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Radio Equipment Directive (RED) Interpretations

Posted on April 10th 2017 by

 

Question:

  1. We have warehouses in the EU with products deemed compliant with the R&TTE Directive. How long can we continue to sell these products in the EU?
  2. Our products provide Bluetooth connectivity via USB port to other devices such as microcontrollers. Are these other devices subject to the RED?
  3. Our products provide Wi-Fi connectivity through the physical integration of our Wi-Fi hotspot with other devices such as microcontrollers. Are these devices subject to the RED?

Answer:

  1. Based on the minimal description provided, and the RED definition of “placing on the market”, the products in the warehouse may be able to be sold after June 13, 2017. However, before making any final determinations, we strongly recommend that manufacturers/importers read sections 2.1 to 2.5 and 3.1 to 3.6 of the Official Journal of the European Union, 2016/C C272/01, the “Blue Guide” on the implementation of EU products rules 2016.
  2. The BT radio must always be compliant with the RED, but since the BT connectivity is via USB only, easily removable, and not integrated nor installed within the microcontroller, the microcontroller must only comply with the EMC Directive and the LV Directive as a non-radio product.
  3. The physical, or permanent, integration of your Wi‑Fi hotspot into another device, e.g. a microcontroller, now makes that other device a radio product under the terms of the RED. Conversely, as with the BT radio above, if the Wi‑Fi hotspot was not permanently installed, and could be easily removed, e.g. a Wi‑Fi micro-card installed in a slot, the Wi‑Fi micro‑card is the radio product that must comply with the RED, whereas the microcontroller is a non radio product, and therefore must comply with the EMC‑D and the LV-D.

    Note: The RED does not allow application of the EMC Directive, as was allowed under the R&TTE. The RED includes all equipment that contains a radio, including those with a combination of multiple radio products in one, or a combination of radio and non-radio products.

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