Using Radio Modules to Create Combined Equipment

What is combined equipment and what impact do radio modules have on combined-equipment compliance? 

“Combined equipment” describes the complete product created when a radio module is installed into a host. 

The compliance of the module and the compliance of the original non-radio host cannot simply be added together. Integration can produce new interactions that did not exist when either component was assessed separately. 

For example: 

• The host processor may introduce noise into the radio receiver 

• The transmitter may create emissions through host cables 

• A metallic enclosure may alter antenna performance 

• A power supply may affect transmitter output or unwanted emissions 

• An internal cable may couple radio-frequency energy to an external port 

• Multiple radios may transmit simultaneously 

• The user’s proximity to the antenna may change RF exposure requirements 

The final product must therefore be considered as a system. 

This is particularly important where an existing product is being made “connected” through the addition of a radio module. The original host may already have passed EMC or electrical safety testing, but that evidence predates the addition of a transmitter and cannot automatically represent the modified equipment. 

 

Webinar chapters 

0:00 – Introduction  

Michael introduces the session and outlines its focus: regulatory approvals, radio modules, combined-equipment compliance, and the relationship between engineering decisions and legal responsibility. 

4:16 – The end goal of regulatory approvals 

Michael begins by establishing: the main goal for manufacturers is to sell products that perform well and meet regulatory requirements. This is broken down by testing and regulatory approvals.  

• Testing exists to solve real-world problems like EMC, safety, and radio performance, improving product reliability and protecting users and other services. 

• Regulatory approvals are not just about quality improvement but ensuring products are legally marketable and safe. 
  
  

7:54 – What is a radio module? 

Michael provides an introduction to radio modules, how manufacturers use them and why module-level approval is not the same as final-product approval. Radio modules are typically small, self-contained units with shielding, voltage input, antenna output, and signal interface.  

9:28 – USA and Canada authorization 

Michael describes how FCC and ISED certification operates, what modular approval covers, and what remains the responsibility of the host manufacturer. 

14:06 – EU RED authorization 

Michael then describes the differences in how radio modules are treated under the Radio Equipment Directive, why the module’s CE marking does not transfer, and why the finished product requires its own Declaration of Conformity. Learn more about the manufacturer's requirements in Element’s 10-point checklist for CE Marking of radio modules for Europe here.  

 

17:47 – Considerations before installing a radio module into a host 

Next, Michael covers what changes when a module is integrated into another product and why the resulting combined equipment must be assessed in its final configuration. For more information related to integrating radio modules into end products to create combined equipment, read our whitepaper here.  

22:43 – Testing challenges and practical considerations for radio modules in combined equipment 

Installing a module in a host device can significantly change emissions and performance; each installation is unique and may require different testing. Michael explains that host enclosures can affect emissions, sometimes increasing them due to larger size and more connectors. He then emphasizes that it’s important manufacturers document their decisions and justifications for testing scope. Michael also mentions the additional considerations and potential risks with multiple radio modules in one device. 

 

28:31 – Key takeaways and practical applications for manufacturers integrating modules for Europe and North America 

Finally, Michael rounds out the webinar by covering some of the key takeaways of radio modules, common mistakes he sees manufacturers making, as well as different approaches manufacturers can take and some practical considerations for testing and approvals.