How to use radio modules to enable connectivity of electronic consumer products in EU

Consumer electronics get more connected every day. Almost all of Miele’s washing machines for example use integrated radio modules by now in order to offer connectivity functionalities eg via WiFi to get info about detergent levels etc. This means, that previously unconnected products are equipped now with radio modules, often manufactured by suppliers and sold to OEMs such as Miele. What do OEMs of previously unconnected products have to know when selling connected “final products” such as Washing machines in the EU?

Here is some info on that:

• There is no section on radio modules in the RED and there is no section for modular approvals.
• In the EU, if the radio module manufacturer has defined their module as radio equipment within scope of the RED, they must CE Mark it to the RED
• BUT, the CE Mark on the radio module does not guarantee that the FINAL RADIO PRODUCT (eg Miele WiFi Washing machine) will comply with the requirements when the module is installed into a host
• The manufacturer of the final radio product IS RESPONSIBLE for fully assessing their equipment to all the essential requirements of the RECORD* That means to fully assess the radio transmitter performance, radio receiver performance, EMC emissions, EMC immunity, product safety and RF exposure, not only for the radio module but for the final product including the radio module