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What Should Organizations Know About the Radio Equipment Directive?

In the second of our series of interviews with member companies, Wi-SUN Alliance President and CEO Phil Beecher talks with Simon Dunkley, Global Spectrum Lead at Itron, about European legislation, the Radio Equipment Directive, and why members should be aware of it.


Hi Simon and welcome to our Wi-SUN member interview series. First of all, please tell us a bit more about Itron and your role in the business?

Itron enables utilities and cities to safely, securely and reliably deliver critical infrastructure solutions to communities in more than 100 countries. Our portfolio of smart networks, software, services, meters and sensors helps our customers better manage electricity, gas and water resources for the people they serve. By working with our customers to ensure their success, we help improve the quality of life, ensure the safety, and promote the well-being of millions of people around the globe. Itron is dedicated to creating a more resourceful world.

My role as Global Lead on Radio Spectrum is to ensure that we are aware of spectrum in target countries in which we can offer Wi-SUN-based solutions. Our colleagues in the US take for granted that we have 26MHz spectrum with simple rules in which to operate. In many other regions of the world – notably Europe – things aren’t so easy and so we need to understand and influence the development of regulations and standards.

In Europe, what is the Radio Equipment Directive?

The Radio Equipment Directive (RED) is a piece of binding European legislation that has to be translated into the national law of each of the 27 European Union (EU) member states and stipulates the way in which radios being ‘placed on the European market’ should be designed, marketed, and ultimately, operated. The regulation has been in place since 2014, and its introduction at the time caused much upheaval because the associated standards – necessary to prove compliance with the regulation for any one radio type – simply were not ready. Nevertheless, it has now been adopted by most European countries – even those outside of the EU – as well as in many other regions, such as the Middle East and Africa.

What is the scope of the RED?

When the RED replaced the previous legislation (the R&TTE Directive) it added radio receiver performance requirements to the existing requirements for transmitters. But the Directive also has various ‘sleeper’ clauses written into it, which are not yet activated. If market developments arise and the European Commission sees fit, these clauses can be ‘switched on’ by means of secondary European regulation.

Can we expect any new legislation soon?

Very much so. In response to governments’ concern of the threat of poorly designed radio products being vulnerable to the ever-evolving cyber threats from around the world, a decision has been made to activate the latent cyber security clauses (3.3 d, e & f). This legislation is due to become active in August 2024, but difficulties with writing the associated standards have delayed the process and this is likely to slip to August 2025.

What impact will that have on our members and their products?

I suspect this will have no impact on any of our members products because the legislation is chiefly intended to raise the baseline for consumer-oriented products, where software patching is rare and default passwords leave many open to recruitment into powerful ‘botnets’. I expect that all our members’ products are suitably designed already, because the Wi-SUN standard mandates mechanisms such as PKI (Public Key Infrastructure) with X509 certificates for device authentication, and AES encryption to protect message content and integrity.

The issue is that, if the standards are still not ready in early 2025, then product conformity will depend on the use of ‘notified bodies’, and there simply won’t be enough of them to do the necessary testing. Members need to keep a close eye on this, familiarize themselves with the standards when they become available and ensure that all of their products have a path to certification.

Thank you Simon.

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