns for RED, UK PSTI, product version, market, owner, source, and expiry or review trigger.

Comparison row 6

Timing and cadence

EU RED

RED has several clocks: the baseline directive has applied since 13 June 2016, technical documentation and EU declarations must be kept available for 10 years after placement on the market, and RED cybersecurity under Delegated Regulation (EU) 2022/30 applies from 1 August 2025.

UK PSTI

UK PSTI timing should be tracked separately for UK launch gates, security claim approvals, and distributor or importer readiness where those duties are confirmed by UK sources.

Operational implication

Use separate EU and UK launch gates. The earlier gate controls release sequencing, while the longer retention or support commitment controls operating cadence.

Comparison row 7

Enforcement and assurance route

EU RED

RED assurance runs through CE conformity evidence, economic-operator traceability, technical documentation, market-surveillance readiness, and notified-body involvement when the selected conformity-assessment route requires it.

UK PSTI

UK PSTI assurance should name the UK authority path, customer-facing security claims, corrective-action owner, and importer or distributor response plan only after the UK source pack is reviewed.

Operational implication

Do not put PSTI enforcement assumptions inside the RED technical file without labelling them as UK-only planning material.

Comparison row 8

Cybersecurity overlap and evidence reuse

EU RED

RED cybersecurity evidence may cover network protection, privacy and personal-data safeguards, and fraud protection for specified radio-equipment categories under Article 3(3)(d), (e), and (f). EN 18031 references can help only within their cited scope and restrictions.

UK PSTI

UK PSTI can often use the same underlying design facts, such as credential design, update policy, and vulnerability intake, but only the UK workstream should decide whether those facts satisfy PSTI duties.

Comparison row 9

Practical decision rule

EU RED

Use RED as the controlling workstream when the blocker is EU market access for radio equipment, Article 3 conformity, harmonised standards, notified-body routing, CE marking, or the EU declaration.

UK PSTI

Run UK PSTI in parallel when the blocker is UK connected-product launch, UK product-security claims, or UK supply-chain assurance.

Operational implication

The practical answer is often both: RED for EU CE access, PSTI for UK product-security readiness, and a controlled evidence bridge between the two.

Practical decision rule

How should teams decide between RED and UK PSTI for a connected radio product?

  • First decide whether the product is radio equipment for EU RED and whether it is separately in UK PSTI scope.
  • Build the RED file around Article 3 requirements, conformity assessment, CE marking, EU declaration, and technical documentation.
  • Build the UK PSTI pack separately, then reuse security controls only through a written bridge note that identifies the shared fact and the remaining gap.
Section 1

What is the practical difference between RED and UK PSTI?

Start with market and product scope. RED applies to radio equipment made available on the EU market or put into service in the Union. Its definition covers electrical or electronic products that intentionally emit and/or receive radio waves for radio communication or radiodetermination, including products that need an accessory such as an antenna to do so.

UK PSTI should be treated as a separate UK product-security assessment. For a Wi-Fi, Bluetooth, cellular, NFC, UWB, or other connected radio product, the same engineering controls may support both workstreams, but the RED conclusion must still be tied to RED scope, Article 3 requirements, conformity assessment, CE marking, EU declaration, and technical documentation.

  • Use RED to answer the EU radio-equipment placing-on-the-market question.
  • Use a separate UK PSTI review to decide whether UK connected-product security obligations apply.
  • Keep one evidence index if useful, but tag each artifact to the law, market, product version, and release it actually supports.
Section 2

Where does RED cybersecurity overlap with PSTI planning?

RED cybersecurity is not a generic IoT-security policy. Delegated Regulation (EU) 2022/30 activates Article 3(3)(d), (e), and (f) for specified classes of radio equipment, covering network protection, personal-data and privacy safeguards, and protection from fraud. Delegated Regulation (EU) 2023/2444 moves that application date to 1 August 2025.

That overlap is useful for engineering planning, but it is not a legal merger. RED cybersecurity evidence should show the applicable radio-equipment category, the Article 3(3) point, the selected standard or alternative technical solution, and any limits on presumption of conformity. UK PSTI materials should stay in a separate UK product-security evidence track unless a UK source confirms reuse.

  • Screen whether the product is internet-connected radio equipment, childcare radio equipment, toy radio equipment, wearable radio equipment, or radio equipment processing virtual money or monetary value.
  • For EN 18031 evidence, record the specific part used and any restriction that affects presumption of conformity, including default-password limitations in Implementing Decision (EU) 2025/138.
  • Do not describe PSTI compliance as achieved by RED testing alone; document only the controls that are actually reused and why.
Section 3

What should the comparison record contain?

A useful comparison record is short and audit-ready. It names the product version, radio technologies, EU and UK markets, economic operators, release date, Article 3 requirement set, standards position, test evidence, declarations, customer-facing claims, and open decisions.

For RED, keep the technical documentation, standards list, risk analysis, test reports, EU declaration of conformity, CE-marking records, instructions, safety and restriction information, notified-body documents where needed, and cybersecurity evidence. For PSTI planning, keep a separate UK workstream with only the claims the team has sourced and approved.

  • Separate RED CE artifacts from UK product-security artifacts even when the same engineering control appears in both.
  • Record whether a harmonised standard was applied fully, partly, or not at all, and explain the alternative technical solution if needed.
  • Reopen the comparison after a radio module change, software update, supplier change, market expansion, standard citation, delegated act, or new UK product-security claim.
Recommended next step

Build a RED and PSTI evidence bridge

Turn the comparison into a source-linked evidence map for connected radio products, with RED CE artifacts, cybersecurity controls, UK product-security assumptions, owners, and review triggers kept distinct.

Primary sources

References and citations

eur-lex.europa.eu
Referenced sections
  • EU product-law guidance for manufacturer responsibility, conformity assessment, economic operators, declarations, CE marking, and post-Brexit conformity context.
"The manufacturer is responsible for the conformity assessment."
data.europa.eu
Referenced sections
  • Binding RED source for radio-equipment scope, essential requirements, economic-operator duties, CE marking, EU declaration of conformity, and technical documentation.
"intentionally emits and/or receives radio waves"
single-market-economy.ec.europa.eu
Referenced sections
  • Commission overview for RED purpose, guidance, standardisation, notified bodies, delegated acts, and Brexit-related conformity context.
"essential requirements for safety and health, electromagnetic compatibility, and the efficient use of the radio spectrum"
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