---
title: "We added Bluetooth or Wi-Fi to an existing product"
description: "A product that intentionally emits or receives radio waves is radio equipment under Directive 2014/53/EU. It leaves the Low Voltage Directive and must meet the radio directive's safety, EMC and spectrum requirements. Internet-connected products, and childcare, toy or wearable products that can process personal data, also meet cybersecurity requirements under Delegated Regulation (EU) 2022/30 from 1 August 2025 until 11 December 2027. Reassess the product and update the declaration."
type: "problem"
url: "https://www.conphora.com/solutions/problem/connected-product-radio/"
markdown: "https://www.conphora.com/solutions/problem/connected-product-radio.md"
locale: "en"
language: "en"
updated: "2026-10-04"
author: "Conphora compliance team"
publisher: "Conphora"
source: "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02014L0053-20260530"
tags: ["RED", "EMC", "LVD", "placing-on-market"]
license: "Free to quote with attribution and a link to the page"
---

# We added Bluetooth or Wi-Fi to an existing product

A product that intentionally emits or receives radio waves is radio equipment under Directive 2014/53/EU. It leaves the Low Voltage Directive and must meet the radio directive's safety, EMC and spectrum requirements. Internet-connected products, and childcare, toy or wearable products that can process personal data, also meet cybersecurity requirements under Delegated Regulation (EU) 2022/30 from 1 August 2025 until 11 December 2027. Reassess the product and update the declaration.

## Why this happens

Adding a radio changes the legal category of a product, not just its feature list. Directive 2014/53/EU defines radio equipment as an electrical or electronic product that intentionally emits or receives radio waves for radio communication or radiodetermination, or one that must be completed with an accessory such as an antenna to do so (Article 2(1)(1)). Radio equipment within the directive is not subject to the Low Voltage Directive, except that the safety objectives of that directive apply through the radio directive's own Article 3(1)(a) (Article 1(4)). [1] [4]

The essential requirements of the radio directive then apply to the whole product. It must protect the health and safety of persons and domestic animals and protect property, including the Low Voltage Directive's safety objectives but with no voltage limit (Article 3(1)(a)); it must have an adequate level of electromagnetic compatibility as set out in the EMC Directive (Article 3(1)(b)); and it must use the radio spectrum efficiently to avoid harmful interference (Article 3(2)). Further requirements in Article 3(3) apply to categories named in delegated acts. [1] [3]

One of those delegated acts is Delegated Regulation (EU) 2022/30. It applies the network protection requirement to radio equipment that can communicate over the internet, the personal data and privacy requirement to internet-connected, childcare, toy and wearable radio equipment that can process personal, traffic or location data, and the fraud requirement to internet-connected equipment that can transfer money or virtual currency (Article 1). Medical and in vitro diagnostic devices are excluded from all three requirements, and equipment also covered by the aviation, vehicle safety or road toll acts named in Article 2(2) from the privacy and fraud requirements (Article 2). After an amendment, it applies from 1 August 2025 (Article 3). Delegated Regulation (EU) 2026/339 repeals it with effect from 11 December 2027, the date from which the Cyber Resilience Act, Regulation (EU) 2024/2847, applies in full; according to its recitals, radio equipment placed on the market between 1 August 2025 and 10 December 2027 remains subject to market surveillance against those requirements (Article 1, recitals 3 to 5). [2] [5]

The conformity route depends on standards. For the safety and EMC requirements the manufacturer may use internal production control, EU-type examination or full quality assurance (Article 17(2)). For the spectrum and Article 3(3) requirements, internal production control is only available where harmonised standards published in the Official Journal were applied; otherwise a notified body is involved (Article 17(3) and (4)). The assessment takes into account all intended operating conditions and, for safety, the reasonably foreseeable conditions, and confirms compliance in every possible configuration (Article 17(1)). [1]

The paperwork follows. The manufacturer draws up the technical documentation before placing on the market and keeps it updated (Article 21(1)–(2)), and draws up a single EU declaration of conformity where several Union acts require one (Article 18(3)). Each unit is accompanied by a copy of the declaration or a simplified declaration with the internet address of the full text (Article 10(9)), and the instructions state the frequency bands and the maximum radio-frequency power transmitted (Article 10(8)). Where use is restricted or needs authorisation in some areas, the packaging must allow those Member States or areas to be identified (Article 10(10)). [1]

## How to solve it

1. **Accept that the product is now radio equipment** Radio equipment is an electrical or electronic product that intentionally emits or receives radio waves for radio communication or radiodetermination. Once that applies, the Radio Equipment Directive is your main act, and the Low Voltage Directive no longer applies except for its safety objectives, which the radio directive takes over without a voltage limit.
2. **Map the essential requirements that now apply** Health and safety, electromagnetic compatibility and efficient use of the radio spectrum apply to all radio equipment. If the product can communicate over the internet, processes personal data or lets users transfer money, check the network, privacy and fraud requirements made applicable by Delegated Regulation (EU) 2022/30.
3. **Choose the conformity assessment route** For the spectrum requirement and the Article 3(3) requirements, internal production control is only available if you applied harmonised standards published in the Official Journal. If you did not, applied them in part, or none exist, the equipment goes through EU-type examination or full quality assurance with a notified body.
4. **Assess the product in every configuration** The assessment covers all intended operating conditions, the reasonably foreseeable conditions for safety, and every configuration the product can take. The radio directive has no rule on modules; read with Articles 10 and 17(1), a supplier's report for the radio module is evidence for your file, but the declaration must cover the product you place on the market.
5. **Update the declaration, instructions and packaging** Draw up one EU declaration of conformity covering every act that requires one, ship a copy or a simplified declaration with each unit, and add the frequency bands and maximum radio-frequency power to the instructions. Where use is restricted in some Member States, the packaging must allow buyers to identify them.

## What you need to show

- **Updated technical documentation for the radio product, with the elements of Annex V** — The manufacturer (Directive 2014/53/EU Articles 10(3) and 21(1)–(2))
- **A single EU declaration of conformity naming every applicable Union act** — The manufacturer (Directive 2014/53/EU Article 18(3))
- **Instructions with frequency bands and maximum transmitted power, and a copy or simplified declaration with each unit** — The manufacturer (Directive 2014/53/EU Article 10(8) and (9))

## If you do nothing

- **The old declaration no longer fits the product** — The declaration must state that the essential requirements of Article 3 of the radio directive have been demonstrated (Directive 2014/53/EU Article 18(1)); a declaration that names only the Low Voltage and EMC Directives does not, because radio equipment leaves the Low Voltage Directive (Article 1(4)).
- **Missing evidence can mean a test at your expense** — If the technical documentation does not present sufficient data, the market surveillance authority may require a test by a body it accepts, at the manufacturer's or importer's expense, within a set period (Directive 2014/53/EU Article 21(4)).
- **Cybersecurity gaps are a conformity gap** — Since 1 August 2025 the network, privacy and fraud requirements of Article 3(3)(d)–(f) apply to the radio equipment named in Delegated Regulation (EU) 2022/30 (Articles 1 and 3), which is repealed with effect from 11 December 2027 (Delegated Regulation (EU) 2026/339 Article 1); equipment that does not meet them is not in conformity and must be corrected, withdrawn or recalled (Directive 2014/53/EU Article 10(11)).

## Questions

### Our product runs on 5 V USB. Do the safety requirements still apply?

Yes. Radio equipment must protect health and safety, including the safety objectives of the Low Voltage Directive, with no voltage limit applying (Directive 2014/53/EU Article 3(1)(a)).

### Does the EMC Directive still apply?

Not directly. The EMC Directive excludes equipment covered by Directive 1999/5/EC (Directive 2014/30/EU Article 2(2)(a)), a reference read as one to the radio directive (Directive 2014/53/EU Article 50). Electromagnetic compatibility is an essential requirement of the radio directive itself, at the level set out in Directive 2014/30/EU (Article 3(1)(b)). Declare it under the radio directive.

### Do we need a notified body?

Not if you applied harmonised standards in full for the spectrum and Article 3(3) requirements; then internal production control is allowed. Without them, or with only partial use, EU-type examination or full quality assurance is required (Directive 2014/53/EU Article 17(3) and (4)).

### Do the cybersecurity requirements apply to every connected product?

Point (d) applies to radio equipment that can communicate over the internet; point (e) also to childcare, toy and wearable radio equipment that processes personal data; point (f) to internet-connected equipment that transfers money. Medical and in vitro diagnostic devices are excluded from all three; equipment also covered by Regulation (EU) 2018/1139, Regulation (EU) 2019/2144 or Directive (EU) 2019/520 from points (e) and (f) (Delegated Regulation (EU) 2022/30 Articles 1 and 2).

### Can we put a short declaration in the box?

Yes. Each item must come with a copy of the full declaration or a simplified one; the simplified version must give the exact internet address of the full text (Directive 2014/53/EU Article 10(9)).

## Regulations involved

RED, EMC, LVD

## Sources

1. [Directive 2014/53/EU on radio equipment (consolidated text of 30 May 2026)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02014L0053-20260530) — EUR-Lex, 2026-10-04
2. [Delegated Regulation (EU) 2022/30 on the application of Article 3(3)(d), (e) and (f) of Directive 2014/53/EU (consolidated text of 27 October 2023)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02022R0030-20231027) — EUR-Lex, 2026-10-04
3. [Directive 2014/30/EU on electromagnetic compatibility (consolidated text of 30 May 2026)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02014L0030-20260530) — EUR-Lex, 2026-10-04
4. [Directive 2014/35/EU on electrical equipment designed for use within certain voltage limits (consolidated text of 30 May 2026)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02014L0035-20260530) — EUR-Lex, 2026-10-04
5. [Delegated Regulation (EU) 2026/339 repealing Delegated Regulation (EU) 2022/30](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32026R0339) — EUR-Lex, 2026-10-04