Serbia: RED-Aligned Declaration of Conformity (DoC) Framework Replaces CoC by 2027

Serbia is moving forward with a major regulatory reform for radio equipment, advancing the country's full alignment with the European Union's Radio Equipment Directive (RED, 2014/53/EU). Under the Rulebook on Radio Equipment (Official Gazette of the Republic of Servia, No. 24/2024), the national Certificate of Conformity (CoC) regime will be phased out, paving the way for a self-declaration model based on the EU Declaration of Conformity (DoC) and the CE Mark as of 1 January 2027.

This update is one of the most significant compliance shifts for manufacturers placing radio equipment on the Serbian market, and it requires early preparation to avoid disruptions in market access.

Background: From National CoC to EU-Aligned Self - Declaration of Conformity

The Regulatory Authority for Electronic Communications and Postal Services (RATEL), under the Ministry of Information and Telecommunications (MIT), officially published the new Rulebook on Radio Equipment in the Official Gazette RS 24/2024 on March 22, 2024. The Rulebook took effect on March 30, 2024, and became applicable from June 1, 2024, replacing the previous 2012 Rulebook on Radio and Telecommunications Terminal Equipment.

The reform aligns Serbian domestic legislation with Directive 2014/53/EU (RED) and introduces a phased transition toward a self-declaration model harmonized with EU practice.

Key Provisions of the Serbia DoC and RED-Aligned Framework

Current Certification Requirements (Until 31 December 2026)

• RF product certification remains mandatory under Article 20(1), and a Certificate of Conformity (CoC) is still required to access the market.

• Under the new rules, the CoC now has a formal validity period of 5 years (Article 20(4)).

• As of January 1, 2025, RATEL no longer conducts conformity assessments. The Conformity Assessment Body (CAB) has assumed full responsibility for assessing conformity and issuing certifications, following Article 32.4 of the Rulebook.

Transition to EU-Aligned Self-Declaration (From 1 January 2027)

• Serbian Certificates of Conformity (CoCs) will no longer be mandatory for radio products from December 31, 2026. Starting January 1, 2027, the CE Mark will be sufficient for radio products in Serbia.

• After this transition, a manufacturer's Declaration of Conformity (DoC) must be prepared in the Serbian language, following the specific format defined in Annex V of the Rulebook.

What This Means for Manufacturers

The shift from a mandatory third-party CoC model to a self-declaration DoC model significantly changes how radio equipment manufacturars, importers, and authorized representatives must prepare for the Serbian market:

• Reduced certification overhead. Manufacturers will no longer need a national third-party CoC issued in Serbia from 2027 onward. The EU CE marking process will satisfy Serbian requirements.

• Greater responsibility on the manufacturer. A self-declaration model means that the manufacturer assumes full legal liability for compliance. Technical files, risk assessments, and EU DoC documentation must be airtight.

• Localization of documentation. Even under the self-declaration regime, a Serbian-language DoC following Annex V of the Rulebook will remain required.

• Strategic supply chain readiness. Manufacturers should evaluate their R&D and sypply chain readiness to accommodate these shifting requirements, particularly regarding the move toward Serbian - language documentation and local harmonized standards.

• Avoiding double work. Until 31 December 2026, manufacturers must maintain Serbian CoCs for new placements. Planing early avoids costly re-submissions during the transition window.

Certification Impact Summary

Item	Before 1 June 2024	1 June 2024 – 31 Dec 2026	From 1 January 2027
Governing rule	2012 Rulebook on R&TT Equipment	Rulebook on Radio Equipment (RS Gazette No. 24/2024)	Full alignment with EU RED (2014/53/EU)
Certification model	National CoC (mandatory)	National CoC (mandatory, 5-year validity)	EU Declaration of Conformity (DoC) + CE Mark
Issuing body	RATEL	Designated Conformity Assessment Body (CAB)	Manufacturer self-declaration
Language requirement	Serbian	Serbian	Serbian DoC per Annex V
CE Mark recognized?	No	No (CoC still required)	Yes – sufficient on its own

Timeline and Required Actions

Regulatory Timeline

• 22 March 2024 - Rulebook on Radio Equipment published (Official Gazette RS No. 24/2024).

• 30 March 2024 - Rulebook enters into force.

• 1 June 2024 - Rulebook becomes applicable; new 5-year CoC validity period begins.

• 1 August 2025 - Application of essential requirements covering personal data protection, fraud prevention, emergency services, and accessibility (aligned with EU RED Article 3.3 implementation).

• 1 January 2025 - RATEL ceases conformity assessment activities; designated CAB takes over.

• 31 December 2026 — Last day Serbian CoCs are mandatory.

• 1 January 2027 — CE Mark + EU DoC alone are sufficient for placing radio equipment on the Serbian market.

  
  

Required Actions for Manufacturers

1. Audit existing certifications. Identify all radio products currently sold in Serbia under a national CoC and confirm validity periods.

2. Engage with the designated CAB. Until 31 December 2026, new placements still require a Serbian CoC from the designated Conformity Assessment Body.

3. Prepare an EU-compliant Technical File. Ensure your product complies with RED 2014/53/EU and harmonized standards (e.g., ETSI EN 300 series, EN 301 489, EN 62368-1, EN 18031 series for cybersecurity).

4. Draft the Serbian-language DoC. Format must follow Annex V of the Rulebook.

5. Verify RED Article 3.3 cybersecurity readiness. Particularly for Wi-Fi, Bluetooth, and IoT devices.

6. Plan around the December 2026 cutoff. New CoCs issued late in 2026 may still be valid for up to 5 years, but new strategies should already lean on the EU DoC model.

   
   

How Serbia's Reform Fits the Broader EU Compliance Landscape

Serbia's transition reflects a broader regional movement toward EU regulatory convergence. As an EU candidate country, Serbia's adoption of the RED-aligned DoC framework demonstrates progress in harmonizing technical regulations and removing barriers for cross-border placement of radio equipment. Manufacturers already serving the EU market will benefit from a simplified path into Serbia from 2027 onward provided their EU technical documentation is complete and well-maintained.

Serbia's transition to a RED-aligned Declaration of Conformity (DoC) framework marks the end of mandatory national CoCs and the beginning of full self-declaration alignment with the EU. Manufacturers should not wait until the 1 January 2027 deadline. Early preparation, including technical documentation, supply chain assessments, and language localization, will determine which companies maintain uninterrupted access to the Serbian market during the transition.