Clarification Regarding Brexit and the Application of the Radio Equipment Directive

The Radio Equipment Directive Compliance Association (REDCA), forum of the European Economic Area, addresses questions currently raised in the application of the Radio Equipment Directive (RED), and as it pertains to Brexit.


Q: After Brexit, can we place CE marking products on the UK market in the same way as in the EU?

A: At this moment it most likely that there will be no MRA between UK and EU (and also other regions/countries). This means that UK will be considered to have their own rules for market access. There has been a publication how products should be labelled and the process of putting products on the UK market.

Q: Are Type Examination Certificates issued by a Notified Body in the UK valid after March 29, 2019?

A: A certificate can only be issued by an EU Notified Body. Since UK is no longer a EU member state, the Notified Bodies of the UK will no longer be able to submit certificates after March 29th. Also, equipment accompanied by a Type Examination Certifcate issued by a UK Notified Body before March 29th cannot be accepted after March 29th. This is based on the fact that each individual product has to comply with EU regulations valid at the moment it enters the EU market.

European safety rules for civil drones:

Q: What are the current regulations with respect to drones in the EU?

A: National regulations ruling civil operations of drones lighter than 150 kg are replaced by new European legislations. Regulation (EU) 2018/1139, applicable as of 11/9/2018, repealed and replaced Regulation 216/2008 as amended.

Q: Are drones in the scope of the Radio Equipment Directive?

A: Yes, drones are subject to the RED, see the new RED guide of December 2018, clause

Equipment operating below 9 kHz:

Q: Without harmonized standards, is it possible to bring equipment operating on frequencies below 9 kHz on the EU market?

A: Yes, although it is recommended to consult a Notified Body.

Broadcast receivers:

Q: Are broadcast receivers covered by the RED?

A: Yes, broadcast receivers are covered by the RED and no longer by the EMC-D and LVD.

Q: How can Broadcast receivers comply with the RED?

A: For Broadcast sound receivers (e.g. FM, AM DAB, DVB-T) there are currently no art. 3.2 Harmonized standards available yet. You need to use and to consult a Notified Body to show compliance with the RED art. 3.2.

Radio modules:

Q: Does a radio modular approvals system exist in the EU?

A: RED does not describe or defines โ€œModulesโ€, so RED has no separate regulation for โ€œModules.โ€

Q: How to show compliance when an approved RE (approved module) is included in the end device?

A: If a Radio Equipment device is incorporated into a non-radio product (such as Toys, Machines, Kitchen Appliances) in a permanent way and cannot be easily accessed and removed by the user, the new end device (the non-radio device + the radio-device) has to comply with the RED.

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