Responsibilities in the supply chain of radio equipment | Traficom
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Transport and Communications Agency

Responsibilities in the supply chain of radio equipment

In addition to manufacturers of radio equipment, other operators in the supply chain, such as importers and distributors, are also required to ensure that only complaint equipment is sold.

The obligations of different operators are defined in chapter 30 of the Act on Electronic Communications Services and in the Market Surveillance Regulation (e.g. Article 4). The list below includes the main obligations of economic operators. For more detailed information on the obligations, please see the relevant legislation. 

Links to documents and information on the conformity of radio equipment

Manufacturer means any natural or legal person who manufactures radio equipment or has radio equipment designed or manufactured, and markets that equipment under his name or trade mark.

Authorised representative means any natural or legal person established within the EU who has received a written mandate from a radio equipment manufacturer to act on the manufacturer’s behalf in relation to the tasks specified in the mandate.

Importer means any natural or legal person established within the EU who places radio equipment from a third country on the EU market. 

Distributor means any natural or legal person in the supply chain, other than the manufacturer or the importer, who makes radio equipment available on the market. 

Fulfilment service provider means any natural or legal person offering, in the course of commercial activity, at least two of the following services: warehousing, packaging, addressing and dispatching, without having ownership of the products involved, excluding postal services and freight transport services.

Importers and distributors of radio equipment are considered radio equipment manufacturers and have the same obligations as manufacturers where they place radio equipment on the market under their name or trade mark or modify radio equipment already placed on the market in such a way that may affect its conformity.

Please note that this page has not been updated with the requirements on the so-called common charger; as a rule, they will be applied starting from 28 December 2024. You can find more information about them at the link: Current information on the conformity of radio equipment

Manufacturers have, for example, the obligation to: 

  • ensure that radio equipment has been designed and manufactured in accordance with the essential requirements
  • carry out a conformity assessment or have it carried out
  • ensure that radio equipment is constructed so that it can be operated in at least one EU country without infringing the requirements on the use of radio spectrum
  • ensure that radio equipment is accompanied by, for example:
    • instructions and safety information at least in Finnish and Swedish. The instructions must include the information required to use the radio equipment in accordance with its intended use.
    • in the case of radio transmitters, information on the frequency band(s) in which the radio equipment operates and the equipment’s maximum transmission power
    • equipment packaging and instructions accompanying the equipment that indicate those countries or areas in the EU where the use of the equipment is restricted or requires authorisation.
      • Information on the restrictions must be presented as specified here. The pictogram in Annex 1 is available on the RED web pages of the European Commission. 
  • ensure that the radio equipment bears a type, batch or serial number or other element allowing its identification
  • indicate on the radio equipment their contact details (name, registered trade name or registered trade mark and postal address); if the information cannot be indicated on the radio equipment, it must be provided on its packaging or in a document accompanying the equipment
  • draw up technical documentation and an EU declaration of conformity
  • ensure that each item of radio equipment is accompanied by an EU declaration of conformity or a simplified EU declaration of conformity
    • the contents of an EU declaration of conformity are specified in Annex VI to the Radio Equipment Directive and the contents of a simplified EU declaration of conformity in Annex VII.
  • affix the CE marking to the equipment and its packaging
  • provide the Finnish Transport and Communications Agency Traficom with all the information and documentation concerning the equipment requested by Traficom and cooperate with Traficom to eliminate the risks posed by radio equipment placed on the market
  • take immediate corrective measures if there is reason to believe that the radio equipment is non-compliant.

Authorised representatives have, for example the obligation to: 

  • keep the EU declaration of conformity and the technical documentation at the disposal of the Finnish Transport and Communications Agency Traficom for 10 years after the radio equipment has been placed on the market
  • upon reasoned request by the Finnish Transport and Communications Agency Traficom, provide Traficom with all the information and documentation necessary to demonstrate the conformity of radio equipment
  • cooperate with the Finnish Transport and Communications Agency Traficom on any action taken to eliminate the risks posed by radio equipment covered by the authorised representative's mandate
  • take immediate corrective measures if there is reason to believe that the radio equipment is non-compliant
  • The mandate of an authorised representative may not cover the following:
    • designing and manufacturing radio equipment
    • drawing up technical documentation
    • carrying out conformity assessments.

Before placing radio equipment on the market, importers have the obligation to ensure, for example, that:

  • the manufacturer of the radio equipment has carried out the appropriate conformity assessment procedure and drawn up the technical documentation
  • the radio equipment bears the CE marking
  • the radio equipment is accompanied by clear, understandable and intelligible instructions and safety information at least in Finnish and Swedish; the instructions must include the information required to use the radio equipment in accordance with its intended use
  • radio transmitters are accompanied by information on the frequency band(s) in which the radio equipment operates and the equipment’s maximum transmission power
  • each item of radio equipment is accompanied by an EU declaration of conformity
  • the radio equipment must be accompanied by the manufacturer’s name, registered trade name or trade mark, postal address and the details of a point at which the manufacturer can be contacted
  • they indicate on the radio equipment their contact details (name, registered trade name or registered trade mark and postal address); if the information cannot be indicated on the radio equipment, it must be provided on its packaging or in a document accompanying the equipment
  • the radio equipment bears a type, batch or serial number or other element allowing its identification
  • they provide the Finnish Transport and Communications Agency Traficom with all the information and documentation concerning the equipment requested by Traficom and cooperate with Traficom to eliminate the risks posed by radio equipment placed on the market
  • they take immediate corrective measures if there is reason to believe that the radio equipment is non-compliant.

Before making radio equipment available on the market, distributors have the obligation to ensure, for example, that:

  • the radio equipment bears the CE marking
  • the radio equipment is accompanied by the required documents, instructions and safety information at least in Finnish and Swedish
  • the manufacturer and the importer of the radio equipment have ensured that the radio equipment can be operated in at least one EU country without infringing the requirements on the use of radio spectrum
  • the manufacturer and importer of the radio equipment have ensured that the equipment bears a type, batch or serial number or other element allowing its identification
  • the manufacturer and importer of the radio equipment have indicated their names, registered trade names or trade marks, postal addresses and the details of points at which they can be contacted
  • the radio equipment is accompanied by clear, understandable and intelligible instructions and safety information at least in Finnish and Swedish; the instructions must include the information required to use the radio equipment in accordance with its intended use
  • radio transmitters are accompanied by information on the frequency band(s) in which the radio equipment operates and the equipment’s maximum transmission power
  • each item of radio equipment is accompanied by an EU declaration of conformity
  • they provide the Finnish Transport and Communications Agency Traficom with all the information and documentation concerning the equipment requested by Traficom and cooperate with Traficom to eliminate the risks posed by radio equipment placed on the market
  • they take immediate corrective measures if there is reason to believe that the radio equipment is non-compliant

The obligations of fulfilment service providers include the following:

If the manufacturer, importer and authorised representative are not established in the EU, the fulfilment service provider has the following obligations with respect to the products it handles:

  • to verify that the EU declaration of conformity and technical documentation have been drawn up, keep them available and make them available to the market surveillance authorities upon request
  • to make all information and documentation on the radio equipment available to the market surveillance authorities upon request
  • to inform the market surveillance authorities if it has reason to believe that a product in question presents a risk
  • to cooperate with the market surveillance authorities
  • to indicate on the product or on its packaging, the parcel or an accompanying document its name, registered trade name or registered trade mark and contact details, including postal address.
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