Directive 2014/53/EU · Del. Reg. 2022/30Generate my documentation — €99
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You manufacture fitness trackers and sell them in the EU. Heart rate, step count, sleep data, GPS location — your product processes personal data. Art. 3(3)(e) of Directive 2014/53/EU applies. If it also connects to the internet via a phone app, Art. 3(3)(d) applies too. The documentation is mandatory from 1 August 2025.

Your fitness tracker records heart rate, steps, sleep patterns, GPS routes. It syncs via BLE to a smartphone app. The app connects to the internet. Art. 3(3)(d) and Art. 3(3)(e) both apply. A compliance lab quotes €9,000 per model. You have 5 models = €45,000. REDCheck: €99 per product. 5 models = €495.

Generate my RED documentation — €99Free: does my fitness tracker need RED cybersecurity documentation?

€99 one-time payment · 5 PDF documents in ZIP · 30 minutes · 100% in your browser

Directive 2014/53/EU · Art. 3(3)(d)(e)(f) · Art. 21 + Annex V · Art. 18 + Annex VI · Art. 10(9) + Annex VII · Delegated Reg. (EU) 2022/30 · EN 18031-1, -2, -3

EU cybersecurity documentation for fitness trackers: the numbers

Fitness trackers sit at the intersection of two Art. 1(2) categories: internet-connected (Art. 1(2)(a)) and wearable (Art. 1(2)(d)). Both routes lead to Art. 3(3)(e).

2 categories
Wearable (Art. 1(2)(d)) + internet-connected (Art. 1(1)). Double basis for Art. 3(3)(e).
Heart rate = personal data
Health-related data is personal data under GDPR Art. 4(1) and special category data under Art. 9(1).
€9,000 vs €99
Compliance lab vs REDCheck per model. 5 models = €45,000 vs €495.

What REDCheck does with your product data

You enter your product specifications. REDCheck structures the cybersecurity documentation requirement by requirement, following the EN 18031 categories.

1
Company details
Legal name, role under Directive 2014/53/EU, country, EU contact.
2
Product classification
Determines applicable requirements: Art. 3(3)(d), (e) and/or (f).
3
Cybersecurity assessment
EN 18031 categories: access control, authentication, secure comms, updates, vulnerability management.
4
Risk assessment
Structured risk table per applicable requirement.
5
EU Declaration of Conformity
Art. 18 + Annex VI. Basis for CE marking.
6
Download ZIP
5 PDFs. Add to technical file. Retain 10 years (Art. 10(4)).

Three mistakes fitness tracker manufacturers make about RED cybersecurity

COMMON ERROR

"Fitness trackers are consumer electronics, not 'radio equipment'"

Art. 2(1)(1) defines 'radio equipment' as any product that intentionally emits or receives radio waves. A fitness tracker with BLE or WiFi is radio equipment.

COMMON ERROR

"Step count and calories are not personal data"

Step count linked to a user account is personal data under GDPR Art. 4(1). Heart rate data is special category data under Art. 9(1). Art. 3(3)(e) applies.

COMMON ERROR

"Our tracker is exempt because it's similar to a medical device"

The medical device exemption applies ONLY to devices regulated under Regulation (EU) 2017/745. A consumer fitness tracker without medical device classification is NOT exempt.

What's in the ZIP

5 PDF documents per product model. Each cites the exact article of Directive 2014/53/EU that it covers.

1

Product Classification

Art. 1, Del. Reg. (EU) 2022/30 + Art. 3(3), Dir. 2014/53/EU.

2

Cybersecurity Technical Documentation

Art. 21 + Annex V.

3

Risk Assessment

Arts. 3(3)(d) and (e).

4

EU Declaration of Conformity

Art. 18 + Annex VI.

5

Simplified Declaration + Label

Art. 10(9) + Annex VII.

Look before you buy — Download sample dossier (PDF, fictitious product)

Generated from your data, in your browser. No product data leaves your computer.

What you pay

🧾 COMPLIANCE LAB
€9,000
Per model. 3-4 months. 5 models = €45,000.
✓ REDCHECK
€99
5 documents. 30 minutes. 5 models = €495.

Technical documentation and third-party testing: two layers

● LAYER 1

Cybersecurity technical documentation (Annex V)

5 PDF documents. 30 min. €99. Art. 21 prerequisite for any conformity route.

∅ LAYER 2

Conformity assessment by a Notified Body

If you fully apply EN 18031, self-declare via Module A (Annex II). If not, Art. 17(4) requires third-party involvement.

We do not sell testing. We do not sell consulting. We sell the tool that structures your cybersecurity documentation.

What happens without cybersecurity documentation

Wearables that process health data are under heightened scrutiny.

🇪🇺
Market withdrawal
Immediate

Arts. 40(1), 40(4) and 43.

🔒
GDPR overlap
Up to €20M or 4% of global turnover

Device-level failure can trigger GDPR enforcement. Penalties compound.

📉
Investor and board impact
Strategic

EU launch delay costs more than €99.

Alternatives

AlternativeCostWhat you get
Compliance lab / Notified Body€9,000–20,000/model3-4 months. Third-party assessment.
EU consultancy€5,000–12,000/modelCustom report. Weeks.
Rely on medical device regulationsN/AOnly if classified under MDR 2017/745.
REDCheck€995 documents, 30 min. Covers Art. 3(3)(d) + (e).

Manufacturing more than one fitness tracker model?

Professional Pack: €999 for 70 generations.

Request volume pricing
Reply within one business day.

What REDCheck guarantees and what it does not

REDCheck generates a document structured under Art. 21 and Annex V of Directive 2014/53/EU based on the information you enter. The truthfulness, accuracy and completeness of that information is your responsibility as manufacturer of the radio equipment.

We guarantee that the document structure follows Art. 21 and Annex V of Directive 2014/53/EU and that the legal references cited are correct as of the latest verification date.

REDCheck is not legal advice. For specific situations, consult a lawyer or specialised regulatory consultancy.

Frequently asked questions

My tracker only has BLE — no WiFi. Does Art. 3(3)(d) apply?
If the BLE tracker syncs to a smartphone that connects to the internet, Art. 3(3)(d) applies. Plus Art. 1(2)(d) applies Art. 3(3)(e) because it is a wearable processing personal data.
Our fitness tracker also has an NFC chip for contactless payments. Does Art. 3(3)(f) apply?
Yes. Art. 1(3) applies Art. 3(3)(f) to internet-connected radio equipment that enables money transfers. REDCheck covers all three requirements.
Can we use Module A (self-declaration) for fitness trackers?
Yes, if you fully apply EN 18031-1 (if internet-connected) and EN 18031-2 (for personal data). Art. 17(3)(a) allows Module A.
What happens when the CRA replaces RED?
Delegated Regulation (EU) 2022/30 will be repealed from 11 December 2027.
Is it a subscription?
No. One-time payment. Each license includes a 30-day editing window and up to 10 regenerations. The 5 PDF documents you download are yours permanently.
Can I request a refund?
Under Art. 16(m) of Directive (EU) 2011/83 on consumer rights, by activating the license you give express consent to the immediate generation of the digital content, waiving the 14-day right of withdrawal. Refunds are accepted only for reproducible technical failures reported to hello@solidwaretools.com within 14 days of purchase.
What if the regulation changes?
If Directive 2014/53/EU, Delegated Regulation (EU) 2022/30 or the EN 18031 standards change during your license validity period, you can regenerate the documents with the updated version of the generator at no additional cost.
⚠️ Important notice: REDCheck is a documentary self-assessment tool, not legal advice or a third-party audit. The document is generated from the data you enter. The accuracy of the data is your responsibility under Art. 10(1) of Directive 2014/53/EU. REDCheck does not replace a conformity assessment by a Notified Body where required under Art. 17(4) of the Directive.

Heart rate is personal data. Your tracker needs cybersecurity documentation. Generate it in 30 minutes.

Five PDF documents. Art. 21 and Annex V fully structured. Directive 2014/53/EU. Your product data never leaves your computer.

€99 per product
One-time payment · No subscription · 30 minutes · 10 regenerations · 30-day editing window · Professional Pack: €999
Generate my RED documentation — €99
✓ Last regulatory check: 6 May 2026 · No substantive changes detected · View history