Introduction: The Importance of REDCA May 2025 for Radio Equipment Regulation
The Radio Equipment Directive Committee (REDCA) meeting held on May 14, 2025, represents a critical milestone in the evolution of radio equipment regulation in the European Union. This gathering of regulatory authorities, industry experts, standardization bodies such as ETSI, and the European Commission focused on the latest developments in the implementation and adaptation of the Radio Equipment Directive (RED 2014/53/EU).
With the rapid advancement of wireless technologies, increasing cybersecurity threats, and the broader EU digital policy landscape evolving through initiatives like the Cyber Resilience Act (CRA), the meeting’s outcomes have far-reaching implications. The discussions covered harmonised standards, compliance methodologies, market surveillance, and new regulatory challenges, including the expanding scope of the Common Charger directive and the treatment of refurbished products within the New Legislative Framework.
1. Cybersecurity Regulation: Transition from RED to the Cyber Resilience Act
1.1 Background on Cybersecurity in Radio Equipment
The RED includes specific cybersecurity requirements intended to protect radio equipment against cyber threats. However, with the EU Cyber Resilience Act (CRA) slated for application, there is a regulatory transition underway. The CRA provides a more centralized and comprehensive cybersecurity framework for digital products, including radio equipment.
1.2 EN 18031 Standards and Their Restricted Use
The meeting confirmed that the EN 18031 series, which addresses cybersecurity requirements for radio equipment, was published with certain restrictions by ETSI. The Commission has issued guidance via Circabc, clarifying the conditions under which these standards may be used for conformity assessment.
In particular, manufacturers must comply with the constraints described in the guidance, ensuring alignment with both RED and CRA provisions. This dual applicability requires detailed risk assessment and mitigation plans, focusing on software vulnerabilities, secure communication protocols, and threat detection mechanisms.
1.3 Repeal of the RED Delegated Act on Cybersecurity
The REDCA meeting acknowledged the Commission’s intention to repeal the RED delegated act on cybersecurity once the CRA comes into force. The CRA’s broader scope and harmonized cybersecurity requirements will supersede existing RED obligations, offering a single regulatory pathway for cybersecurity compliance.
1.4 Upcoming Technical Guidance Note (TGN) on Cybersecurity
A draft Technical Guidance Note is under development to assist stakeholders in understanding the practical application of RED cybersecurity provisions during the CRA transition period. This TGN will address:
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Conditions for applying EN 18031 standards under restriction
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Assessment methodologies for cybersecurity risk in radio equipment
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Clarification of responsibilities between modules and integrated radio components
Why it matters: This guidance will reduce uncertainty in product conformity assessments, helping manufacturers avoid costly redesigns and delays in market access.
2. Harmonised Standards: Progress, Challenges, and Future Outlook
2.1 Current State of Harmonised Standards under RED
Harmonised standards provide a presumption of conformity with the RED, facilitating market access for compliant products. Since 2022, ETSI has published 48 standards relevant to the RED, but as of May 2025, only 10 have been cited in the Official Journal of the European Union (OJEU). This lag limits the ability of manufacturers to rely on harmonised standards for conformity assessments.
2.2 Reasons for Delays in Publication in OJEU
The Commission highlighted several technical and procedural issues causing delays:
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Environmental Profiles and Measurement Uncertainty: Some standards lacked detailed environmental profile definitions or failed to address measurement uncertainties comprehensively, causing doubts about repeatability and reliability of testing results.
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Normative References to Non-European Documents: Certain standards referenced non-European or non-harmonised documents, complicating their official recognition under EU law.
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ETSI Document Structure: The formatting and clarity of some ETSI documents did not meet the Commission’s requirements for harmonisation decisions.
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Scope Interpretation: Ambiguities in standard scope led to questions about their applicability to all intended product categories under RED.
2.3 Upcoming Harmonised Standards
The Commission anticipates publishing decisions for an additional 20 standards in the near term, addressing:
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DECT phones
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RFID technologies
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Airline and satellite communications equipment
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Environmental impact and EMC standards
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Short Range Devices (SRDs)
These additions will provide manufacturers with updated tools to demonstrate compliance efficiently.
2.4 Deletion of Standards and Standards Disputes
The meeting also discussed the deletion of certain standards, notably those concerning Autonomous Maritime Radio Devices (AMRDs), due to evolving regulatory priorities and technical assessments.
One prominent dispute concerns EN 301 893 (5 GHz RLAN), where ETSI maintains the current version meets RED requirements, but regulators continue to debate compliance status. The outcome will influence future conformity assessment practices and potentially affect hundreds of wireless products.
3. Expansion of the Common Charger Directive and Its Implications
3.1 Recap of the Common Charger Directive
The EU’s Common Charger initiative aims to reduce electronic waste by standardizing charging solutions across various devices. Initially focused on smartphones, tablets, and similar electronics, the directive promotes interoperability and sustainability.
3.2 Recent Interpretations and Wireless Charging
In May 2024, the Commission published a clarifying interpretative document answering frequently asked questions on the directive’s application. The REDCA meeting highlighted a recent standardisation request for developing wireless charging protocols, recognizing the increasing prevalence of inductive and resonant wireless charging technologies.
3.3 Potential Scope Extension by End of 2025
A study commissioned by the Commission is examining the feasibility of extending the Common Charger directive to new product categories, including:
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Wearable devices (e.g., smartwatches, AR/VR headsets)
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Drones and radio-controlled toys
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Electric toothbrushes and personal care devices
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Video game controllers and peripherals
The study, expected to conclude by the end of 2025, will inform potential amendments to the directive.
3.4 Unbundling of Chargers from Devices
The issue of whether chargers must be sold separately from devices (unbundling) remains under consideration, with a targeted Commission decision due by December 2026. The outcome will affect manufacturers’ product packaging, marketing strategies, and environmental claims.
4. Market Surveillance and Safeguard Clauses: SAR Testing and iPhone 12 Case
4.1 Overview of SAR and Regulatory Limits
Specific Absorption Rate (SAR) measures the rate at which human tissue absorbs radiofrequency energy. The EU limits SAR exposure to 2 W/kg averaged over 10 grams of tissue to ensure safety.
4.2 French Safeguard Procedure on iPhone 12
ANFR (France’s National Frequency Agency) initiated a safeguard clause under the RED after identifying that certain iPhone 12 models exhibited SAR levels exceeding regulatory limits. Ireland has formally objected to this procedure, leading to an EU Commission decision pending publication.
This case underscores the critical role of market surveillance authorities in enforcing compliance and protecting consumers.
4.3 Standards Under Revision for SAR Testing
EN 50566, the primary standard for SAR testing in Europe, has been revised following formal objections. In addition, several IEC standards relevant to SAR measurement and power density are under active development or amendment:
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IEC 62209 series on SAR measurement methods
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IEC 63127 on SAR power density measurement
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IEC 63171 concerning system-based SAR
These efforts aim to harmonize SAR testing methodologies globally and improve measurement precision.
5. Technical Guidance Notes (TGNs): Enhancing Compliance Clarity
5.1 Purpose and Role of TGNs
Technical Guidance Notes complement RED provisions by offering detailed explanations and best practices for conformity assessment, risk evaluation, and standard application.
5.2 New and Updated TGNs Presented at REDCA May 2025
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TGN 33: Clarifies requirements for radio equipment installed in vehicles, including EMC considerations and type approval procedures.
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TGN 29: Provides guidance on managing type examination certificates, emphasizing renewal, changes, and modular approval processes.
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TGN 30: Offers a refined risk assessment methodology for manufacturers, focusing on harmonized approaches to identifying and mitigating radio interference and cybersecurity risks.
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New Draft TGN on EN 18031 Restrictions: Details conditions for applying cybersecurity standards published with restrictions, ensuring conformity without compromising security integrity.
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TGN 01 Update: Updates on responsibilities concerning radio modules, clarifying interface requirements and manufacturer obligations.
These TGNs represent a vital resource for harmonizing regulatory interpretation across EU member states and industry.
6. Emerging Topics: Reconfigurable Radio Systems, AI Act, and Refurbished Products
6.1 Reconfigurable Radio Systems (RRS)
A study on RRS, which includes devices capable of changing radio parameters via software, is ongoing. The REDCA meeting acknowledged that potential interference risks might prompt new regulatory measures to ensure coexistence with existing radio systems.
6.2 Intersection with the Artificial Intelligence Act (AI Act)
Discussions also touched on the AI Act, currently in legislative development, which may impact radio equipment that incorporates AI functionalities. Clarifying how radio devices fit into AI regulatory categories is critical to avoid conflicting requirements.
6.3 Refurbished Products and Circular Economy
The treatment of refurbished radio equipment within the New Legislative Framework is an increasing concern. The risk of non-compliant refurbished devices entering the market from non-EU sources threatens the integrity of the single market and environmental objectives.
7. Global Perspectives: Mutual Recognition Agreements and FCC Cybersecurity Initiatives
7.1 Mutual Recognition Agreements (MRAs)
The REDCA meeting reviewed progress on MRAs with key partners, including the USA, UK, and Japan, focusing on mutual acceptance of conformity assessments and test reports. These agreements facilitate trade by reducing redundant testing and aligning technical requirements.
7.2 FCC Cybersecurity Labelling Scheme
The US National Institute of Standards and Technology (NIST) and the Federal Communications Commission (FCC) have launched a voluntary cybersecurity labelling initiative for wireless devices. This scheme serves as a potential model for similar European efforts aimed at improving transparency and trust in connected devices.
Conclusion: Navigating the Future of Radio Equipment Compliance
The REDCA May 2025 meeting demonstrated the EU’s commitment to maintaining robust, adaptive, and harmonized radio equipment regulations amidst rapid technological changes. The integration of cybersecurity under the Cyber Resilience Act, evolution of harmonised standards, and expanded directives like the Common Charger exemplify the multifaceted challenges regulators and manufacturers face.
For stakeholders in the radio equipment ecosystem, understanding these detailed regulatory updates is essential to ensure ongoing compliance, avoid market access delays, and contribute to the EU’s goals of safety, sustainability, and innovation.
Entirety remains at the forefront of navigating these complex regulatory landscapes, offering expert consultancy and certification services to ensure your products meet evolving European requirements.