Meshtastic, MeshCore and CE Marking: The Hardware Trap

The hardware question is not “does this board boot Meshtastic?” It is: what exactly was placed on the market, who took responsibility for it, which configuration was assessed, and do its actual frequency, antenna, power, firmware and airtime remain within the applicable rules?

Three Questions That Must Not Be Mixed

A valid EU Declaration of Conformity does not grant access to every frequency. An amateur callsign does not convert 868 MHz SRD operation into amateur radio. And a spectrum setting that stays below 25 mW e.r.p. does not repair missing product-conformity evidence.

Why American “900 MHz Ham Mesh” Does Not Translate

US amateur rules include 902–928 MHz as the 33 cm amateur band in ITU Region 2, subject to sharing requirements. In Europe, the common LoRa range around 868/869 MHz is governed through short-range-device conditions, not a European amateur allocation. The same modulation can therefore sit inside two very different legal frameworks.

The current EU SRD decision contains multiple distinct entries across 863–870 MHz. Examples include different categories and combinations of 5, 25 or 500 mW e.r.p., bandwidth limits, duty cycles and spectrum-access requirements. “EU_868” is therefore only a firmware-region label; it is not a complete compliance statement.

What CE Marking Actually Means

Under the Radio Equipment Directive 2014/53/EU, the manufacturer is responsible for ensuring that radio equipment placed on the Union market meets the applicable essential requirements. For ordinary radio products these include safety, electromagnetic compatibility and effective and efficient use of spectrum. Additional requirements apply to certain categories.

The manufacturer must perform the applicable conformity assessment, prepare technical documentation, issue the EU Declaration of Conformity, provide traceability and required instructions, and affix the CE marking. A notified body is not automatically involved in every assessment; the available assessment route depends in part on how the relevant harmonised standards are applied.

Do not diagnose conformity from logo spacing

The “China Export” story is not a reliable field test. Marks can be missing, misproportioned or misused, but visual spacing alone cannot establish whether the equipment complies. The practical check is the exact product identity, the real CE marking, the dated and signed manufacturer’s EU Declaration of Conformity, the named legislation and standards, the instructions, and the responsible economic operator.

A Module Can Be Radio Equipment—But It Is Not a Blanket

A common oversimplification says that a module is “only a component” and therefore outside the RED. The European Commission’s RED Guide is more precise: an RF module, and in some cases a radio-capable integrated component that needs an accessory such as an antenna or software, can itself meet the RED definition of radio equipment when placed on the market.

That does not make every product built around it compliant. The module manufacturer must define the intended and foreseeable conditions and provide instructions that preserve compliance. Integrating the module into another product can create additional obligations for the finished product.

A development board can legitimately be placed on the market as radio equipment with stated integration conditions. The correct conclusion is neither “the module is CE, so everything is covered” nor “modules can never be CE.” Read the scope and conditions of the exact evidence.

Antenna, Power and Firmware Form One RF Configuration

Licence-exempt limits are frequently expressed as radiated power. For a simple conducted transmitter path:

A higher-gain antenna can therefore require a lower transmitter setting. An SMA connector is not inherently non-compliant, but the permitted antennas, gains, cable arrangements and power settings must be controlled well enough that the product remains compliant and the user can follow the instructions.

The RED Declaration of Conformity can identify accessories, components and software that allow the radio equipment to operate as intended. Changing firmware can affect frequency, output power, occupied bandwidth, duty cycle, channel access, spurious emissions and security behaviour. “The hardware once passed” is not a defence for an operating mode outside the assessed configuration.

Height is not automatically a new CE product

Moving an otherwise unchanged, covered radio-and-antenna configuration from a desk to a mast does not automatically manufacture a new item of radio equipment. Height can nevertheless change coverage, interference reach, exposure geometry, lightning risk, installation safety and whether the intended-use instructions are being followed.

A relay assembled from a board, new enclosure, power system, external antenna and custom firmware may be materially different from the evaluated board configuration. The relevant question is what has changed and whether that change can affect compliance—not whether the node has acquired the label “infrastructure.”

Duty Cycle Is a Network Property Too

Mesh firmware can generate beacons, acknowledgements, retries, route discovery and forwarded packets in addition to the user’s messages. The applicable duty cycle or access requirement concerns actual transmitter airtime in the relevant band, not merely the payload typed by one user.

A node that is quiet on a bench may become busy when deployed as a well-heard router. Compliance analysis therefore needs the configured modem parameters, packet duration, autonomous traffic, retry policy and worst credible traffic load. A high-gain antenna cannot compensate for airtime congestion; link budget and channel occupancy are different design constraints.

Internet-Connected Nodes Now Have a Cybersecurity Layer

Since 1 August 2025, certain categories of radio equipment placed on the Union market have also been subject to RED Article 3(3)(d), (e) and (f) requirements covering network protection, privacy/personal-data safeguards and fraud protection. The exact subset depends on the equipment’s functions; an Internet-connected gateway is not automatically equivalent to an isolated LoRa endpoint.

Commission Delegated Regulation (EU) 2026/339 will repeal this RED cybersecurity delegated regulation from 11 December 2027, when the relevant Cyber Resilience Act regime applies fully. Equipment placed on the market during the 1 August 2025–10 December 2027 interval remains subject to market surveillance for the RED requirements that applied to it.

Buying Direct: Know Who Carries Responsibility

A European warehouse address is not proof that the product was lawfully placed on the EU market. Conversely, manufacturing in China does not prevent genuine conformity. Follow the supply chain and identify the manufacturer, importer or other responsible EU economic operator.

BIPT explicitly warns Belgian buyers that when equipment is bought outside the European market, the buyer may be considered an importer and may have to ensure that the equipment is intended for the EU market and meets all legal requirements. Direct shipment and online marketplace arrangements can be legally nuanced, so do not announce yourself an importer—or assume you have no responsibility—on the basis of parcel routing alone.

Before buying, look for:

• an unambiguous manufacturer, product type and hardware revision;
• the CE marking on the product and, where required, packaging;
• a dated and signed EU Declaration of Conformity, or the permitted simplified declaration with a working link to the full text;
• manufacturer and responsible EU economic-operator contact details;
• frequency bands, maximum transmitted power and restrictions in the instructions;
• the exact antenna, software and accessory conditions; and
• evidence for the actual band variant—not a similar 433, 868, 915 or 920 MHz model.

The Amateur-Radio Exclusion: Real but Narrow

Annex I of the RED excludes certain radio equipment used by radio amateurs, within the meaning of the ITU Radio Regulations, provided the equipment is not made available on the market. The listed cases include kits intended for assembly and use by radio amateurs, equipment modified by and for radio amateurs, and equipment constructed by individual radio amateurs for experimental and scientific purposes related to amateur radio.

This is not a universal “ham exemption” for every undocumented product. A finished mass-produced board sold as a consumer mesh node does not become individually constructed equipment because a radio amateur bought it. A club or shop supplying ready-to-use equipment is not the same situation as an individual amateur constructing or modifying a station for experimentation.

Belgian licence classes matter

BIPT’s current amateur-radio guidance states specifically that a holder of a class A operator’s certificate may build their own equipment. Operators must also follow the frequency plan for their certificate class and hold the required station authorisation. For Belgian class B or C operation, do not infer a self-build privilege from the EU-level amateur exclusion; use compliant equipment unless BIPT’s current conditions provide a clear route.

Use an amateur allocation for amateur privileges

In Belgium and the wider ITU Region 1 framework, 430–440 MHz includes amateur use, subject to national conditions and sharing. The 433 MHz area also supports specified SRD uses, so “70 cm” is neither empty nor exclusively amateur. A coordinated amateur mesh experiment must respect the Belgian frequency plan, band planning, existing users, station control and any unattended or remote-station conditions.

Use the hardware variant designed for the band. Retuning an 868/915 MHz board in firmware does not make its matching network, filter, PA or antenna suitable for 70 cm. Measure conducted power, occupied bandwidth, harmonics and unwanted emissions with equipment appropriate to UHF.

Who Can Rely on What?

A Product-by-Product Review Workflow

1. Freeze the identity. Record manufacturer, model, revision, radio chip, oscillator, PA, filter and band variant.
2. Retrieve the manufacturer’s DoC. Confirm that it names the exact type and current applicable legislation.
3. Check the assessment scope. Note antennas, power settings, firmware, host requirements, supply, enclosure and environmental conditions.
4. Calculate radiated power. Include conducted power, feedline loss and antenna gain in dBd for e.r.p. limits.
5. Check the exact SRD entry. Device category, band, bandwidth, access technique and duty cycle must all fit.
6. Model network airtime. Include autonomous traffic, relaying, retries and worst credible loading.
7. Assess modifications. New antennas, firmware, amplifiers, filters, enclosures and power supplies can affect the original evidence.
8. Check national operation rules. CE conformity and spectrum permission are independent gates.
9. Document the result. Keep the DoC, instructions, settings, link-budget and airtime calculations with the node record.

A Coordinated Belgian 70 cm Route

RF.Guru’s MeshCore RFC Belgium explores a documented, coordinated approach to 70 cm amateur mesh experimentation. The useful part of an RFC is not the acronym; it is making the frequency choice, modem parameters, channel use, identification, node roles and coexistence assumptions reviewable before wide deployment.

Coordination does not replace legal authority, and an RFC does not certify hardware. It can prevent every operator from inventing incompatible parameters and can give repeater managers, associations and technical groups a concrete proposal to test.

The RF.Guru Take

Meshtastic and MeshCore are software ecosystems, not radio services and not conformity-assessment bodies. A useful project starts by separating the product, spectrum and station questions.

For 868 MHz, use equipment and settings that are demonstrably within the relevant RED evidence and SRD conditions. For experimental amateur hardware, use an authorised amateur allocation and the privileges of the actual licence class. In either case, measure the transmitter, control the antenna configuration, budget the airtime and keep the documentation.

Questions, antenna-factor records or height trials to share? Contact RF.Guru.