How does RED Cyber apply to radio modules or system-on-modules (SOMs) that would be a component within an end product and not the end product itself?

Answer

RED Article 3.3 (d), (e), and (f) applies to any product placed on the EU market with the CE mark. Radio modules and SOMs are not exempt from meeting the RED security requirements. Even though these are components, choosing to CE mark them requires demonstrating compliance with all applicable requirements.

While the EU does not recognize modular approvals, meaning a radio module or system-on-module (SOM) with a CE mark will still need to undergo a conformance assessment once integrated into the end product, we take the approach of CE marking our radio modules and SOMs to minimize the risk for our customers when integrating them into their products. While this helps streamline the compliance process, it does not eliminate the need for the final product to undergo its own conformity assessment.