Correction of Standards for Wireless Devices on Aircraft: What Manufacturers and Operators Must Review

Key data

Manufacturers of wireless devices for aeronautical use and operators of mobile communication systems on board aircraft face a concrete problem: the technical references published in the EU Official Journal contained errors, creating a gray area about which harmonized standard is valid for demonstrating conformity.

The correction affects the Implementation Decision (EU) 2025/2499, adopted on December 9, 2025, which in turn amended the Implementation Decision (EU) 2022/2191. Both establish the harmonized standards under the Radio Equipment Directive (RED), the legal framework that allows manufacturers to presume conformity with EU essential requirements when their products comply with the technical standards referenced in the Official Journal.

The problem is not minor: in the field of radio equipment certification, an erroneous reference can invalidate the presumption of conformity, require repeating homologation tests, or generate blockages in marketing within the European single market.

What does this regulation establish?

This error correction acts on two types of equipment regulated under the RED Directive:

• Short Range Devices (SRD): wireless equipment operating in specific frequency bands with limited power, used in aeronautical environments.
• Mobile Communications on Aircraft (MCA): infrastructures that enable the use of mobile devices during flight.

Harmonized standards are European technical standards (developed by bodies such as ETSI or CEN) whose reference is published in the EU Official Journal. When a manufacturer demonstrates that their product complies with a harmonized standard published, they automatically obtain the presumption of conformity with the essential requirements of the applicable directive, without the need for additional testing before a notified body.

The affected regulatory chain is as follows:

The correction has retroactive effect to the date of entry into force of Decision 2025/2499 (December 11, 2025), meaning that the corrected version is the one that should be considered applicable from that date.

Economic and operational impact

The direct impact is not a new fee or automatic penalty, but it can generate relevant operational costs for affected companies:

• Review of technical documentation: any company that has prepared its EU Declaration of Conformity citing the erroneous reference of Decision 2025/2499 must verify whether it needs to update that declaration with the corrected reference.
• Risk of uncertainty in the certification chain: if the erroneous reference was used in homologation processes or conformity audits, it may be necessary to repeat or supplement those processes.
• Potential commercial blockages: products citing standards with incorrect references may encounter obstacles at customs or in validation processes by national market surveillance authorities.
• Cost of legal and technical review: companies will need to allocate internal or external resources to verify the concrete impact on their portfolio of products certified under Decision 2022/2191 and its amendments.

Who does it affect?

• Manufacturers of short-range devices (SRD) intended for aeronautical use that have certified their products under Decision 2022/2191 or its December 2025 amendment.
• Manufacturers and suppliers of MCA systems (mobile communication on board aircraft) operating in the European market.
• Aeronautical operators that use or install these devices on their aircraft and must demonstrate conformity to regulatory authorities.
• Notified bodies and testing laboratories that have issued conformity reports citing the affected references.
• Importers and distributors of these devices in the EU, who are co-responsible for the conformity of the products they place on the market.
• Compliance officers and legal teams of companies in the aeronautical and telecommunications sector with presence in the EU.

Practical example

A European manufacturer of MCA systems that in January 2026 prepared its EU Declaration of Conformity citing Implementation Decision (EU) 2025/2499 to demonstrate that its equipment complies with the essential requirements of the RED Directive may have relied on the harmonized standard reference that contained the error.

With the publication of this correction, that manufacturer must:

1. Identify which specific harmonized standard reference it cited in its technical documentation.
2. Compare that reference with the corrected version published in OJ L 202690752.
3. If the reference was the erroneous one, update the EU Declaration of Conformity and the product technical file to reflect the correct reference.
4. Communicate the change to distributors and importers if the product is already on the market.

This process, although it does not necessarily involve repeating laboratory tests, does require time for legal and technical review, and can affect multiple products in the portfolio if the company has a wide range of equipment certified under these standards.

What should companies do now?

1. Identify affected products: review the catalog of equipment certified under Decision 2022/2191 and its December 2025 amendment (Decision 2025/2499) to determine which could be affected by the erroneous reference.
2. Consult the corrected version: access the text published in the EU Official Journal (OJ L 202690752) to identify exactly which harmonized standard reference has been corrected.
3. Verify technical documentation: check whether the EU Declarations of Conformity and technical files of affected products cite the erroneous or correct reference.
4. Update documentation if necessary: issue revised versions of the EU Declaration of Conformity with the corrected reference and update the product technical file.
5. Inform the distribution chain: notify importers, distributors, and end customers if products are already on the market and documentation must be updated.
6. Consult with the notified body: if certification involved a notified body, verify with it whether the error in the reference affects the issued reports and if any additional action is necessary.

Official source

Consult complete regulation in official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202690752