Guidelines to support Notified Bodies in charge of radio equipment compliance: Smartphones

Smartphones can play an essential role in emergency situations, where accurate caller location enables a swift response from emergency services.

For this purpose, the Commission Delegated Regulation (EU) 2019/320 supplements the Radio Equipment Directive regarding caller location technologies in emergency communications from mobile devices to include “technical solutions for the reception and processing of Wi-Fi data, and data from Global Navigation Satellite Systems (GNSS) compatible and interoperable with at least the Galileo system’’ (European Commission, 2021), in order to make it more effective.

Under the terms of the Delegated Regulation, mobile device manufacturers will have until March 2022 to ensure that new mobile devices can provide access to both Wi-Fi and GNSS location information in emergency communications.

When it comes to the compliance path, in view of the rejection of the EC standardisation request by the standardisation organization ETSI under the Delegated Regulation 2019/320 – which has resulted in absence of harmonised standards – Notified Bodies will now need to assess the compliance of mobile devices via conformity assessment procedures. In this regard, the European Commission has adopted Guidelines to help Notified Bodies apply the applicable requirements in a consistent manner, as well as to provide clarifications on the equipment’s compliance criteria. The Guidelines for compliance with Delegation Regulation (EU) 2019/320are divided in several sections:

  • Requirements;
  • Definitions;
  • GNSS Test specifications;
  • Exposure of additional Galileo observables;
  • Specifications related to making available for transmission of the data referred to in Article 1(2) of Delegated Regulation 2019/230;
  • Specifications related to wireless local area network for positioning;
  • List of abbreviations.

In accordance with the guidance, how can Notified Bodies assess a device with the Delegated Directive?

Among others, tests for the smartphone performance assessment shall be conducted using Radio Frequency simulators generating GNSS signals. The GNSS simulator shall, as a minimum, be able to generate Galileo signals.

It is important to underline that, in order to achieve full compliance with the requirements related to Galileo, it is necessary for smartphone manufacturers to prove compatibility and interoperability with Galileo differentiators. Section 5 of the Guidelines enlists Tests to achieve Galileo’s Compatibility:

1. GNSS Simulator Configuration in the Conformance Testing;

2. NMEA output test;

3. Time to first fix test;

4. Horizontal accuracy test.

Beatriz Reyes Aguirre

Regulatory Affairs Department


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European Commission. (2021). Guidelines for Compliance with Delegated Regulation (EU) 2019/320. Retrieved on 21/06/2021 from

GPS.Gov. (2020). The Global Positioning System. Retrieved on 18/06/2021 from

European Agency Number Association. (2020). EENA Special Focus. Retrieved on 18/06/2021 from

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