Concerns have been expressed to the Commission by some Member States that the proposed guidance on the new Radio Equipment Directive (RED) contains definitions that are different from those used in the legislation itself.

For instance, the Directive defines radio equipment as any electrical or electronic product that emits and/or receives radio waves, but the guidance says that radio equipment may be defined as a “non-radio” product if the emission/reception of radio waves is not its primary function. Furthermore, the draft guidance suggests that the EMCD and LVD will also apply for “non-radio” electrical products functioning with radio equipment. The group preparing the RED Guide for the Commission is due to meet on 11 and 12 October.

Although the RED should by now be transposed into national law of all Member States this has not yet happened in the UK. Similarly, the UK has not transposed the latest versions of the Low Voltage and EMC Directives.