Orgalime guidance on the manufacturer’s obligations for the combination of a machine with radio equipment

Published: 12 June 2017

Policies & Issues: Internal Market - Compliance, Standards & Enforcement

12 June 2017 marks the end of the transitional period for products placed on the market under the old Radio and Telecommunications Terminal Directive (R&TTED). This means that from 13 June on, the products placed by manufacturers on the market must comply with the Radio Equipment Directive (RED). The changeover is requiring engineering companies to revise their conformity assessment procedures, and Orgalime has been providing support to ensure as smooth a transition as possible – including with the publication of this new guide, which helps clarify manufacturers’ obligations for the combination of a machine with radio equipment.

This guidance document is addressed to manufacturers of machines who use radio equipment on the machine. In the document, it is assumed that only radio equipment bearing CE-marking in accordance with the Radio Equipment Directive 2014/53/EU (RED) is incorporated into the final product/machine. The combination of radio equipment with non-radio products is also addressed by the European Commission’s Guide to the Radio Equipment Directive, in the explanations provided by the RED Administrative Cooperation Group (AdCo) and the Telecommunication Conformity Assessment and Market Surveillance Committee (TCAM), in the following way: “Non-radio products (i.e. electrical or electronic products whose function is not to intentionally emit or receive radio waves), may function with radio equipment.”

Orgalime’s guidance document is intended to provide information on the application of the RED with respect to machinery containing radio equipment. This can help provide clarification in cases that commonly occur in practice, such as:

- Radio equipment is operated on new machinery without being attached to the machinery in a fixed way or being incorporated into the machinery

- Radio equipment is incorporated in new machinery in a fixed and permanent way

- Used machinery is retrospectively fitted with radio equipment

- Radio equipment is incorporated in partly completed machinery in a fixed and permanent way

Download the guide above to find out more. 


Philippe Portalier
Director - Better Regulation, Compliance and Standards
Eleonora Piccinni
Manager - Technical Regulation

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