The Radio Equipment Directive comes into force this year: what do you need to know?

The RED, which came into force on 13 June 2016, replaces the Radio and Telecommunications Terminal Equipment Directive (R&TTE Directive 1995/5/EC).

With a significant bearing on how manufacturers gain a CE Mark, due to changes between the two frameworks, it’s crucial to fully understand these regulatory differences in order to avoid time and cost overruns.

Here’s an overview of the RED – its scope, impact on product design and on what you should do next.

Regulatory necessity
In the past, devices that depended on the RF spectrum for their functionality consisted mainly of AV equipment, PCs and telecommunications technology.

Since 2000, however, regulatory compliance and conformity has come under the Radio and Telecommunications Terminal Equipment Directive (RTTE).

Now, the Internet of Things has ushered in an age of ultra-connectivity, with millions of items connected and communicating daily; smart cars, meters, jewellery, fitness devices – even smart paper. The list seems endless.

The relentless proliferation of IoT is also widely believed to have been a contributory factor to the revisions to the RTTE Directive.

RED – its aims
The driving forces behind this new regulation were improving market surveillance and raising the number of products meeting compliance requirements.The RED ensures all radio devices (or ‘apparatus’) within its remit are compatible for use in the EU.

This is done through a regulatory mandate of standard technical requirements for telecommunications apparatus; allowing approved equipment to be sold without restriction between countries in the European Economic Area (EEA).

Enforcement
The RTTE Directive was replaced by RED on 13 June 2016 with a one-year grace period, during which both the old and new Directives may be used for product compliance.The RTTE will be repealed on the 13 June 2017, after which only the RED will apply.

RED – what’s new?
The main changes include:

• No provision for Telecom Terminal Equipment (TTE); this now comes under the EMC (EMC) or Low Voltage (LVD) Directives
• No lower limit to the radio frequency spectrum. Under the RTTE Directive, the range covered was between 9kHz and 3000GHz.
• LVD safety obligations: no voltage limits for radio equipment
• No alert sign (Class 2 labelling)
• Provision for universal chargers to address wastage
• Closer regulation of the activities of Notified Bodies
• The manufacturer must inform the Notified Body of all modifications to the product that may affect compliance
• Further clarification on market surveillance guidelines

The RED’s scope includes:

• All radio receivers (broadcast TV and radio equipment included)
• Equipment capable of being connected to a public telecommunications network even if that is not its intended purpose

Examples of equipment falling within the scope of the RED include:

• Cordless and mobile phones
• Terminal adapters
• Telephones
• Modems

Legacy products must also meet the latest RED harmonised standards.The EMC, Safety and Radio RTTE harmonised standards will eventually be harmonised under RED. However, the RED’s scope excludes:

• Amateur radio kits
• Marine equipment
• Airborne components and products (which fall under Article 3 of regulation EC216/2008)
• Equipment for military, police and state-security

There are currently very few RED harmonised Radio standards and the R&TTE list has disappeared.

Who’s affected?
The RED applies to:

• All 27 EU member states
• Three EEA countries
• Switzerland

RED and the EMC Directive
Anne Barr from The Compliance Map, a developer of supply chain and environmental compliance software solutions, explains how RED affects the EMC Directive. ”The EMC Directive requires equipment to be designed and manufactured in such a way that ensures any electromagnetic disturbance generated does not impact the operation of radio and telecommunications equipment and that the device itself is not impacted by such disturbance. It specifically excludes equipment covered by the RED.

“Therefore, the changes introduced by RED had two direct impacts on EMC:

• Telecom Terminal Equipment previously covered by RTTE and not included in RED now falls within the EMC.
• Sound and TV receive only equipment and radio equipment operating at frequencies of less than 9kHz previously excluded from RTTE are no longer by covered by the EMC.

“However, Article 3 of RED requires radio equipment to have an adequate level of electromagnetic compatibility as set out in EMC, recognising that the essential requirements of the EMC were sufficient to cover equipment covered by RED. This effectively merges the requirements of EMC into RED.”

Impact on product designers
For new products, the impact on product designers is minimal, as most products that fall under RED would also have fallen under RTTE, so the testing will be required anyway.

The main problem at the moment is overcrowding and high charges at test houses, due to the retesting of existing products, as well as new ones. In addition, the lack of clarity due to RED not yet having been passed into UK law UK is adding to delays for product designers.

What action needs to be taken now?
Barr shares the key next steps for electronics companies: “First, determine whether products you design, manufacture, import or distribute are within the scope of the new Directive, given the changes that have taken place.

“If you are affected by the Directive, then a compliance project plan should be designed and implemented to meet the regulatory deadline of 13 June.

“Roles and responsibilities for the compliance project plan should be assigned and budget allocated for:

• ensuring that the legislative requirements are understood and that changes – for example, with respect to product registration – are tracked
• reviewing and updating existing conformity assessment procedures. The use of harmonised standards should be considered as thisallows self-declaration of conformity. ETSI is currently in the process of developing these for different product types and OEMs should monitor progress
• revising product labelling, technical documentation and declaration of conformity, as appropriate
• amending risk management procedures, such as sample testing, complaints monitoring and product recall as needed
• communicating requirements, both internally and externally.“

Post Brexit; what happens now?
Despite talk of a return to British Standards Institute (BSI) conformance, it’s too early to speculate about a potential two tier compliance system for UK manufactured devices.

Britain is in the early stages of leaving the EU, a process which is likely to take two years. So, as far as EU legislation – including the RED – is concerned, it’s business as usual.

To find out more on European harmonised radio spectrum usage, try the EFIS tool (www.efis.dk) – the European Communications Office’s Frequency Information System.

Author profile:
Dunstan Power is director of ByteSnap Design