Radio Equipment Directive (2014/53/EU): scope, EN 18031, USB-C and what you must do

Radio equipment is any product that intentionally sends or receives radio waves

The Directive defines radio equipment as an electrical or electronic product that intentionally emits or receives radio waves for radio communication or radiodetermination. It also covers a product that must be completed with an accessory, such as an antenna, to do that. Radio waves are electromagnetic waves below 3,000 GHz that travel in space without an artificial guide, and radiodetermination means working out the position, velocity or other characteristics of an object by the way radio waves propagate (Art. 2Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 2Click opens the article on EUR-Lex.). The definition names no size, price or sector. It speaks of the product, so a radio inside a larger product makes the whole product radio equipment. For the cybersecurity requirements the Commission says so in terms: no requirement of the Directive separates the radio and non-radio functions, and all aspects and parts of the equipment should comply (recital 8 of Delegated Regulation (EU) 2022/30).

The Directive does not apply to (Art. 1Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 1Click opens the article on EUR-Lex., Annex I):

• radio equipment used by radio amateurs, unless it is made available on the market. Kits for assembly and use by radio amateurs, equipment modified by and for radio amateurs, and equipment built by individual amateurs for experiments count as not made available;
• marine equipment under Council Directive 96/98/EC;
• aviation equipment under Regulation (EU) 2018/1139 that is intended exclusively for airborne use, as Annex I describes it;
• custom-built evaluation kits for professionals, used only at research and development facilities;
• radio equipment used exclusively for public security, defence, State security and the activities of the State in the area of criminal law.

A product left out of this Directive can still fall under other EU laws.

The essential requirements: safety, interference, spectrum and named categories

The Directive sets requirements, not technical specifications. The first three apply to all radio equipment. The fourth group applies only to the categories or classes that the law names (Art. 3Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 3Click opens the article on EUR-Lex.).

A delegated act under Art. 3(3)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 3, paragraph 3Click opens the article on EUR-Lex. switches on a requirement for a named category. Until it does, the Directive names no category that the requirement binds. On 20 January 2026 the Commission abandoned its initiative on software for reconfigurable radio systems, the one that would have used Art. 3(3)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)The whole regulationClick opens the law on the EU Publications Office., point (i), and Art. 4Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 4Click opens the article on EUR-Lex. (Commission, RED page). The Directive also allows type registration for categories with a low level of compliance, with a registration number on the product (Art. 5Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 5Click opens the article on EUR-Lex.). The Commission’s list of acts under the Directive names no act that switches that on.

Safety and electromagnetic compatibility come from two other Directives, with no voltage limit

Radio equipment is not subject to the Low Voltage Directive, except through its own safety requirement, which borrows the same objectives and drops the voltage range (Art. 1Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 1Click opens the article on EUR-Lex., Art. 3(1)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 3, paragraph 1Click opens the article on EUR-Lex.). A 5 V Bluetooth gadget is therefore assessed for electrical safety, which a non-radio 5 V product is not under the Low Voltage Directive, because that Directive starts at 75 V DC (Art. 1Directive 2014/35/EU, Low Voltage Directive (consolidated text of 30 May 2026)Article 1Click opens the article on EUR-Lex.). The Electromagnetic Compatibility Directive leaves out equipment covered by Directive 1999/5/EC (Art. 2(2)Directive 2014/30/EU, Electromagnetic Compatibility Directive (consolidated text of 30 May 2026)Article 2, paragraph 2Click opens the article on EUR-Lex.), and references to that repealed Directive now read as references to the Radio Equipment Directive (Art. 50Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 50Click opens the article on EUR-Lex.). The radio product is assessed under the radio Directive for both.

The assessment must take into account all intended operating conditions and, for safety, the reasonably foreseeable conditions. Where the equipment can take different configurations, the assessment has to confirm that it meets the requirements in all of them (Art. 17(1)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 17, paragraph 1Click opens the article on EUR-Lex.). The product’s other EU laws still apply next to the radio Directive: RoHS compliance for the substances inside it, and the battery and electronic waste rules for a product with a battery or a mains plug (battery regulation and WEEE registration).

Radio spectrum: the product must be usable in at least one EU country

The manufacturer must make sure the equipment can be operated in at least one EU country without infringing the rules on the use of radio spectrum there, and the importer checks that it did (Art. 10(2)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 10, paragraph 2Click opens the article on EUR-Lex., Art. 12(2)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 12, paragraph 2Click opens the article on EUR-Lex.). EU countries must allow the putting into service of compliant equipment. They may add requirements for putting it into service and use only for reasons of efficient use of spectrum, avoiding harmful interference, avoiding electromagnetic disturbance or public health (Art. 7Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 7Click opens the article on EUR-Lex.). Countries notify the radio interfaces they intend to regulate (Art. 8Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 8Click opens the article on EUR-Lex.). Where a restriction or an authorisation requirement exists, the product must say so. The section on restrictions below shows how.

Cybersecurity: three requirements switched on by Delegated Regulation (EU) 2022/30

Art. 3(3), points (d), (e) and (f), name three requirements: no harm to the network, protection of personal data and privacy, and protection from fraud (Art. 3(3)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 3, paragraph 3Click opens the article on EUR-Lex.). Delegated Regulation (EU) 2022/30 says which radio equipment must meet each one (Art. 1 of Delegated Regulation (EU) 2022/30):

• Network protection applies to any radio equipment that can communicate itself over the internet, directly or through other equipment.
• Personal data and privacy applies to radio equipment that can process personal data, traffic data or location data and is internet-connected, designed or intended exclusively for childcare, covered by the Toy Safety Directive 2009/48/EC, or designed to be worn on, strapped to or hung from the body or from clothing. The last three are covered without an internet connection. The Commission’s recital gives a wrist watch, a ring, a wristband, a headset, earphones and glasses as wearables, and says implants are not wearables, though an implant that can itself communicate over the internet counts as internet-connected (recitals 5 and 6).
• Fraud protection applies to internet-connected radio equipment that lets its holder or user transfer money, monetary value or virtual currency.

Radio equipment covered by the Medical Devices Regulation or the In Vitro Diagnostic Medical Devices Regulation is outside all three. The personal data and fraud requirements also leave out equipment covered by the civil aviation Regulation (EU) 2018/1139, the vehicle type-approval Regulation (EU) 2019/2144 and the road toll Directive (EU) 2019/520 (Art. 2 of Delegated Regulation (EU) 2022/30). A toy with a radio is also under the toy law (CE marking for toys).

The Regulation was first set to apply from 1 August 2024. Delegated Regulation (EU) 2023/2444 moved that to 1 August 2025 (Art. 1 of Delegated Regulation (EU) 2023/2444) and corrected the data wording in Art. 1(2) of the 2022 Regulation (Art. 2 of Delegated Regulation (EU) 2023/2444). The Commission’s RED page confirms that the Regulation has applied since August 2025.

EN 18031-1, EN 18031-2 and EN 18031-3 give a presumption of conformity, with restrictions

Radio equipment that conforms to harmonised standards, or to parts of them, whose references are published in the Official Journal is presumed to meet the requirements those standards cover (Art. 16Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 16Click opens the article on EUR-Lex.). For the three cybersecurity requirements, the standards are EN 18031-1:2024, EN 18031-2:2024 and EN 18031-3:2024. Commission Implementing Decision (EU) 2025/138 of 28 January 2025 published them in the Official Journal on 30 January 2025 as rows 164 to 166 of Annex I to Implementing Decision (EU) 2022/2191, and it entered into force that day (its Art. 2). The reference is OJ L, 2025/138, 30.1.2025.

The Commission gave its reasons in the recitals of the Decision. The “rationale” and “guidance” sections set out no specifications. The password options leave authentication risks unaddressed. The access-control categories may not suit parental control. None of the update methods alone suffices for financial assets (recitals 5 to 8).

Four later decisions amend Implementing Decision (EU) 2022/2191: those of 14 May 2025, 13 August 2025, 9 December 2025 and 4 September 2026 (the last is Decision (EU) 2026/2003). None of them mentions EN 18031. The Commission’s page lists the amendments up to 4 September 2026.

Using a standard is voluntary. A product that does not follow EN 18031, or follows it only in part, can still comply, but then a notified body must examine it (see the conformity route below). Your technical documentation lists the standards you applied in full or in part, and names the parts where you applied one only in part (Annex V, point (d)).

The common charger rules: USB-C, fast charging, the label and the sale without a charger

Directive (EU) 2022/2380 added the charging rules to the Radio Equipment Directive. They bind the equipment of 13 categories (Art. 3(4)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 3, paragraph 4Click opens the article on EUR-Lex., Annex Ia, Part I, point 1): handheld mobile phones, tablets, digital cameras, headphones, headsets, handheld videogame consoles, portable speakers, e-readers, keyboards, mice, portable navigation systems, earbuds and laptops. EU countries had to apply their national measures from 28 December 2024 for the first twelve categories and from 28 April 2026 for laptops (Art. 2(1) of Directive (EU) 2022/2380). The Commission’s page gives the same two dates.

What the rules ask, in so far as the equipment can be recharged by wired charging (Annex Ia, Part I):

• A USB Type-C receptacle, as described in EN IEC 62680-1-3:2022, that stays accessible and operational at all times, and the ability to charge with cables that comply with that standard.
• USB Power Delivery, as described in EN IEC 62680-1-2:2022, where the equipment can charge at more than 5 V, more than 3 A or more than 15 W. Any additional charging protocol must allow the full functionality of USB Power Delivery, whatever charger is used.
• A choice for the buyer. An operator that offers the equipment together with a charging device must also offer it without any charging device (Art. 3a(1)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 3a, paragraph 1Click opens the article on EUR-Lex.).
• A pictogram that shows whether a charging device is included. It is printed on the packaging or fixed to it as a sticker, and in distance selling it sits close to the price. The dimension “a” is at least 7 mm (Art. 3a(2)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 3a, paragraph 2Click opens the article on EUR-Lex., Annex Ia, Part III).
• A label and instructions that give the minimum and maximum power the charger must deliver and, where the equipment supports it, an indication of USB Power Delivery. They go in the instructions and on the packaging, or on the equipment itself where there is no packaging, and in distance selling close to the price (Art. 10(8)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 10, paragraph 8Click opens the article on EUR-Lex., Annex Ia, Parts II and IV).

Importers and distributors who sell to consumers must make sure the label is displayed (Art. 12(4)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 12, paragraph 4Click opens the article on EUR-Lex., Art. 13(2)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 13, paragraph 2Click opens the article on EUR-Lex.). The Directive’s recitals add that only equipment with a removable or embedded rechargeable battery is concerned, that a digital camera made exclusively for the audiovisual or the security and surveillance sector does not have to carry the harmonised charging solution, that earbuds count together with their charging case, and that a laptop is any portable computer (recital 14 of Directive (EU) 2022/2380). The Annex’s own condition is the wired charging capability.

The Commission’s Notice C/2024/2997 (OJ C, 7.5.2024), guidance rather than law, reads the rules the same way. They apply to a listed device that has a removable or embedded rechargeable battery and can be recharged by cable. The battery’s capacity does not matter (Q4, Q7). On stock, the Notice says the rules apply to each device first placed on the market on or after the application date, whether or not its model was already on sale. Stock placed on the market before that date may still be sold legally afterwards, and the Directive does not require chargers or cables already on the market to be thrown away (Q40, Q42).

The Annex references were later updated by Delegated Regulation (EU) 2023/1717 to the 2022 editions of the two standards, and the consolidated Directive shows that wording. The Directive lets you use Module A for the charging requirement (Art. 17(2)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 17, paragraph 2Click opens the article on EUR-Lex.).

What the Commission has said it is looking at next, as statements rather than law: its first report of 30 June 2026 identified seven categories it could add (smartwatches, fitness trackers, smart glasses, wristbands, AR and VR headsets, drones for personal use and video game controllers); by 28 December 2026 it must report on the impact of selling radio equipment without a charging device and without cables, with a legislative proposal if appropriate to make that unbundling mandatory (Art. 47(3)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 47, paragraph 3Click opens the article on EUR-Lex.). Separately, Regulation (EU) 2025/2052 sets ecodesign rules for external power supplies and USB Type-C cables from 14 December 2028, which the Commission describes as complementing the common charger.

Conformity assessment: Module A for spectrum and cybersecurity only where harmonised standards are fully applied

The manufacturer performs the conformity assessment of the radio equipment (Art. 17(1)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 17, paragraph 1Click opens the article on EUR-Lex.). Which procedures are open depends on the requirement and on the standards:

The rows come from Art. 17(2)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 17, paragraph 2Click opens the article on EUR-Lex., Art. 17(3)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 17, paragraph 3Click opens the article on EUR-Lex. and Art. 17(4)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 17, paragraph 4Click opens the article on EUR-Lex.. The third row is the only case in which the Directive requires a notified body. So a manufacturer that applied the harmonised standards for spectrum, and for the cybersecurity requirements that apply to its product, can assess the product itself. A product with a radio design that no published standard covers goes to a notified body for the spectrum requirement.

Under Module A the manufacturer draws up the technical documentation, takes the measures that keep production in line with it, affixes the CE marking and signs the declaration on its sole responsibility (Annex II). Under Annex III a notified body examines the technical design and issues an EU-type examination certificate; the manufacturer then declares conformity to that type. Under Annex IV a notified body approves the manufacturer’s quality system and audits it. Where Annex IV is used, the CE marking is followed by the notified body’s identification number, at the same height (Art. 20(3)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 20, paragraph 3Click opens the article on EUR-Lex.). A notified body is a body an EU country has notified to the Commission (Art. 22Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 22Click opens the article on EUR-Lex.); the Commission’s page for the Directive links the list of bodies notified under it.

Technical documentation and the declaration of conformity

The technical documentation holds the data or the means that show the equipment meets Art. 3Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 3Click opens the article on EUR-Lex.. It is drawn up before the equipment is placed on the market and kept up to date (Art. 21Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 21Click opens the article on EUR-Lex.). At least, wherever applicable, it holds (Annex V):

• a general description, with photographs or illustrations of the external features, marking and internal layout, the versions of software or firmware that affect compliance, and the user information and installation instructions;
• design and manufacturing drawings and schemes of components, sub-assemblies and circuits, with the descriptions needed to read them;
• the harmonised standards applied in full or in part, with the parts named, and where none was applied the solutions adopted and the other specifications used;
• a copy of the EU declaration of conformity, and any EU-type examination certificate;
• results of design calculations and examinations, and test reports;
• an explanation of how Art. 10(2)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 10, paragraph 2Click opens the article on EUR-Lex. (use in at least one EU country) is met and whether the restrictions information is on the packaging.

Test reports sit in the file as evidence. The declaration and the responsibility for it are the manufacturer’s (Art. 10(3)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 10, paragraph 3Click opens the article on EUR-Lex., Art. 18(4)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 18, paragraph 4Click opens the article on EUR-Lex.). If the documentation does not give enough data, the authority may ask the manufacturer or the importer to have a test done, at the manufacturer’s or importer’s own cost, by a body the authority accepts (Art. 21(4)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 21, paragraph 4Click opens the article on EUR-Lex.). The manufacturer keeps the documentation and the declaration for 10 years after placing on the market (Art. 10(4)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 10, paragraph 4Click opens the article on EUR-Lex.).

The declaration states that the essential requirements of Art. 3 are met. It follows Annex VI, is kept up to date and is translated into the languages the EU country of sale requires. Where the equipment is under more than one EU act that asks for a declaration, one declaration names them all (Art. 18(1)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 18, paragraph 1Click opens the article on EUR-Lex., Art. 18(2)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 18, paragraph 2Click opens the article on EUR-Lex., Art. 18(3)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 18, paragraph 3Click opens the article on EUR-Lex.). Annex VI has nine points:

1. The radio equipment (product, type, batch or serial number).
2. The name and address of the manufacturer or its authorised representative.
3. A statement that the declaration is issued under the sole responsibility of the manufacturer.
4. The object of the declaration, identified so it can be traced; it may include a colour image.
5. A statement that the object conforms to Directive 2014/53/EUDirective 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)The whole regulationClick opens the law on the EU Publications Office. and to other applicable Union harmonisation legislation.
6. The harmonised standards or other specifications used, each with its number and version and, where applicable, its date.
7. Where applicable, the notified body, what it did and its certificate.
8. Where applicable, the accessories and components, software included, that let the equipment operate as intended and are covered by the declaration.
9. Additional information, then the place and date of issue, and the name, function and signature of the signer.

A number for the declaration is optional (footnote 7 to Annex VI). The simplified declaration may travel in place of the full text. It reads: “Hereby, [name of manufacturer] declares that the radio equipment type [designation of type of radio equipment] is in compliance with Directive 2014/53/EUDirective 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)The whole regulationClick opens the law on the EU Publications Office.. The full text of the EU declaration of conformity is available at the following internet address:” (Annex VII). The address must be exact (Art. 10(9)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 10, paragraph 9Click opens the article on EUR-Lex.). The full text must be available there in the languages the country of sale requires.

What goes on the product, in the box, on the packaging and on the listing

• On the product: the CE marking, visibly, legibly and indelibly, on the equipment or its data plate unless that is not possible or not warranted given its nature; it is also affixed visibly and legibly to the packaging. Because of the nature of radio equipment, the CE marking may be lower than 5 mm if it stays visible and legible (Art. 19(2)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 19, paragraph 2Click opens the article on EUR-Lex., Art. 20(1)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 20, paragraph 1Click opens the article on EUR-Lex.). Also on the product: a type, batch or serial number, the manufacturer’s name, trade name or trade mark with a single postal address, and the importer’s name and postal address. Where size or nature does not allow it, this goes on the packaging or in a document that comes with the product (Art. 10(6)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 10, paragraph 6Click opens the article on EUR-Lex., Art. 10(7)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 10, paragraph 7Click opens the article on EUR-Lex., Art. 12(3)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 12, paragraph 3Click opens the article on EUR-Lex.).
• In the box: instructions and safety information in a language consumers can easily understand, as the EU country decides. They include, where applicable, a description of accessories and components, software included, that let the equipment operate as intended. For equipment that intentionally emits radio waves they give the frequency bands it uses and the maximum radio-frequency power it transmits. For Annex Ia devices they carry the charging information. A copy of the declaration or the simplified declaration comes with each item (Art. 10(8)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 10, paragraph 8Click opens the article on EUR-Lex., Art. 10(9)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 10, paragraph 9Click opens the article on EUR-Lex.). What a manual must hold is in EU user manual requirements.
• On the listing: the manufacturer’s name and postal and electronic address; where the manufacturer is outside the EU, the EU operator under Article 4(1)Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office. of Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office.; a picture and type of the product; and any warning or safety information that goes on the product, in a language consumers understand (Art. 19Regulation (EU) 2023/988, General Product Safety RegulationArticle 19Click opens the article on EUR-Lex. of the General Product Safety Regulation). For Annex Ia devices, the charging pictogram and label sit close to the price. The GPSR’s manufacturer and importer duties in Chapter III, Section 1 do not apply to a product under Union harmonisation legislation; its rules on online offers do (Art. 2(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 2, paragraph 1Click opens the article on EUR-Lex.).

Restrictions on use: a pictogram on the packaging and a list in the instructions

Where an EU country restricts putting radio equipment into service or requires an authorisation to use it, the packaging must let the buyer identify that country or the area within it, and the instructions complete the information (Art. 10(10)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 10, paragraph 10Click opens the article on EUR-Lex.). Implementing Regulation (EU) 2017/1354 sets the form. It applies only to radio equipment that is subject to such a restriction or requirement in at least one EU country (Art. 1 of Implementing Regulation (EU) 2017/1354). Then:

• the packaging shows, visibly and legibly, either a pictogram set out in its Annex I, or the words “Restrictions or Requirements in” followed by the abbreviations of the EU countries concerned from its Annex II;
• the instructions list the EU countries and the geographical areas where the restrictions or requirements exist, and the type of restriction or requirement in each, in a language end users easily understand (Art. 2 of Implementing Regulation (EU) 2017/1354).

Equipment placed on the market after 8 August 2017 that conforms to the Regulation is deemed to meet Art. 10(10) (Art. 3 of Implementing Regulation (EU) 2017/1354). The technical documentation says whether the packaging carries this information (Annex V, point (i)).

What each role owes

What changes when you sell online from outside the EU

An online offer targeted at end users in the EU counts as making the product available on the EU market (Art. 6Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 6Click opens the article on EUR-Lex. of Regulation (EU) 2019/1020). The Directive defines an importer as someone established in the EU and an authorised representative as someone established in the EU with a written mandate (Art. 2Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 2Click opens the article on EUR-Lex.), so a seller outside the EU shipping straight to EU buyers has neither by default.

Directive 2014/53/EUDirective 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)The whole regulationClick opens the law on the EU Publications Office. is one of the laws listed in Art. 4(5)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 5Click opens the article on EUR-Lex. of Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office.. A product under it may be placed on the market only if an economic operator established in the EU is responsible for it (Art. 4(1)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 1Click opens the article on EUR-Lex.). That operator is any of these: an EU manufacturer; the importer, where the manufacturer is not in the EU; an authorised representative with a written mandate; or, where none of those is established in the EU, an EU fulfilment service provider for the products it handles (Art. 4(2)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 2Click opens the article on EUR-Lex.). It verifies that the declaration and technical documentation exist, keeps the declaration at the disposal of the authorities, makes sure the documentation can be produced, cooperates with the authorities and informs them of a risk (Art. 4(3)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 3Click opens the article on EUR-Lex.). Its name, trade name or trade mark and contact details, postal address included, go on the product, its packaging, the parcel or an accompanying document (Art. 4(4)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 4Click opens the article on EUR-Lex.). Who can hold the role is the EU Responsible Person.

The Cyber Resilience Act takes over the cybersecurity rules from 11 December 2027

Regulation (EU) 2024/2847, the Cyber Resilience Act, covers products whose intended or reasonably foreseeable use includes a direct or indirect data connection to a device or network (its Art. 2(1)Regulation (EU) 2024/2847, Cyber Resilience ActArticle 2, paragraph 1Click opens the article on EUR-Lex.). Its exclusions in Art. 2(2)Regulation (EU) 2024/2847, Cyber Resilience ActArticle 2, paragraph 2Click opens the article on EUR-Lex. to 2(4)Regulation (EU) 2024/2847, Cyber Resilience ActArticle 2, paragraph 4Click opens the article on EUR-Lex. name medical devices, vehicle type-approval, certified aviation products and marine equipment; radio equipment is not among them. A Wi-Fi or Bluetooth product with a data connection is therefore under both laws. How the two meet:

The Commission repealed the cybersecurity delegated act because Annex I of the Cyber Resilience Act includes all the elements of the three requirements, and it wanted to prevent radio equipment from being under both at once (Delegated Regulation (EU) 2026/339, recitals 3 and 4). The repeal changes nothing for the other requirements: it removes only Delegated Regulation (EU) 2022/30. Safety, interference, spectrum and charging stay under the Radio Equipment Directive. For radio equipment placed on the market between 1 August 2025 and 10 December 2027 that was subject to any of the three requirements, the repeal does not end market surveillance under the Directive (recital 5).

The Cyber Resilience Act applies to products placed on the market from 11 December 2027. Products placed on the market before then come under it only if they are substantially modified after that date (Art. 69(2)). Its recital 30 asks the Commission and the standards bodies to take the work done under the standardisation request for EN 18031 into account when they prepare standards for the Act. The recital does not say whether EN 18031 will give a presumption of conformity under the Cyber Resilience Act. What the Act asks of connected products, the support period and the dates are on the Cyber Resilience Act guide. For a connected radio product, one declaration is drawn up for both acts (Art. 18(3)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 18, paragraph 3Click opens the article on EUR-Lex.).

What happens if you sell without it

Without the CE marking, the declaration or the documentation, the product stays off the shelf: an importer must make sure they exist before placing the product on the market, and a distributor must check them before making it available (Art. 12(2)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 12, paragraph 2Click opens the article on EUR-Lex., Art. 13(2)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 13, paragraph 2Click opens the article on EUR-Lex.).

An EU country that finds any of these must require the economic operator to end the non-compliance (Art. 43(1)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 43, paragraph 1Click opens the article on EUR-Lex.): the CE marking affixed wrongly or not at all; the notified body number wrongly affixed or missing where Annex IV is used; no declaration, or one drawn up wrongly; technical documentation missing or incomplete; the charging pictogram or label wrong, missing or not displayed; the manufacturer’s or importer’s details absent, false or incomplete; the information in the instructions, the declaration or the restrictions information not accompanying the equipment; or the duties on identifying economic operators, on the sale without a charger (Art. 3a(1)) and on registration (Art. 5) not met. If it persists, the country takes all appropriate measures to restrict or prohibit the product, or to have it recalled or withdrawn (Art. 43(2)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 43, paragraph 2Click opens the article on EUR-Lex.).

Where equipment presents a risk or does not meet an essential requirement, the authorities evaluate it and require corrective action, withdrawal or recall within a reasonable period. The operator must make sure the action covers every unit it made available throughout the Union (Art. 40Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 40Click opens the article on EUR-Lex.). Equipment that complies but presents a risk can be pulled the same way (Art. 42Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 42Click opens the article on EUR-Lex.). Penalties are set by each EU country, which must make them effective, proportionate and dissuasive; they may include criminal penalties for serious infringements (Art. 46Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 46Click opens the article on EUR-Lex.).

Great Britain and Northern Ireland have their own radio rules

For England, Wales and Scotland the rules are the Radio Equipment Regulations 2017 (S.I. 2017/1206). They apply to radio equipment, with exclusions for equipment placed on the market before the commencement date, the equipment listed in their Schedule 1 and radio equipment used exclusively for public security, defence, State security or criminal law (reg. 3). Radio equipment within them is not subject to the Electrical Equipment (Safety) Regulations 2016 or the Electromagnetic Compatibility Regulations 2016, except as regulation 6 provides (reg. 3).

GOV.UK says the UK continues to recognise the CE marking, alongside or in place of the UKCA marking, for Great Britain, and lets a manufacturer self-declare conformity under the Radio Equipment Regulations 2017 for all products, except where designated standards covering the essential requirements do not exist or the manufacturer has not applied them in full or in part. For CE marked radio equipment placed on the Great Britain market from 1 August 2025, GOV.UK’s factsheet says the manufacturer must meet the requirements made applicable by Regulation (EU) 2022/30, with updated technical documentation and declaration.

The UK also has its own connected-product rule. The Product Security and Telecommunications Infrastructure Act 2022 and Regulations 2023, in force since 29 April 2024, require manufacturers of relevant consumer products that connect to the internet or a network to ban universal default and easily guessable passwords, publish how to report security issues and publish the minimum security update period, and to provide a Statement of Compliance. Importers and distributors have their own compliance duties under the Act (GOV.UK). The regime leaves out electric vehicle charge points, medical devices, smart meter products and certain vehicles, and desktop computers, laptops and tablets with no cellular capability, unless the manufacturer designed them exclusively for children under 14. Products in scope of the Radio Equipment Directive made available in Northern Ireland are excepted from that regime.

In Northern Ireland the Radio Equipment Regulations 2017 apply too, modified on 28 December 2024 for the USB-C charging rules and on 16 December 2025 for cybersecurity requirements for internet-connected radio equipment, childcare devices and wearables that process personal, traffic or location data (GOV.UK). GOV.UK says Regulation (EU) 2022/30 applies in Northern Ireland from 1 August 2025 (factsheet). The UKCA marking does not replace the CE marking in the EU. The CE marking is the only marking that attests conformity with EU harmonisation law (Art. 30(4)Regulation (EC) No 765/2008, accreditation and market surveillance (CE marking)Article 30, paragraph 4Click opens the article on EUR-Lex.).

What the law leaves open

• Whether following a standard that carries a restriction counts as having “applied” it. The route in Art. 17(3)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 17, paragraph 3Click opens the article on EUR-Lex. depends on having applied harmonised standards. Implementing Decision (EU) 2025/138 says the three EN 18031 standards give no presumption in the listed cases. A manufacturer who applied a standard only in part goes to a notified body (Art. 17(4)Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 17, paragraph 4Click opens the article on EUR-Lex.). Neither text says whether a case inside a restriction counts as applied in part. The notified-body route is the one the text clearly allows.
• Whether a Bluetooth-only product counts as internet-connected. Art. 1 of Delegated Regulation (EU) 2022/30 covers equipment that “can communicate itself over the internet, whether it communicates directly or via any other equipment”. Its recital 5 describes such equipment as operating “protocols necessary to exchange data with the internet either directly or by means of an intermediate equipment”. Neither says how to treat a gadget that speaks only Bluetooth to a phone app. A wearable, a toy or a childcare device is covered for personal data with no internet connection at all.
• Which countries restrict use. The Directive lets each country notify the interfaces it regulates (Art. 8Directive 2014/53/EU, Radio Equipment Directive (consolidated text of 30 May 2026)Article 8Click opens the article on EUR-Lex.) and sets the form of the information that follows, but it holds no list of countries. The manufacturer finds the restriction from the national notifications.
• Whether the standards for the Cyber Resilience Act will reuse EN 18031. Recital 30 of that Regulation asks that the work be taken into account. It says no more.

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