New EU Radio Equipment Directive (RED) and Particle?

Last June the new Radio Equipment Directive (RED) came into effect:

According to my reading this new directive requires me to actually test my whole product including the Particle Photon again. Previously, it was just possible to just adhere to the integration standards set out by Particle (
Are there any work arounds for this? ie. instead of mounting the photon directly on my PCB buy a ‘assembled and certified photon’ and just connect the photon via an external cable to my PCB (sounds a bit of a hassle but our current product production is around 50 a year so we don’t need a super scalable solution at this point)?

You can actually do that but wouldn’t it still be considered a product by itself?

Is like the traces are on the PCB where everything is assembled on VS having cables that go between the Photon and your other modules.

You are right, I just mean that when someone would release a ‘photon breakout board + photon + connector + casing’ and get this CE certified. I could just connect my PCR to this ‘photon unit’. It sounds a bit cumbersome but when considering a product with an annual output of ~100 units it is not worth to go through the whole certification process (with the old regulations it did, because it required minimal effort since the photon was certified) and an external photon makes more sense.

@Patrick1 I have read the RE-D directive and I don’t see the requirement to test (re-test) your whole product except if your product contains a new radio emitting device or changes to the antenna. The EU RE-D Q&A - states “any other radio equipment that was already placed on the market before 12 June 2017 will continue to be sold, provided they comply with the legislation applicable at that time”. Since the photon (with or without headers) conforms to and has been sold since before 12 June 2017 with CE mark. The integration documents from Particle are clear on this as well.

For the Photon/PØ and P1 Modules, these integration instructions are the same as for the FCC/IC--so long as you're integrating the modules without modifying the RF design or implementing an antenna with gain greater than that used in certification, your equipment will likely remain compliant.

I am working with a customer to bring a new product to market but with a photon at its core. Our assumption is as above and our focus on testing is for EMC EN-55022 with things like suppression of switched power supplies.

I would appreciate if anyone in the EU countries believes this view is incorrect.

This is indeed an interesting view on it. Would also appreciate input from anyone making use of this?