CLC/TR 50734:2025
(Main)Application of EMF standards to combined products
Application of EMF standards to combined products
This document explains the application of harmonized and other EMF standards for placing on the market combined products with single or multiple radios to demonstrate conformity with the essential requirements laid down in article 3(1)(a) (health and safety of persons and domestic animals and safety of property) of the Radio Equipment Directive 2014/53/EU (RED) [1]. In particular this document addresses: - the EMF conformity assessment of this type of product, including how to make use of EMF assessments already performed on each constituent product of the combined product and to identify the additional assessment necessary; - the selection of the exposure limits for general public or for workers and test conditions. The type of products covered by this document is a product consisting of the combination of two or more products where at least one of them is a radio equipment as defined in the RED. Examples and types of products to be covered by this document include, but are not limited to, a combination of radio product(s) in radio product (e.g. Hi-Fi receiver with WPAN module integrated), combination of radio and non-radio product (e.g. domestic appliance with WLAN module integrated, radio-controlled lighting system, etc.).
Anwendung von EMF-Normen auf kombinierte Produkte
Application des normes relatives aux champs électromagnétiques (EMF) aux produits combinés
Uporaba standardov EMF za kombinirane izdelke
General Information
Standards Content (Sample)
SLOVENSKI STANDARD
01-november-2025
Uporaba standardov EMF za kombinirane izdelke
Application of EMF standards to combined products
Anwendung von EMF-Normen auf kombinierte Produkte
Application des normes relatives aux champs électromagnétiques (EMF) aux produits
combinés
Ta slovenski standard je istoveten z: CLC/TR 50734:2025
ICS:
33.100.10 Emisija Emission
2003-01.Slovenski inštitut za standardizacijo. Razmnoževanje celote ali delov tega standarda ni dovoljeno.
TECHNICAL REPORT CLC/TR 50734
RAPPORT TECHNIQUE
TECHNISCHER REPORT September 2025
ICS 33.100.10
English Version
Application of EMF standards to combined products
Application des normes relatives aux champs Anwendung von EMF-Normen auf kombinierte Produkte
électromagnétiques (EMF) aux produits combinés
This Technical Report was approved by CENELEC on 2025-08-18.
CENELEC members are the national electrotechnical committees of Austria, Belgium, Bulgaria, Croatia, Cyprus, the Czech Republic,
Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, the
Netherlands, Norway, Poland, Portugal, Republic of North Macedonia, Romania, Serbia, Slovakia, Slovenia, Spain, Sweden, Switzerland,
Türkiye and the United Kingdom.
European Committee for Electrotechnical Standardization
Comité Européen de Normalisation Electrotechnique
Europäisches Komitee für Elektrotechnische Normung
CEN-CENELEC Management Centre: Rue de la Science 23, B-1040 Brussels
© 2025 CENELEC All rights of exploitation in any form and by any means reserved worldwide for CENELEC Members.
Ref. No. CLC/TR 50734:2025 E
Contents Page
European foreword . 3
Introduction . 4
1 Scope . 5
2 Normative references . 5
3 Terms and definitions . 5
4 Abbreviated terms . 6
5 Types of products considered . 7
6 Elements of the assessment procedures . 8
6.1 General . 8
6.2 Exposure limits . 9
6.3 Exposure assessment . 9
6.3.1 General . 9
6.3.2 Product specific harmonized standards . 10
6.3.3 Generic harmonized standards . 11
6.3.4 European and International standards . 11
6.3.5 Assessment of simultaneuous transmissions . 11
6.3.6 Actual maximum approach . 11
Bibliography . 12
European foreword
This document (CLC/TR 50734:2025) has been prepared by CLC/TC 106X “Electromagnetic fields in the
human environment”.
Attention is drawn to the possibility that some of the elements of this document may be the subject of patent
rights. CENELEC shall not be held responsible for identifying any or all such patent rights.
This document has been prepared under a standardization request addressed to CENELEC by the European
Commission. The Standing Committee of the EFTA States subsequently approves these requests for its
Member States.
Any feedback and questions on this document should be directed to the users’ national committee. A complete
listing of these bodies can be found on the CENELEC website.
Introduction
With the Internet of Things (IoT), more and more systems get interconnected, delivering new use cases that
create more convenience for the consumers. In this connected world, products that were previously not
connected to the internet are now equipped with wireless communication functions and can detect and interact
with their environment.
Products that enable radio communication or radio determination will fall in the scope of the Radio Equipment
Directive and assessment of compliance with its essential requirements will be required. Especially, the
essential requirement related to health and safety, introduces an obligation to assess the human exposure to
electromagnetic fields (EMF). As the radio equipment will emit radio waves, care needs to be taken that the
limits of such EMF exposure will be respected when the product, non-radio or radio product, is equipped with
wireless functions (a “combined product”). This document aims to guide manufacturers of such combined
products in the assessment of their products with respect to the EMF requirements of the Radio Equipment
Directive.
1 Scope
This document explains the application of harmonized and other EMF standards for placing on the market
combined products with single or multiple radios to demonstrate conformity with the essential requirements laid
down in article 3(1)(a) (health and safety of persons and domestic animals and safety of property) of the Radio
Equipment Directive 2014/53/EU (RED) [1]. In particular this document addresses:
— the EMF conformity assessment of this type of product, including how to make use of EMF assessments
already performed on each constituent product of the combined product and to identify the additional
assessment necessary;
— the selection of the exposure limits for general public or for workers and test conditions.
The type of products covered by this document is a product consisting of the combination of two or more
products where at least one of them is a radio equipment as defined in the RED.
Examples and types of products to be covered by this document include, but are not limited to, a combination
of radio product(s) in radio product (e.g. Hi-Fi receiver with WPAN module integrated), combination of radio and
non-radio product (e.g. domestic appliance with WLAN module integrated, radio-controlled lighting system, etc.).
2 Normative references
There are no normative references in this document.
3 Terms and definitions
For the purposes of this document, the following terms and definitions apply.
ISO and IEC maintain terminology databases for use in standardization at the following addresses:
— ISO Online browsing platform: available at https://www.iso.org/obp
— IEC Electropedia: available at https://www.electropedia.org/
3.1
combined product
product consisting of two or more constituent products where at least one of them is a radio communication or
radio determination product (i.e. radio equipment as defined in the RED)
[SOURCE: ETSI EG 203 367 V1.1.1 [2], definition combined equipment, modified]
3.2
(constituent) product
constituent part of a combined product (i.e. radio product or non-radio product)
[SOURCE: ETSI EG 203 367 V1.1.1 [2], definition product, modified]
3.3
function
functionality that cannot be identified as a separate product and is embedded in one of the constituent products
of the combined product
Note 1 to entry: This function can be a radio function or non-radio function.
[SOURCE: ETSI EG 203 367 V1.1.1 [2], definition function, modified]
3.4
reasonably foreseeable (conditions of) use
intended use as well as use of products in conditions, which results from lawful and readily predictable human
and system behaviour that can be anticipated by the manufacturer
Note 1 to entry: Use conditions explicitly excluded by the manufacturer in the information for use or user training, but
nevertheless reasonably foreseeable under the assumption that the user has not read the information for use or has not
followed training instructions, are deemed to represent reasonably foreseeable misuse and such conditions fall outside this
definition.
Note 2 to entry: In the context of this document, it is possible that the conditions of use include exposure conditions of
bystanders.
[SOURCE: CLC/TR 50713:2021 [3], 3.2, modified]
3.5
low power (combined) product
(combined) product where the average total radiated power is less than or equal to the low-power exclusion
level
[SOURCE: EN 62479:2010 [4], 3.7, modified]
3.6
low power exclusion level
P
max
specified condition on product output power, which can also depend on other variables such as frequency and
distance of radiating source from persons, such that the exposure level produced by the source will not exceed
the applicable basic restrictions or exposure limit values EU
[SOURCE: EN 62479:2010 [4], 3.8, modified]
3.7
Exposure Ratio
ER
ratio of the exposure metric and the applicable exposure limit, both expressed in terms of power
[SOURCE: EN IEC 62232:2022 [22], 3.47]
3.8
Total Exposure Ratio
TER
summed exposure ratio (ER) contributions from multiple RF sources at an evaluation point
[SOURCE: EN IEC 62232:2022 [22], 8.5, modified]
4 Abbreviated terms
For the purposes of the present document, the following abbreviated terms apply:
EMF Electromagnetic Field(s)
ER Exposure Ratio
RED Radio Equipment Directive, 2014/53/EU
RFID Radio Frequency Identification
TER Total Exposure Ratio
WLAN Wireless Local Area Network
WPAN Wireless Personal Area Network
5 Types of products considered
Two or more separate radio products may be placed on the market or made available together as a single
product for end use. The manufacturer will verify on a case-by-case basis whether a combination of products
and parts will be considered as one product within the scope of the RED or whether they should be considered
as separate products. For this purpose, the intended operation of the product as well as the reasonably
foreseeable conditions of use will be taken into account, including exposure conditions of bystanders.
If the radio product is incorporated in a fixed and permanent way in the non-radio product in such a way that it
cannot be easily accessed and readily removed, the RED is applicable to the combined product as a whole.
NOTE Supplementary Guidance on the LVD/EMCD/RED [5] and Guide to the Radio Equipment Directive 2014/53/EU,
9.3 [6] provides clarifications on the applicability of RED with other EU acts on safety or EMC.
Figure 1 illustrates an example with a radio product that is a component of the non-radio product.
Figure 1 — Radio product incorporated in a non-radio product
If the radio product can be easily removed because it is not permanently affixed, only the radio product is subject
to the RED (example: domestic appliance equipped with a standard interface where a WLAN dongle can be
inserted).
The combination of radio and non-radio products as well as the integration of several radio products into a single
product require care in assessing conformity against the essential requirements of article 3(1)(a) of the RED.
Figure 2 — Combination of radio product with a non-radio product
Figure 2 represents another concept of “combined product” covered by this document.
Product A and Product B are products in their own right. Both Product A and Product B could have been
assessed and placed on the EU market individually according to the applicable EU Directive(s). At least one of
these is a radio product as defined in the RED.
Product C is a new product constructed by the combination of Product A and Product B. Product B can be
integrated in Product A (see Figure 1) or Product A and Product B can be installed in a common housing (see
Figure 2). Since Product A or Product B is a radio product within the scope of the RED, also this new product C
falls under the scope of the RED as a result of the combination.
ETSI EG 203 367 V1.1.1 (2016-06) [2] Table 1 provides an overview of possible RED conformity assessments
for a radio product and a combined product.
6 Elements of the assessment procedures
6.1 General
The manufacturer of the combined product is responsible to ensure the conformity of the product against the
RED. The manufacturer defines the intended operation of the product and with respect to health and safety
(RED Article 3(1)(a)), the reasonably foreseeable conditions.
NOTE The Blue Guide [3] provides clarifications on the role and the responsibilities of economic actors in the supply
chain when they make their products available on the EU market.
If the manufacturer of the combined product installs the radio product in a non-radio product in equivalent
conditions and according to the installation instructions for the radio product (e.g. using the antennas
recommended in the installation instructions, distance to the user and exposed person respected), then no
additional assessment of the radio function of the combined product is necessary.
If the manufacturer of the combined product does not install the radio product in a host non-radio product in
equivalent assessment conditions and according to the installation instructions for the radio product, then the
combined produ
...
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