On 28 January 2025, the European Commission published a decision in the Official Journal of the European Union (OJEU) numbered (EU) 2025/138 to incorporate the three standards EN 18031-1/2/3 into the harmonized standards of the Radio Directive (RED), with corresponding restrictions. The inclusion of harmonized standards means that manufacturers are allowed to demonstrate compliance with the regulatory requirements by providing a self-declaration, thus avoiding the involvement of a Notified Body (NB). However, if the product does not fully comply with the requirements or does not meet the constraints, a type examination certificate must be issued by NB.
The relevant restrictions are explained below
- For the EN 18031-1/-2/-3 standard, the restriction can be circumvented if clauses 6.2.5.1 and 6.2.5.2 of the standard are applied, i.e. the user is not allowed to do not set or use any password;
- In the case of EN 18031-2, restrictions can be circumvented if the product is a childcare device and a toy radio if it has been evaluated in accordance with standards 6.1.3, 6.1.4, 6.1.5, 6.1.6 to guarantee parental access control;
- For the EN 18031-3 standard, Clause 6.3.2.4 lists four different implementation categories for security updates, including digital signatures, secure communication mechanisms, access control mechanisms, and others. No single method is sufficient to deal with financial assets, and the restriction can be circumvented if the manufacturer can demonstrate that the product exceeds the requirements of the standard in this regard.
Click on this link to view the original decision (EU) 2025/138.