FEM, together with CECE, the construction equipment manufacturers association, submitted a joint position on combined equipment, in preparation for the Radio Equipment Directive Guide.Both organisations request the European Commission to provide urgent clarification regarding the situation of non-radio products functioning with radio equipment (i.e. combined equipment), for which there is no consensus yet between the different actors involved, notably the market surveillance authorities and the industry stakeholders.
As a key message, FEM stresses that, regardless of the permanent incorporation of a radio equipment into a non-radio product, it is fundamental that the radio equipment manufacturer should remain the one responsible for the conformity of the radio equipment, thereby ensuring that the radio product complies with the RED requirements.
Following the integration of the radio product into a non-radio product, the responsibility for carrying out radio equipment’s conformity assessment procedure should not be shifted to the machine manufacturer who needs to remain accountable for his/her product as subject to its base legislation (for example, the Machinery Directive).
Moreover, as a pragmatic solution, the organisations propose to add a copy of the Declaration of Conformity (DoC) of the radio equipment in the technical file of the non-radio product, which is already laid down as a possibility in the Pressure Equipment Directive. On a voluntary basis, the copy of the DoC may also be added to the user manual and/or the other documentation of the final product which is given to the customer.