As the supporting standard for EU (EU) 2022/30, EN 18031-3:2024 regulates “wireless devices handling financial/virtual value”—jurisdiction depends not on product category, but whether wireless links create financial fraud risks. Post-mandatory enforcement on August 1, 2025, authorities clarified a 4-tier product classification system, adding virtual asset devices and financial IoT terminals to compliance categories while refining exemption lists. Breaking free from static market checklists, this guide decodes compliance boundaries, confusing scenarios, and exemption rules based on regulatory essence to help businesses avoid access risks or resource waste from misjudgments.
Businesses exporting EU wireless devices often stumble on EN 18031-3: relying on outdated checklists to miss required certifications, or blindly applying for exempt products—wasting time and costs. Post-2025 mandate, bodies strictly audit product scope; “following others” no longer works.
EN 18031-3 scope centers on “wireless function + financial value linkage.” The 2025 EU official 4-tier system clearly defines “mandatory, assessment-required, exempt” boundaries—more accurate than vague market checklists.
1.Core Compliance Zone: Deep Integration of Financial Value & Wireless Functions (Mandatory, No Exceptions)
Core functions involve financial/virtual asset processing/transfer; wireless links are critical for value flow, with highest fraud risks—certification is mandatory, no exemptions.
·Traditional financial payment terminals: Wireless POS, mobile QR payment devices, networked ATMs, NFC-enabled smart cash registers—wireless functions directly support core transactions (collection, transfer), the basic regulated category.
·Virtual asset processing devices: Cryptocurrency hardware wallets, cold digital asset wallets, virtual currency transaction terminals—core functions manage private keys and initiate value transfers via wireless; 2025 regulatory focus.
·High-value/cross-border financial terminals: Cross-border wireless payment terminals, enterprise wireless reconciliation devices, multi-currency smart terminals (single transaction >€5,000, cross-border fund flows)—highest risk level.
2.Derivative Compliance Zone: Additional Financial Functions Trigger Risks (Easy to Miss, Key Audit Focus)
Primary functions are non-financial, but additional features link to payment/value transfer—businesses often miss these; non-compliance leads to EU customs seizures post-launch.
·Wearables: NFC-enabled smartwatches, bands, glasses—even if payment is a secondary feature, wireless payment capability triggers compliance.
·Financial IoT devices: Smart printers with remote supply ordering & auto-deduction, in-vehicle infotainment for parking/fuel payments, contactless vending machines—IoT wireless functions directly initiate payments.
·Emerging value exchange devices: Payment-enabled smart locks (small parking/access fees), voice-controlled in-vehicle payment modules, wireless terminals for digital collectible transactions—2025 new compliance category, rarely covered in market guides.
3.Ambiguous Assessment Zone: Data Nature Determines Compliance (Assessment-Required, No Blind Applications)
Compliance can’t be generalized—depends on whether processed data has monetary value. Confirm via function scenarios or Notified Body consultations to avoid wasted certification resources.
·Assessment-required devices: Wireless devices handling tradable virtual items (e.g., crypto-rechargeable smart consoles, transferable digital collectible terminals), industrial IoT sensors transmitting supply chain financial settlement data (triggering accounts receivable financing)—value-linked data, gradually regulated.
·Exempt devices: Wireless devices only query account balances, stock prices, or financial news (e.g., financial displays, balance-only smart bands, stock terminals)—information-only, no value processing, no fraud risks, no certification needed.
·Partial exemption-eligible devices: Internal-network-only financial terminals (no external wireless links) or non-market test prototypes—apply for exemptions to Notified Bodies, no full certification required.
4.Clear Exemption Zone: Regulated by Specific Laws or Low-Risk (Directly Exempt, No Certification)
2025 EU official refined exemption lists; devices regulated by specific laws or with no financial fraud risks are explicitly exempt from EN 18031-3.
·Specific law-regulated devices: Medical devices (MDR, e.g., wireless infusion pumps), avionics (Regulation (EU) 2018/1139), automotive electronic safety devices (automotive-specific laws)—existing dedicated compliance, no duplicate certification.
·Wireless-free devices: Wired-only POS, non-wireless financial terminals—no wireless links, no wireless fraud risks, direct exemption.
·Low-risk consumer devices: Wireless devices without financial value processing (e.g., regular smart toys, entertainment-only smart speakers, payment-free fitness bands)—no financial fraud risks, no certification needed.
II.2025 High-Confusion Product Classification: Real Cases
Most business misjudgments involve “seemingly compliant but exempt” or “seemingly unrelated but required” scenarios. 2025 real cases decode 5 high-frequency scenarios for accurate compliance.
1.Smartwatches: Payment-enabled vs. Payment-free
·NFC/voice payment-enabled: Required—wireless payment capability creates transaction fraud risks.
·Step-tracking/balance-checking only, no payment: Exempt—information-only, no value transfer.
2.IoT Sensors: Financial data vs. General data transmission
·Supply chain financial settlement/value data: Assessment-required—data links to financial settlement, tampering fraud risks exist.
·Temperature/humidity/equipment status data: Exempt—no financial value, no fraud risks.
3.Smart Locks: Payment-enabled vs. Access-only
·Wireless property/access fee payment: Required—wireless triggers payments, derivative compliance.
·Access authentication only, no payments: Exempt—access-only, no financial transactions.
4.Game Consoles: Virtual currency transaction-enabled vs. Entertainment-only
·Wireless crypto-rechargeable/virtual item tradable: Required—handles tradable virtual value, fraud risks.
·Entertainment-only, no virtual asset transactions: Exempt—no financial value linkage.
4.Tablets: Payment-module integrated vs. Office-only
·Wireless payment-enabled cash register tablets: Required—wireless payment capability, core compliance.
·Office/information-only, no payment: Exempt—no financial transactions.
III.Practical Business Self-Assessment: 3 Steps for Quick Classification (No Body Needed)
For new products, avoid blind body consultations—3-step self-assessment for quick compliance decisions, efficient and cost-saving.Step 1: Check for wireless functionsConfirm Wi-Fi, Bluetooth, 4G/5G, NFC support—no wireless = direct exemption, no further checks; wireless = Step 2.
Step 2: Check for financial/virtual value handlingJudge if functions directly/indirectly handle currency/virtual assets via 3 questions: Can it initiate payments? Transfer value? Process financial settlement-linked data? Yes to any = Step 3; No = exempt.
Step 3: Check exemption list alignmentAlign with “Clear Exemption Zone”—if medical/aviation/wired-only, exempt; else = certification or assessment required.
2025 EN 18031-3 product classification relies on “function risk penetration,” not static checklists. For businesses, master the “wireless + financial value” core logic and 3-step self-assessment to avoid misjudgments.For professional certification consulting, contact BLUEASIA at +86 13534225140.
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