ETSI EN 300 220-2 V3.3.1: What Short-Range Device Manufacturers Need to Know Before the 2027 Deadline

After 11 June 2027, any short-range device placed on the EU or UK market must comply with ETSI EN 300 220-2 V3.3.1. This significant revision introduces mandatory receiver performance testing for all short-range devices, new temperature testing obligations linked to product category, and updated transmitter requirements, including frequency stability measurement. Published in March 2025, it replaces earlier versions under the EU Radio Equipment Directive and UK Radio Equipment Regulations. This practical whitepaper by Element wireless testing expert Robert Graham draws on his firsthand client experience to set out what changed, which products are affected, and what engineers and compliance teams need to do before that deadline.

 

Compliance Deadline - Products placed on the EU or UK market after 11 June 2027 must reference V3.3.1 in their Declaration of Conformity. Earlier versions of EN 300 220-2 lose their presumption of conformity under the Radio Equipment Directive and UK Radio Equipment Regulations on that date. 

 

Is Your Short-Range Device Ready for EN 300 220-2 V3.3.1?

If your product operates in the sub-GHz spectrum and holds existing certification under earlier versions of EN 300 220-2, this whitepaper tells you what has changed and what it means for your compliance status. Specifically, it helps you: 

• Understand whether your product will pass the new mandatory receiver performance tests, which now apply to all receivers for the first time. 
• Identify whether your current temperature test scope covers the mandatory range for your product category. 
• Assess whether FHSS or PSA implementations previously validated by declaration now require formal measurement. 
• Understand the laboratory method and documentation changes that will affect your next test submission. 
• Plan your compliance programme against a realistic timeline ahead of the 11 June 2027 deadline. 

 

Understanding the Changes to the Latest Edition of ETSI EN 300 220-2: Abstract 

EN 300 220-2 V3.3.1 represents a step-change in what the standard demands of short-range device manufacturers. The document has grown from 33 to 107 pages, with the additional content reflecting substantive new requirements rather than editorial revision. The most significant changes are the introduction of mandatory receiver performance testing for all receivers- covering sensitivity, dynamic range, adjacent channel selectivity, spurious response rejection, and intermodulation rejection, and the expansion of environmental testing obligations, which are now linked to mandatory minimum temperature ranges by product use category.  

On the transmitter side, frequency stability moves from self-declaration to mandatory measurement, and a band-edge spectrum mask now applies unconditionally to all transmitters. PSA timing parameters and FHSS behaviour also move from declaration to measurement.  

This whitepaper sets out each change in technical detail, explains its commercial and engineering implications, and provides a structured approach to preparing for the transition. 

 

Does EN 300 220-2 V3.3.1 Apply to Your Product?

EN 300 220-2 covers non-specific short-range devices operating between 25 MHz and 1000 MHz at power levels up to 500 mW e.r.p. The scope is broad and includes telemetry and telecommand systems, alarm devices, generic data transmitters, and FHSS devices operating in the licence-exempt bands governed by CEPT/ERC Recommendation 70-03. 

V3.3.1 widens that scope. Products transmitting analogue voice were previously excluded. They are now explicitly in scope, bringing a category of devices into the full EN 300 220-2 compliance framework for the first time. 

If your product's certification was based on an earlier version of the standard, your compliance evidence will need to be updated before the June 2027 deadline, regardless of whether the product itself has changed. 

 

Mandatory Receiver Testing: The Change Most Likely to Require Hardware Redesign

For manufacturers whose products have historically been assessed primarily on transmitter performance, V3.3.1 introduces an entirely new category of compliance work. The standard now requires a comprehensive suite of receiver tests for all receivers. Previously, most of these requirements applied only to devices implementing Polite Spectrum Access.

The tests collectively assess how the receiver handles weak signals, strong interferers, adjacent channel energy, image frequencies, and two-tone intermodulation. They challenge the quality of the receive chain in ways that earlier versions of the standard did not.

For products built around third-party chipsets or modules, the key question is whether the silicon has been characterised to the new limits. Some components will not meet the updated requirements without hardware changes, and early engagement with your silicon vendor is the single most effective step you can take at this stage.

The specific test parameters, limits, and measurement procedures are covered in full in the whitepaper, along with guidance on how to assess your product's likely compliance margin before formal testing begins. 

 

Mandatory Temperature Testing Under EN 300 220-2 V3.3.1: What Your Product Category Determines 

Temperature testing is no longer self-declared. V3.3.1 links mandatory minimum temperature test ranges directly to the intended use of the product across five defined categories. The ranges differ significantly across those categories, and the whitepaper sets out exactly what applies to each.

Two details make this more consequential than it first appears. First, products previously tested over a narrower temperature window will require full re-qualification. Second, if your product's datasheet or user documentation claims operation beyond the baseline for its category, the radio testing must cover that broader range. The standard ties the required test conditions to what you claim, not just what category you select.  

For products built around integrated chipsets or modules, RF performance at temperature extremes may never have been formally characterised as part of a regulatory compliance programme. That changes with V3.3.1, and engaging your component vendor early to establish whether the data already exists is the most efficient first step.

 

New Transmitter Requirements: Frequency Stability, Band-Edge Mask, and FHSS Measurement 

Frequency Stability

What was previously a manufacturer declaration is now a test requirement. Frequency stability must be demonstrated and documented under defined normal and extreme conditions. The specific conditions and their interaction with the expanded temperature testing obligations are covered in the whitepaper. 

 

Band-Edge Spectrum Mask 

The band-edge mask at the edges of the Permitted Frequency Band now applies unconditionally to all transmitters, including narrowband devices that were exempt under previous versions. If this test has not previously been part of your compliance programme, it now needs to be. 

 

FHSS Measurement Requirements 

For FHSS devices, declaration is no longer sufficient. V3.3.1 introduces explicit measurement requirements covering how the duty cycle is assessed and the capture rates required to validate hop-level behaviour. The full measurement parameters are set out in the whitepaper. 

 

Understanding the Changes to the Latest Edition of ETSI EN 300 220-2: Excerpt 

"For manufacturers whose products have historically been tested primarily on the transmitter side, the receiver performance requirements in V3.3.1 will require a material expansion of their compliance programme. The adjacent channel selectivity, spurious response rejection, and intermodulation rejection tests collectively challenge the front-end architecture in ways that previous versions of the standard did not. For chipset-based products or integrated modules, the key question is whether the silicon vendor can confirm compliance with the new thresholds. Early engagement with silicon vendors is strongly recommended, as some chipsets may not meet the new thresholds without hardware changes."  

— Robert Graham, Wireless Testing Expert, Element Connected Technologies & Mobility 

 

EN 300 220-2 V3.3.1 Testing, Advisory, and Certification Services from Element 

Element's Connected Technologies teams have been engaged with the development of V3.3.1 since its publication and understand where products are most likely to encounter problems, particularly around receiver performance and temperature-dependent RF behaviour. 

We support manufacturers across three areas. As regulatory advisors, we help you understand how V3.3.1 applies to your product and identify the correct conformity assessment route under the EU Radio Equipment Directive and UK Radio Equipment Regulations. As a test laboratory, our ISO/IEC 17025-accredited facilities deliver the full V3.3.1 test suite, including the expanded receiver requirements, transmitter tests, and environmental testing. As an ISO/IEC 17065 accredited Notified Body, we provide EU-type examination where required and support technical file and certification activities for both the EU and UK market access. 

If your product also carries cybersecurity obligations under the Cyber Resilience Act, the Radio Equipment Directive cybersecurity requirements under EN 18031, or the UK PSTI Act, we can coordinate radio and cybersecurity testing within a single programme. 

 

To receive a copy of this whitepaper by email, please fill out your details in the form below: 

The whitepaper gives your team the specific numbers, conditions, and procedures needed to assess your product before formal testing begins.  

It covers everything this article does not. 

• Receiver test thresholds and limits for all six requirements
• Temperature ranges per product category
• FHSS measurement parameters and capture rate requirements
• PSA timing test conditions and limits
• Laboratory method changes, including analyser configuration
• Annex G EUT documentation checklist
• Annex H measurement uncertainty limits per test parameter
• Conformity assessment route guidance under RED and UKRER