Internal Market: Common understanding of the term “Internet-connected radio equipment” 

The delegated regulation (EU) 2022/30 defines in Article 1 a “internet-connected radio equipment” as “any radio equipment that can communicate itself over the internet, whether it communicates directly or via any other equipment”. A common understanding of the term “internet-connected radio equipment” is key for both the European Standardisation Organisations (ESO)s and economic operators, but also for market surveillance authorities, for the following reasons:

• Basis for the development of harmonised standards (including security risk assessment),

• Identification of products within the scope of the delegated regulation.

Even though an agreement on the definition of the term “internet-connected radio equipment” would not be legally binding, it could then be integrated into the Guidelines to the 2014/53/ EU Radio Equipment Directive (RED) as a common understanding between stakeholders and
thus support the legal base. Following the discussion in the RED Expert Group 15, the European Commission suggested that the industry should provide further case studies to support the request for better guidance. The following paper gives an overview of the current discussion within trade associations and industry use-cases in this respect.

It should be noted that the approach to analysis in this paper is technology neutral. This paper does not intend to indicate whether one specific technology is affected by the delegated regulation or not. Instead, this paper solely focuses on providing clarifications for the term “internet-connected radio equipment”, which is key for the application of the delegated regulation. For example, it cannot be stated that “Bluetooth technology” is excluded from the delegated regulation. Depending on the communication protocol used by that equipment, radio equipment using Bluetooth technology may or may not fall under the scope of the delegated regulation.

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