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Pre-approved radio modules: Element's 10 point checklist

Dr. Simon Hindle
By Engaged Expert Dr. Simon Hindle Product Qualification Testing

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The CE Mark allows manufacturers to import and export their products freely within the European Union, with common product design and manufacturing requirements defined within EU Directives. By placing the mandatory conformity mark on a radio product, you are providing a clear indication that it meets all the relevant requirements and should therefore enjoy free movement between all 28 member states. 

Pre-approved radio modules are a popular choice for radio product manufacturers wishing to get their end product to market quickly and cost effectively. However, it’s important to ensure the radio module does not end up compromising the CE Marking of the end product.  

Our radio experts at Element have put together a ten point checklist to help make sure you are able to demonstrate the necessary due diligence in using a radio module in your product. 

Element’s 10 point radio module checklist for CE Marking 

1. Is the device a radio module?

There is often confusion about whether a device is a radio module or a chipset and it is important to be clear that you understand the definitions for both. 

2. Does the module have a CE Mark? 

If the device does not have a CE Mark then you will need to ascertain the level of compliance that the module carries and if it is not sufficient then you will need to take steps to ensure that your end product is compliant against all applicable requirements.  Be careful not to mistake the China Export mark with the CE Mark. 

3. Do you have a copy of the Declaration of Conformity (DoC)? 

Manufacturers of modules are required to sign a DoC before CE Marking the device and placing it onto the market or putting it into service. This should be provided to you at point of sale, or on request. 

4. Are the standards listed and current? 

The DoC should list the standard(s) the module was assessed against. You should check that these are the correct standards and are in date. You can check these on the R&TTE/RED Official Journal. 

5. Do you have a copy of the test report(s)?

Whilst the manufacturer is not obliged to provide them, if they fail to do so on request it does raise the question of whether the testing has been done correctly, or at all. If you sign your DoC without obtaining these, you would be doing so with little evidence to back up your presumption of conformity. 

6. Have you changed the module in a way that may affect compliance?

If you have made any changes to the module, you have not be able to carry forward the compliance of the module. Common alterations involve a change of antenna or frequency allocation. 

7. Does the module have a host-mounted antenna?

Occasionally modules will not have a built-in antenna but will have a connector instead. Often in the case of cellular radios the antenna is host-mounted and not mounted on the module. In this case there will be some modification to the RF chain, usually in the form of a small PCB trace between the module and the host-mounted antenna connector. This can comprise the compliance, and so limited ‘verification’ testing may be required. 

8. Are you using the module in the temperature range covered by the existing compliance evidence? 

The test reports will have a designated temperature range outside of which the radio is not shown to be compliant. For use outside of this range, further testing may be required. 

9. Is the radio module co-located and capable of simultaneous transmission with another transmission? 

 For products with multiple radios that are capable of simultaneous transmission there is a requirement for an intermodulation investigation in accordance with ETSI TR 102 070-2 to ensure there are no spurious emissions caused by the interaction of these transmitters. 

10. Is the equipment portable, body worn or used against the head? 

Equipment that is body-warn, handheld, or used against the body will require an RF Exposure evaluation and possibly an SAR assessment.

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