Harmonised radio frequencies
Wireless products require radio frequencies to work. The allocation of frequencies is done by each Member State in their regional frequency plans or registers.
Once frequencies are allocated for a certain use, it is difficult to allocate these frequencies for other uses as well without causing interference with existing services and products. As a consequence radio frequencies may not be available for harmonisation in the whole EU and restrictions or authorisations may be required for your product. If restrictions exist in at least one Member State then consumers shall be informed before they buy.
The first step is to find out if there are restrictions for a wireless product. If this is the case then the additional information obligations must fulfilled.
Wireless products work with radio waves; these waves have a wavelength. The wavelength is directly related to the frequency. Most products do not work on a single frequency but they operate in a frequency range or band that is defined by the lowest and highest frequency.
In addition to the frequency band, the radiated power and the use or category of the product matters too.
ECO and EFIS
An overview of the frequency plans of 49 regions in Europe is provided in the ECO Frequency Information System (EFIS). ECO is the European Communications Office in Copenhagen, Denmark.
The EFIS system (www.efis.dk) allows you to search on all allocations of radio frequencies in Europe.
It is worthwhile to invest some time in exploring the information provided by ECO.
Class 1 and Class 2
Decision 2000/299/EC is still valid. It refers to radio products without restrictions as 'Class 1'.
Class 1 products only require CE marking. But Class 2 products have regional restrictions and require additional markings as defined on the next page. Classifications are published by the Commission and TCAM (Telecom Conformity Assessment and Market surveillance committee).
Harmonised for SRD
Another helpful resource is Decision 2006/771/EC.
This decision originally referred to R&TTE Directive 1999/5/EC, but it is still valid for the RED 2014/53/EU. It contains a list of harmonised frequencies for short range devices (SRD), which includes many of the mass- market wireless consumer products. The list is regularly updated, the latest amendment is Decision (EU) 2019/1345 of 2 August 2019. The complete list can be found on eur-lex.europa.eu or www.efis.dk.
Although there is sufficient information available, it remains challenging for manufacturers to determine if a wireless product can be sold without restrictions in all Member States. Some technologies have become popular just because they are harmonised such as Bluetooth or WiFi (IEEE 802.11), but caution is advised.
In case of doubt, please consider to involve professional service providers for wireless products such as testing laboratories or RED Notified Bodies.
A full list of the Notified Bodies is provided by NANDO, the New Approach Notified and Designated Organisations Information System.
If any regional or geographic restrictions apply to a wireless product then the following information obligations shall be fulfilled.
RED Article 10(10)
Article 10(10) of the Radio Equipment Directive (RED) 2014/53/EU defines the obligations for the packaging and the instruction manual of wireless (radio) products with a geographical restriction. The article also mentions that the 'Commission may adopt implementing acts specifying how to present that information'. Such an 'implementing act' was adopted on 20 July 2017. The Regulation provides more details about the manufacturer's obligations for wireless products with geographical restrictions.
Regulation (EU) 2017/1354
This regulation of 20 July 2017 specifies in detail the information obligations of RED Article 10(10).
It is mandatory since 9 August 2018.
If radio equipment is subject to restrictions then the packaging of the radio equipment shall indicate:
- A pictogram (see below); or
- The words 'Restrictions or Requirements in', in the local language.
- Always followed by the abbreviations of the Member States where restrictions or requirements exist.
The abbreviations for Member States shall be as follows:
- Belgium (BE)
- Bulgaria (BG)
- Czech Rep. (CZ)
- Greece (EL)
- Spain (ES)
- France (FR)
- Lithuania (LT)
- Luxembourg (LU)
- Hungary (HU)
- Portugal (PT)
- Romania (RO)
- Slovenia (SI)
- Denmark (DK)
- Croatia (HR)
- Malta (MT)
- Slovakia (SK)
- Germany (DE)
- Estonia (EE)
- Italy (IT)
- Cyprus (CY)
- Netherlands (NL)
- Austria (AT)
- Finland (FI)
- Sweden (SE)
- Ireland (IE)
- Latvia (LV)
- Poland (PL)
- United Kingdom (UK)
The (new) pictogram
A pictogram does not require translations and is therefore more practical than words.
The following rules apply to the pictogram:
- The pictogram shall be in the form of a table;
- Thepictogram shall be the prescribed sign;
- The pictogram shall also mention, below or next to the sign the abbreviations of the Member States;
- The pictogram and its contents may take different variations (e.g. colour, solid or hollow, line thickness) as long as it remains visible and legible.
In addition to the information on the packaging the instructions (user manual) shall indicate in local language the list of the Member States and geographical areas within the Member States where such restrictions or requirements exist, as well as the types of restrictions or requirements applicable in each Member State and each geographical area within a Member State.