RED and CRA overlap for connected radio products: 2025-2027 transition

Radio products may have several independently applicable obligations. The transition removes the delegated 2022/30 regime from 11 December 2027 while other RED safety, EMC and spectrum requirements continue. Do not make a blanket claim that CRA replaces RED or that EN 18031 automatically proves CRA conformity.

Essential requirements and exclusions

Article 3(1)(a) covers health/safety objectives of LVD without its voltage limits; 3(1)(b) covers EMC; 3(2) covers spectrum. RED Article 1(4) excludes standalone LVD application and EMC Article 2 excludes RED radio equipment. Other applicable acts such as RoHS remain separately assessed. Delegated Regulation 2022/30 activates selected 3(3)(d)-(f) requirements from 1 August 2025 after 2023/2444; its Article 2(1) excludes MDR/IVDR devices from those three cybersecurity requirements, not from all RED duties. Regulation 2026/339 repeals 2022/30 from 11 December 2027; RED itself continues.

Conformity assessment

For Article 3(1) requirements, Article 17(2) permits A, B+C or H. For Article 3(2)/(3), Article 17(3) permits A, B+C or H where applicable OJ-listed harmonised standards are fully applied; absent/partially applied standards, Article 17(4) requires B+C or H. Check exact editions, scope and OJ restrictions. EN 18031 citations under 2025/138 carry limitations; neither EN 18031 nor ETSI EN 303 645 automatically gives CRA presumption of conformity.

Scope and exclusions

CRA concerns products with digital elements made available on the EU market whose intended or foreseeable use includes a direct or indirect logical or physical data connection. MDR/IVDR devices and other Article 2 exclusions require separate scope assessment. Assess manufacturer responsibility and the statutory remote-data-processing definition, not cloud dependence alone. Main product requirements apply from 11 December 2027; Article 14 reporting applies from 11 September 2026.

Conformity assessment A, B+C and H

Annex VIII offers internal control (A), EU-type examination plus conformity to type (B+C), and full quality assurance (H). Standard products may use A. Important Class I A depends on Article 32(2) full coverage through applicable harmonised standards, common specifications or qualifying certification; otherwise B+C or H. Class II uses B+C or H under Article 32(3). Article 32(5) allows qualifying important free/open-source software with public technical documentation to use A. Critical products require assessment of Article 8 certification conditions; absent the mandated suitable scheme conditions, Article 32(4) provides B+C or H. Classify the main product function against Annexes III/IV and implementing technical descriptions 2025/2392, not a component name alone.

Evidence to keep with the product

Record the intended purpose, responsible economic operator, target market, first placing date and exact hardware/firmware configuration. For each applicable requirement, link the actual test or assessment record, dated standard/specification, scope and reviewer decision. Proposed controls and supplier marketing statements are not evidence that the final configuration has passed an assessment.

Separate an open question from a completed assessment. A report outside the laboratory's relevant scope, a different firmware build or an unverified exemption needs a reasoned decision before it supports a declaration. Keep original evidence and the issued declaration alongside any AI-assisted working draft.

Using Cenitia for this work

Cenitia assists with a limited regulatory catalogue and draft documents. The manufacturer must confirm applicability, actual applied specifications and completed assessment procedures. AI scores are quality signals, not a probability of conformity. Source monitoring raises a review prompt when validated source text changes; it does not automatically verify amendments, update the corpus or monitor every national rule and OJ standard edition. Public QR verification records issuance, not product certification.

Review status

This guide was substantively corrected by Cenitia on 2 October 2026 using the primary references below. It is an editorial summary, not an authoritative legal quotation or an independently signed expert opinion. Product-specific and licensed-standard questions remain subject to a real technical review.

Primary references

• Primary source 1
• Primary source 2