Q1: Can the product simultaneously claim compliance with RED, LVD and EMCD as stipulated in RED 2014/53/EU?

　　SGS replied: No. Products falling within the RED scope only need to claim compliance with the RE Directive. The reason is that products within the RED scope do not fall within the LVD and EMCD scopes; instead, they need to meet the requirements of LVD and EMCD as stipulated in Article 3 of the RE Directive.

　　Q2: Under what circumstances is it necessary to apply for the RED Notified Body EU-Type Examination Certificate for the product, and then proceed with RED Annex III Module B or Annex IV Module H to comply with the assessment procedure?

　　SGS replied: There are two situations where an application is necessary:

　　1) When the manufacturer does not adopt or only partially uses the harmonized standards published on the OJ EU to assess the requirements of Article 3.2 and/or 3.3;

　　2) Evaluate the situation where the coordination annotations in Article 3.2 and/or 3.3 do not exist.

　　The assessment methods for RED NB are divided into two types: Module B (RED NB EU-TEC) and Module H. Manufacturers can choose either one according to their actual needs. The latter has stricter requirements and a longer cycle, and can use the NB ID on the product for appropriate endorsement. Applying for Module B, which is NB TEC, is the best choice for peers.

　　Q3: Is it necessary to apply for the assessment of Article 3.1a (Safety, Health), Article 3.1b (EMC), Article 3.2 (Radio Spectrum), and/or Article 3.3 when applying for the NB type approval (Annex III Module B)?

　　SGS replied: Not necessarily. The application for RED NB intervention assessment under Article 3.1 (Safety, Health) and Article 3.2 (EMC) is voluntary. Manufacturers can choose based on actual needs. As mentioned in the answer to point 2, only 3.2 and/or 3.3 are mandatory. For devices under the RE Directive scope, all can apply for RED NB TEC. Whether or not to apply for RED NB TEC, products within the scope of the directive must comply with the requirements of Article 3 of the directive and all the requirements of the RE Directive. Applying for NB TEC means that a third-party assessment body intervenes for inspection, and the notification and implementation of the directive requirements are more thorough.

　　Q4: What current authorization regulations are there under RED Article 3.3?

　　SGS replied: Excluding Article 3.3.g which states that radio equipment must support certain functions to ensure access to emergency services.

　　There are the following applicable regulations: Articles 3.3.a to 3.3.i all have no authorized regulations.

　　2000/637/EC: Inland Waterway Radio Telephone Service;

　　2001/148/EC: Avalanche Beacon;

　　2013/638/EC: For non-SOLAS ships and participating in the Global Maritime Distress and Safety System (GMDSS);

　　2005/53/EC: Automatic Identification System (AIS)

　　2005/631/EC: Cospas-Sarsat Positioning Beacon.

　　Q5: When it comes to choosing between effective coordinated standards and non-coordinated standards, must the manufacturer opt for the coordinated standards?

　　SGS replied: No. Manufacturers can voluntarily adopt the harmonized standards. The harmonized standards merely offer an advantage in terms of presuming product conformity.

　　Q6: What are the specific points to note regarding the EU DoC?

　　SGS replied: If a product falls under the control of multiple regulations and meets the requirements of multiple regulations, a Single DoC should still be issued. This Single DoC can consist of multiple pages and should not issue multiple separate EU DoCs. Each radio equipment must be accompanied by a DoC or a simplified DoC (that is, at least one of them should be in printed form).

　　Question 7: RED requires that the manufacturer's name and address be displayed on the product or packaging (as the first option if the product cannot convey this information), or on other accompanying materials shipped to the consumers. Does the manufacturer's address need to be the actual physical address of the manufacturer?

　　SGS replied: There is no mandatory requirement for the actual physical address of the manufacturer. This address should be a specific one that is convenient for the manufacturer to be reached directly, especially for the market inspection agencies in various EU countries to contact their companies. For example, the address could also be the address of the manufacturer's EU authorized representative or the product customer service address. The manufacturer's website is not considered as a single contact address that meets the requirements.

　　Q8: What exactly do the product guidelines provided by RED and the EU DoC refer to as the components and software? How should they be presented?

　　SGS replied: The manufacturer only needs to describe those accessories and components, including software: when (1) it has an impact on the conformity of the radio equipment, and (2) the user can install or replace them without the manufacturer's involvement. The manufacturer can determine the format and description level of these accessories and components (including software), as long as they can be identified.

　　Q9: For radio equipment with usage restrictions or usage authorization requirements, what are the specific requirements for packaging and product instructions?

　　SGS replied: Article 10.10 of the RED requires manufacturers to display on the packaging the names of the member states or geographical areas where these restrictions or permit applications exist. The official document specifying the specific methods is Regulation (EU) 2017/1354 of 20 July 2017. Here is an example of each method:

　　Text form

　　Restrictions in ES CZ SI LU FR DK RO HU HR

　　In the form of pictures