Audio and wearables
EU Declaration of Conformity for Bluetooth Trackers and GPS Trackers: requirements and checklist
By Ing. Jaroslav Křepelka, Owner, DoC solutions s.r.o. · Updated 29 October 2026
In short: A Bluetooth or GPS tracker is declared under the Radio Equipment Directive 2014/53/EU, including Delegated Regulation (EU) 2022/30, and the RoHS Directive 2011/65/EU. Trackers that report location through a phone app or a cellular network communicate over the internet and process location data, so both the network-protection and the data-protection requirements of RED apply since 1 August 2025.
Item finders, luggage tags, GPS trackers for cars and pet trackers are tiny radio devices whose whole purpose is to process location data, which makes them a priority for the RED cybersecurity and data-protection rules. Many also run on coin cell batteries, which bring a serious child-safety risk.
This page covers Bluetooth item finders that work through a phone app or a find-my network, GPS trackers with a cellular connection, and pet and child trackers.
Checklist: what your bluetooth / gps tracker declaration must contain
- Model exactly as on the device or packaging, with each colour, battery and network variant covered
- Name and postal address of the manufacturer (and of the authorised representative, if appointed)
- The statement that the declaration is issued under the sole responsibility of the manufacturer
- Radio Equipment Directive 2014/53/EU, including Delegated Regulation (EU) 2022/30
- RoHS Directive 2011/65/EU
- The harmonised standards for each radio (Bluetooth, GNSS, cellular), EMC, safety, EMF and cybersecurity, with versions
- Place and date of issue, name and function of the signatory, and the signature
Which EU legislation applies
| Legislation | Applies? | In the DoC? | Notes |
|---|---|---|---|
| Radio Equipment Directive2014/53/EU | Applies | In the DoC: Yes | Bluetooth, GNSS receivers and cellular modules all make the tracker radio equipment. RED covers safety, EMC and radio. |
| Cybersecurity and data protection delegated actDelegated Regulation (EU) 2022/30 | Applies | In the DoC: Yes | Applicable since 1 August 2025. A tracker that sends its location through a phone app, a find-my network or a cellular connection communicates over the internet, directly or via other equipment, so network protection (Article 3(3)(d)) applies; location is personal data, so data protection (Article 3(3)(e)) applies too. Child and pet trackers worn on the body are wearable or childcare equipment as well. |
| RoHS Directive2011/65/EU | Applies | In the DoC: Yes | Restriction of hazardous substances in electrical and electronic equipment. |
| Batteries Regulation(EU) 2023/1542 | Applies | In the DoC: No | For the coin cell or built-in rechargeable battery: marking and producer registration, and from 18 February 2027 the end-user removability requirement of Article 11 for built-in batteries. |
| General Product Safety Regulation (GPSR)(EU) 2023/988 | Applies | In the DoC: No | Covers risks outside RED, above all the button battery hazard for children: a swallowed coin cell can cause severe internal burns within hours. Battery compartments should be child-resistant and the packaging and instructions should carry warnings. |
| WEEE Directive2012/19/EU | Applies | In the DoC: No | Producer registration in every EU country where you sell and the crossed-out wheeled bin symbol. |
Typical harmonised standards
A harmonised standard gives presumption of conformity only in the version cited in the Official Journal of the EU. Always check the current list for each directive before you issue or update a declaration (European Commission: harmonised standards); the versions below are the ones commonly used at the time of writing, and the right selection depends on your product.
Radio and EMC
Versions shown are cited under RED in Implementing Decision (EU) 2022/2191 as amended; for EN 301 489-1 use the version listed in the Official Journal.
- ETSI EN 300 328 V2.2.2Bluetooth and other 2.4 GHz wideband transmission
- ETSI EN 303 413GNSS receivers (GPS, Galileo)
- ETSI EN 301 908 seriesIMT cellular networks, for LTE-M, NB-IoT or 4G trackers
- ETSI EN 301 489-1 with EN 301 489-17 V3.3.1 (and EN 301 489-19 or -52 as relevant)EMC standard for radio equipment
Safety and EMF
- EN 62368-1Safety of ICT equipment, including the requirements for products containing coin or button batteries (current edition EN IEC 62368-1:2024 + A11:2024)
- EN 62479 or EN 50663Human exposure to electromagnetic fields for low-power equipment
Cybersecurity and data protection
- EN 18031-1:2024Internet-connected radio equipment (cited with restrictions)
- EN 18031-2:2024Radio equipment processing data (cited with restrictions)
Hazardous substances (RoHS)
- EN IEC 63000:2018Technical documentation for the assessment of electrical and electronic products with respect to the restriction of hazardous substances
Already have a declaration for your bluetooth / gps tracker?
A certification expert checks it against everything on this page and tells you exactly what to fix. Written report in 48 hours, €99 per product (excl. VAT).
Among other things, we check for the mistakes we find most often:
- Data protection ignored
- GNSS or cellular radio not assessed
- Coin cell accessible to children
Common mistakes in bluetooth / gps tracker declarations
Data protection ignored
A tracker exists to process location data. Since 1 August 2025 RED Article 3(3)(e) applies to it, typically shown with EN 18031-2, and the app and cloud service are part of the assessment.
GNSS or cellular radio not assessed
GPS trackers often list only the Bluetooth standard. Every radio in the device needs its own harmonised standard or other evidence.
Coin cell accessible to children
A battery compartment that opens without a tool or a push-and-turn action is a serious risk and a frequent recall reason. Use a child-resistant design and warnings.
Misuse for stalking not considered
Item finders can be used to track people without their knowledge. A risk assessment that addresses unwanted-tracking alerts strengthens the data-protection case.
LVD and EMC listed next to RED
For radio equipment RED covers safety and EMC; listing the other directives is a template error.
What you need besides the declaration
- Technical documentation
- Radio, EMC, safety and EMF test reports for every radio, the cybersecurity and data-protection assessment including the app and cloud, battery data and RoHS documentation. Keep it for 10 years.
- Instructions and warnings
- Button battery warnings on the packaging and in the instructions, privacy information, and setup and safety instructions in the local language.
- Economic operator in the EU
- An importer, authorised representative or responsible person established in the EU (Article 4 of Regulation (EU) 2019/1020).
No EU presence yet? We can act as your EU authorised representative or responsible person.
Frequently asked questions
Do Bluetooth trackers have to meet the RED cybersecurity requirements?
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Yes, if they report location through a phone app, a find-my network or a cellular link, which nearly all do. Both network protection and data protection under Delegated Regulation (EU) 2022/30 then apply.
Which standards apply to a GPS tracker?
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EN 303 413 for the GNSS receiver, the EN 301 908 series for a cellular module, EN 300 328 for Bluetooth, the EN 301 489 EMC parts, EN 62368-1 for safety and EN 18031 for cybersecurity.
Are coin cell batteries in trackers regulated?
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Yes. The Batteries Regulation covers the battery itself, and the risk of children swallowing it is a safety issue under the General Product Safety Regulation and EN 62368-1.
What does MyCECheck check on a tracker declaration?
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RED and the delegated act, the standards for every radio and their versions, the data-protection evidence, the product identification and the economic operator. Written report within 48 hours.
Already have a declaration for your bluetooth / gps tracker?
A certification expert checks it against everything on this page and tells you exactly what to fix. Written report in 48 hours, €99 per product (excl. VAT).
Among other things, we check for the mistakes we find most often:
- Data protection ignored
- GNSS or cellular radio not assessed
- Coin cell accessible to children