After August 2025, EN 18031 has become a mandatory requirement for wireless products entering the EU market. When arranging certification, laboratories often quote 3–5 week timelines, but actual execution frequently faces delays due to various issues.

I. Key Premise for CE RED Cybersecurity Certification

EN 18031 is Not an Independent Certification

EN 18031 is not a standalone certification system but a harmonized standard under the RED Directive (2014/53/EU), fulfilling cybersecurity requirements under RED Article 3.3 (d)(e)(f).

Accordingly, NB involvement is determined by the RED Directive’s conformity assessment modules, not EN 18031. Most wireless products qualify for Module A (internal production control) without NB involvement. Only products listed in RED Annex IV require NB participation.

Common products such as Bluetooth headsets, smart cameras, and Wi-Fi routers do not require mandatory NB pathways regardless of password design or parental controls. NB requirement depends solely on Annex IV listing — a critical point affecting timelines and costs, to be confirmed upfront to avoid retroactive NB processes post-testing.

  II. Complete EN 18031 Certification Process

1.Preparation Phase: Data collation, standard interpretation, technical documentation preparation — duration depends on enterprise efficiency, ranging from days to weeks.

2.Sample Submission Phase: Sample delivery, laboratory receipt, testing scope confirmation — typically several days to 1 week.

3.Testing Phase: Penetration testing and security assessment. The commonly quoted 3–5 week timeline generally includes testing plus basic reporting.

4.Rectification Phase: Fixing issues identified in testing — simple issues resolved in days, complex issues taking longer.

5.Documentation Finalization Phase: Compiling final technical files and signing DoC — fast if adequately prepared upfront.

6.NB Audit Phase (where applicable): 2–4 weeks for NB review. As of 2026, most RED Notified Bodies possess EN 18031 audit capabilities, with timelines varying by body.

  III. Most Common Causes of CE RED Cybersecurity Certification Delays

1.Sample Preparation Issues

·Debug interfaces: EN 18031 does not require closure but mandates access control to prevent unauthorized use; unprotected interfaces require rectification, mostly achievable via firmware.

·Firmware version: Pre-production candidate firmware is acceptable for testing if security logic is consistent; final release is not required.

·Functional integrity: Incomplete OTA and other security functions restrict testing scope and may require retesting.

2.Inconsistent Technical Documentation & ProductsEN 18031 requires threat models, security architecture, vulnerability management processes, etc. Common issues are not inability to write documentation but mismatches between documents and products — e.g., claiming AES-256 while implementing AES-128, or unimplemented functions — causing rework.

3.Testing Issue Rectification (Most Delayed Stage)Penetration testing reveals weak passwords, open ports, configuration vulnerabilities, etc.

·Simple issues: Closing logs, changing default passwords, etc. — resolvable in 1–3 days

·Complex issues: Protocol flaws, encryption restructuring — longer timelines

Key Point: Security issues must be rectified and cannot be bypassed via NB pathways. NBs also enforce EN 18031 compliance and do not waive vulnerabilities.

  IV. CE RED Cybersecurity Certification Timeline (Bluetooth Headset Example)

·Week 1: Data preparation, testing scope confirmation, sample verification

·Week 2: Sample delivery and laboratory scheduling

·Weeks 3–5: Laboratory testing with concurrent simple rectifications

·Week 6: Final rectification, documentation completion, report issuance, DoC signing

Total: Approximately 6 weeks, compressible to 4–5 weeks with smooth progress, extendable to 8 weeks with multiple issues.

  V. Timeline Reference by Product Category

·Simple Products (Single-band Bluetooth devices): 4–6 weeks (8 weeks with issues)

·Mid-Range Products (Routers, smart cameras): 6–10 weeks

·Complex Products (POS, industrial controllers): 10–14 weeks or longer

·NB Pathway Add-On: Extra 2–4 weeks

Clear confirmation of product status, documentation, and solutions before testing minimizes surprises and ensures on-time EN 18031 certification.Contact BLUEASIA Testing & Certification Consultant: +86 13534225140