Document: CEMA_PP-_2020_02_20_-_Application_of_RED_to_agricultural_machinery-final.pdf

POSITION PAPER

In 2014 a revised Radio Equipment Directive 2014/53/EU was published. With new technologies like remote and/or automated control of functions came new safety and health risks. It was concluded that these risks were best solved in the Directive itself. For a large number of products it meant that their main piece of legislation would cover all related risks.

With the opening of the scope came the need to assess the appropriateness of this Directive to some products. And certain grey areas remained like e.g. agricultural machinery. 

For the application of the Radio Equipment Directive the ‘Guide to the Radio Equipment Directive’ and ‘Supplementary Guidance on the LVD/EMCD/RED’ are available.  This CEMA position paper provides an approach based on these guides that ensures that the conformity of the combination of radio equipment installed on agricultural machinery, tractors and implements is fulfilled.

It is not appropriate to treat a combination of radio equipment and vehicle (such as agricultural machinery, tractors and implements) as a whole product subject to the Radio Equipment Directive, under the conditions specified in this position paper. The result would be a redundant application of the essential requirements for health and safety and electromagnetic compatibility as well as burdensome conformity assessment requirements preventing the aim of the New Legislative Framework.

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