Lauren That was the case for the old R&TTE Directive, but is not permitted under RED as the manufacturer has created a new piece of "radio equipment" and the whole device must fully comply with the RED.
Best regards Charlie Charlie Blackham Sulis Consultants Limited Tel: +44 (0)7946 624317 Web: https://sulisconsultants.com/ Registered in England and Wales, number 05466247 From: lauren.cr...@lamresearch.com <lauren.cr...@lamresearch.com> Sent: 28 February 2025 16:25 To: EMC-PSTC@LISTSERV.IEEE.ORG Cc: Charlie Blackham <char...@sulisconsultants.com> Subject: Re: [PSES] RED in an end product For the EU arena, I was recalling that a CE-marked-for-RED component could be integrated into another product and that incorporating product would not need additional RED assessment provided: 1. The RED component was integrated in accordance with its instructions and particularly was not modified in any RED-relevant way (e.g., chassis or antenna alterations). 1. The integrating product calls out RED in its own DoC, describing the integrated RED component and indicating the NoBo number used for the RED component. 1. Repeating the RED component's NoBo number near the CE mark of the integrating product. But perhaps that is not longer correct? Best Regards, -Lauren Crane Confidential - Limited Access and Use ________________________________ From: Charlie Blackham <char...@sulisconsultants.com<mailto:char...@sulisconsultants.com>> Sent: Thursday, February 27, 2025 2:33 PM To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> <EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>> Subject: Re: [PSES] RED in an end product External Email: Do NOT reply, click on links, or open attachments unless you recognize the sender and know the content is safe. If you believe this email may be unsafe, please click on the "Report Phishing" button on the top right of Outlook. Steve I'm going to be slightly pedantic on the terminology, as there's a difference between USA/Canada and EU when it comes to modules: * USA and Canada have a modular certification scheme that allows modules to be integrated into end products without the need for further "certification" (assuming grant conditions covering things such as antennas and EMF/SAR are complied with * The EU has "radio equipment" and modules are "radio equipment", but so are mobile phones, Bluetooth speakers and cellular basestations. Where a module has a NB certificate that is useful in showing that the module complies with the stated articles of the RED but can't just be "carried across". A product can have a Notified Body EU-Type Examination certificate, but it's not "certified". A quick summary is the "whole product" with the radio in it is now "radio equipment" and should be assessed: * For safety against the most appropriate product safety standard - which could be 62368-1 for IT/AV equipment or 60335-x standards for domestic appliance * SAR/EMF needs to be assessed against a suitable standard for the application * EMC against the most appropriate product standard and the EN 301 489-x standards in the end product * RF spectrum is up to the manufacturer - The manufacturer may choose to trust the module manufacturer, but according to RED article 17 and Annex II or III, the manufacturer: * Needs copies of the test reports if self-declaring (so they can confirm that Harmonised Standards have been fully applied * Needs another Notified Body certificate for the whole product if Harmonised Standards haven't been "fully applied" * Really ought to do some additional testing of the end radio product, such as Radiated Spurious Emissions * All of the above options need to be considered and supported in the manufacturer's RED Risk Assessment * Article 3.3 Cyber security requirements may be applicable to the end product from 1st August 2025 More information in REDCA Technical Guidance Notes TGN01 on modules, https://www.redca.eu/Unrestricted%20Documents/TGN/REDCA%20TGN%2001%20RED%20Radio%20equipment%20modules%20V1.2a%20March%202020.pdf TGN30 on Risk Assessments https://www.redca.eu/Unrestricted%20Documents/TGN/REDCA%20TGN%2030%20-%20RED%20NB%20Risk%20assessment%20guide%20-%20V3.1%20-%20May%202022.pdf Best regards Charlie Charlie Blackham Sulis Consultants Limited Tel: +44 (0)7946 624317 Web: https://sulisconsultants.com/ Registered in England and Wales, number 05466247 From: Steve Brody <0000355150a0f9b9-dmarc-requ...@listserv.ieee.org<mailto:0000355150a0f9b9-dmarc-requ...@listserv.ieee.org>> Sent: 27 February 2025 19:57 To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: [PSES] RED in an end product Never having worked with the RED, the question I have is this: A client is incorporating an RED certified [by an NB] module in their end product. The RED DoC lists the following standards, and the RED Directive: RoHS Directive 2011/65/EU EN IEC 62368-1: 2020 + EN IEC 62368-1: 2020/A11: 2020 EN 50566 : 2017 EMC (Art.3(1) (b)): EN 301 489-1 v2.2.3 EN 301 489-17 v3.2.4 EN 301 489-3 v2.1.1 Spectrum (Art.3(2) EN 300 328 v2.2.2 (WLAN & BT) EN 301 893 v2.1. EN 300 440 v2.2.1 What needs to be on the end product DoC? Thanks in advance, Steve Brody sgbr...@comcast.net<mailto:sgbr...@comcast.net> C - 603 617 9116 ________________________________ This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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