When does a harmonised standard for radio equipment start to count?
7 min read
Anyone who in recent months signed off a microwave link declared compliant with EN 302 217-2 V3.4.1 closed the acceptance record leaning on a presumption of conformity that was not yet there. The reference for that version entered the list in the Official Journal of the European Union on Monday 7 September 2026. Before that day the standard existed, it could be downloaded and it was being cited in equipment files: the presumption could not.
The act that moved the list
Commission Implementing Decision (EU) 2026/2003 of 4 September 2026 appeared in the Journal on 7 September and enters into force on the day of publication itself. It amends Annex I to Implementing Decision (EU) 2022/2191, the single list of references that confer a presumption of conformity with Directive 2014/53/EU on radio equipment.
The movement is of three kinds. Eight rows added at the end, numbered 184 to 191. Five lettered rows inserted in the middle, beside the versions they replace. And five rows deleted, though not yet: Article 3 provides that “Point (1) of the Annex shall apply from 7 March 2028”. For eighteen months old and new sit in the list together.
The three rows that end up on site
Row 95a carries EN 302 217-2 V3.4.1: “Fixed Radio Systems; Characteristics and requirements for point-to-point equipment and antennas; Part 2: Digital systems operating in frequency bands from 1 GHz to 174,8 GHz; Harmonised Standard for access to radio spectrum”. Row 95, which stays alive until 7 March 2028, carries V3.3.1, stopping at “Digital systems operating in frequency bands from 1 GHz to 86 GHz”. The difference is not cosmetic: for digital point-to-point fixed systems, the list had no row reaching above 86 GHz.
Row 187 is new and replaces nothing: EN 301 489-50 V2.4.1, “Specific conditions for Cellular Communication Base Station (BS), repeater and ancillary equipment”. It is the electromagnetic compatibility standard for the units installed to cover the inside of a hospital, a tunnel, a warehouse. It arrives with a hole written next to the row: “This harmonised standard does not address emission requirements in frequency bands below 9 kHz and does not therefore confer a presumption of conformity as regards this parameter in this band”.
Row 147a carries EN 303 354 V1.2.1, “Amplifiers and active antennas for TV broadcast reception in domestic premises”: the aerial installation that gets put right while the fibre goes up the stairwell.
The date on the standard and the date that counts
Legislative decree 128 of 22 June 2016, which transposes the radio equipment directive, says it in article 16: radio equipment in conformity with harmonised standards «i cui riferimenti sono stati pubblicati nella Gazzetta Ufficiale dell’Unione europea» — the references of which have been published in the Official Journal of the European Union — is presumed to conform to the essential requirements of article 3. The presumption is born from the row in the Journal, not from the cover of the standard.
And more than a year passes between the two dates. EN 302 217-2 V3.4.1 was adopted on 2 July 2025, EN 303 354 V1.2.1 on 29 August 2025, EN 301 489-50 V2.4.1 on 3 September 2025. All three entered the list on 7 September 2026.
The cost of confusing the two dates sits in article 17 of the same decree. For the requirements of article 3(2) and 3(3) — efficient use of spectrum and the specific requirements — where the manufacturer «non ha applicato o ha applicato solo in parte norme armonizzate i cui riferimenti sono stati pubblicati nella Gazzetta Ufficiale dell’Unione europea», has not applied, or has applied only in part, harmonised standards the references of which have been published in the Official Journal, only two roads are left: EU type-examination under Annex III, or full quality assurance under Annex IV. That means a notified body. Internal production control under Annex II is not available.
Translated into acceptance: a EU declaration of conformity issued between July 2025 and 6 September 2026, which for spectrum cites V3.4.1 alone, declares Annex II and carries no notified body number, is a declaration to look at. It is not a defect in the installation: it is a defect in the document you accepted together with the installation.
Two calendars that never meet
There is a second misalignment, and it holds for every ETSI standard. Each edition carries a date for the withdrawal of conflicting national texts: for EN 303 354 V1.2.1 it is 31 May 2027. But row 147, the one for V1.1.1, stays in the Journal list until 7 March 2028. For nine months the conflicting national text will have been withdrawn while the old row goes on conferring a presumption of conformity. The same pattern holds for the microwave link: we lined up its dates when writing about the national radio interfaces.
The row number that was wrong
One last caution. Implementing Decision (EU) 2025/2499 of 9 December 2025 provided that rows 10, 106 and 125 were to be deleted from 11 June 2027, and inserted immediately after them the row for the new level probing radar standard. But row 125 is EN 302 977 V2.1.1, on vehicle-mounted satellite earth stations in the 14/12 GHz bands; the standard being replaced, EN 302 729 V2.1.1, is row 121.
On 7 September 2026 the Commission corrected the error twice: Article 2 of Decision 2026/2003 replaces the number 125 with the number 121, and a corrigendum published the same day moves the inserted row from 125a to 121a. For nine months the official list said that on 11 June 2027 the wrong row would go.
What to write, from now on
- the standard in full — designation, part, version — not the bare designation;
- the date of the declaration set against the date the reference was actually listed;
- the module applied (Annex II, III or IV) and, where needed, the notified body number;
- the notices beside the row: below 9 kHz, for base stations and repeaters, there is no presumption;
- the row cited by standard and version, never by number: numbers move and get corrected.
What we do not know
We do not know when 2022/2191 will be re-consolidated: the latest consolidated version is the one of 11 December 2025 and does not contain the new rows, so anyone opening the consolidated text today reads a list frozen nine months ago. We have not read the technical content of the standards cited: for the CENELEC parts, which are catalogue items and paid for, we report only reference, edition and status. We do not know how many declarations in circulation cite a version not yet listed: that is a check made file by file. And this search filtered the titles of Union acts from 1 July to today: a title that does not appear is no proof that the act does not exist.
How we solve it
On a radio unit the line that surfaces at inspection is not the power: it is the standard-and-date pair. We put it in writing twice. In the specification it becomes a clause: standard with part and version, assessment module, notified body where required, the notices from the list reproduced in full — and that same list becomes a point of the acceptance check, with the record handed over together with the installation. Then it becomes data: declarations, versions and deadlines leave the folder of PDFs and sit beside the optical traces and the as-built, in a single map of the network. On that map an AI running inside the client perimeter — on-premise or in a dedicated cloud with data centres in Italy, together with CSIDIA, the other company in the group — answers the question that today is worked out by hand: when a row in the list changes, which units and which files have to be revisited. It is the method we bring to network services, to the work on data and infrastructural AI and to projects for telecom operators. Our own crews, no subcontracting.
Do you have radio units in the field and declarations of conformity citing a designation without a version? Write to us: we look at which rows of the list concern you and what is missing from the files.