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Why Your EMC Test Pass Isn’t Enough for CE Marking in 2025

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Successfully passing an EMC test—especially to EN 55032 or EN 55035—feels like a big win. And it is. But in 2025, an EMC pass is no longer the finish line for CE marking. It’s just one leg of a much broader compliance journey.

If your product is destined for the EU market, especially if it includes wireless functionality or operates on mains power, there are critical additional directives and standards that must be addressed.

Let’s break it down.

1. EMC Directive: Only the Beginning

EN 55032 (for emissions) and EN 55035 (for immunity) cover essential requirements under the EMC Directive (2014/30/EU). These apply to most multimedia and ITE equipment.

But here’s the catch:

The EMC Directive only applies to products that do not have intentional radio transmitters.

If your product includes Wi-Fi, Bluetooth, LTE/5G, Zigbee, or any other radio interface, you fall under the scope of a different directive altogether.

 

📡 2. The RED Directive: Now With Enforced Cybersecurity (2022/30/EU)

Wireless products must comply with the Radio Equipment Directive (RED) 2014/53/EU. As of August 1, 2025, Articles 3.3(d), (e), and (f) (cybersecurity and data protection) are legally enforceable under Delegated Regulation 2022/30/EU.

You’ll now need to show compliance with:

  • 🔒 Network protection (Article 3.3(d))

  • 🔐 Data protection and privacy (Article 3.3(e))

  • 🛡️ Fraud prevention (Article 3.3(f))

And yes—this means documented risk assessments, secure-by-design development, and test reports for software resilience in addition to your EMC results.

You must also meet radio-specific EMC requirements under RED Annex I, not just general EN 55032/35 tests. For many, this includes EN 301 489-1/-17/-52 and other ETSI harmonised standards depending on the radio tech used.

 

3. The Low Voltage Directive (LVD): Mandatory for Powered Products

If your product is powered by mains (AC) or falls within 50V–1000V AC / 75V–1500V DC, the Low Voltage Directive (2014/35/EU) applies.

This means:

  • Electrical safety testing (e.g. to EN 62368-1 or EN 60335-1)

  • Clear labelling and marking

  • Instruction manuals with safety guidance

  • A complete technical file documenting risk assessments and test evidence

Passing EMC tests doesn’t cover this. LVD requires a separate set of evaluations, often involving high-voltage, leakage current, insulation resistance, and fault condition tests.

 

📄 4. Harmonised Standards & the ‘Presumption of Conformity’

As the European Commission continues to update harmonised standards lists, manufacturers must ensure they are using the latest versions to benefit from the presumption of conformity.

For example:

  • EN 301 489-1 V2.2.3 is no longer enough for RED — updated versions aligned with new cyber norms may be required.

  • EN 62368-1 for LVD has recently transitioned and superseded EN 60950-1.

Outdated test reports = non-compliance, even if they passed at the time.

 

🧾 5. Don’t Forget the Documentation (Technical File Requirements)

CE marking also requires a comprehensive technical file, which includes:

  • Declaration of Conformity (DoC)

  • Test reports (EMC, LVD, RED, etc.)

  • Risk analysis and cybersecurity measures (especially for RED 3.3 compliance)

  • Design drawings, user manuals, and product labelling

 

🚀 What This Means for You

If you’re relying solely on an EMC pass for CE marking in 2025, you’re leaving major gaps that could:

  • Block your product at customs

  • Result in product recalls or penalties

  • Lead to refusal by distributors or online retailers demanding full compliance

 

How C-PRAV Can Help

At C-PRAV, we provide end-to-end guidance across:

  • EMC testing (EN 55032/35 and beyond)

  • Radio testing (ETSI EN 301 489-x, EN 300 328, EN 301 893, etc.)

  • Safety testing for LVD

  • Cybersecurity evaluations under RED 3.3

  • Technical file preparation and audit support

Don’t let a partial compliance strategy cost you access to the EU market.

 

🛠️ Final Takeaway:

CE marking is more than just EMC.

In 2025, it’s a multi-directive, multi-standard process that must be coordinated, current, and complete.

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