Radio equipment and lifts are covered by Directive 2014/53/EU and Directive 2014/33/EU respectively, both listed in Annex I Section A. An AI system that is itself such a product, or is intended to be used as a safety component of it, can be high risk under Article 6(1) where third party conformity assessment is required under the sector directive. The AI requirements are then assessed through the sector conformity procedure. This guide explains the route for two very different product families that share the same Annex I section, and it does not decide the position for any named product.
What does the radio equipment directive cover?
Directive 2014/53/EU on radio equipment covers equipment that intentionally emits or receives radio waves for communication or radiodetermination, with scope, exclusions and essential requirements set out in the directive itself. It addresses radio spectrum use, electromagnetic compatibility, electrical safety and, for certain equipment, network, privacy and fraud safeguards. Radio equipment with AI functions can include devices that optimise spectrum use, manage connections, recognise speech or images, or control other functions through a radio link. The AI Act question for such equipment starts with the directive scope: whether the product is radio equipment under the directive, which essential requirements apply, and which conformity assessment procedure applies. A product that contains a radio module is not necessarily radio equipment in the directive sense for every function, and a product that is radio equipment may have AI functions that are unrelated to its radio function. The record should separate the radio function from the AI functions and should address each function on its own terms, rather than treating the whole product as a single radio AI system.
When can radio equipment with AI be high risk?
Radio equipment with AI can be high risk under Article 6(1) where the AI system is itself a product covered by the radio equipment directive, or is intended to be used as a safety component of such a product, and the product must undergo third party conformity assessment under that directive. The safety component question turns on the function and on the consequence of failure under Article 3. A radio function that carries safety critical communications, for example in an emergency or industrial safety context, can be safety relevant in a way that a consumer entertainment radio function is not. A function that manages spectrum or network access can affect safety indirectly if its failure disables a safety communication. The record should describe the communication function, the safety role if any, the failure consequence and the conformity procedure. It should also address cybersecurity and network safeguards, because radio equipment duties in those areas overlap with AI Act accuracy, robustness and cybersecurity requirements. Where the overlap is claimed as equivalence, the claim should be evidenced provision by provision rather than asserted in general terms.
For the broader regulatory framework, see products, machinery and vehicles overview.
What does the lifts directive cover?
Directive 2014/33/EU on lifts and safety components for lifts covers lifts permanently serving buildings and constructions and safety components for lifts, with essential health and safety requirements, conformity assessment procedures and the roles of installers, manufacturers and notified bodies set out in the directive. Lifts are safety critical installations in which failure can cause serious injury, and the directive therefore prescribes detailed requirements for design, installation, inspection and maintenance. AI functions in lifts can include door control, levelling, traffic management, predictive maintenance, voice control and emergency communication. Each function must be examined for its safety role. A traffic management function that optimises waiting time is different from a door control function that prevents a person being trapped or struck. The lift guide in the sector file should identify the installer and the manufacturer roles, the safety components listed in the directive, and the conformity procedure for the lift and for each safety component. The AI analysis builds on that sector identification and does not replace it.
How do lifts show the safety component test in practice?
Lifts provide a concrete illustration of the safety component test because the safety functions are visible and the failure consequences are well understood. A door timing function illustrates the point: a function intended to improve efficiency can still be a safety component if its failure can endanger persons, for example by closing on a person or by allowing movement with doors open. A predictive maintenance function illustrates the opposite boundary: a function that predicts wear and schedules maintenance may support safety without itself performing a safety function, but if it suppresses a safety warning or delays a safety critical repair, its role changes. The record for a lift AI function should therefore describe the normal operation, the failure modes, the protective measures that remain if the AI function fails, and the evidence from testing and inspection. It should also record the maintenance and inspection regime, because a lift AI function that depends on sensors or software updates can degrade if maintenance is missed. The notified body role under the lifts directive should be recorded, including which procedures required notified body involvement.
What other Section A families follow the same pattern?
The same pattern applies to the other Section A families, including pressure equipment, cableway installations, personal protective equipment, appliances burning gaseous fuels, recreational craft and equipment for potentially explosive atmospheres. In each case, the sector directive or regulation sets the scope, the essential requirements and the conformity procedure, and Article 6(1) adds the AI classification question where the AI system is a product or a safety component and third party assessment is required. The details differ sharply: pressure equipment turns on pressure and temperature limits, personal protective equipment turns on the protection it provides to the wearer, and explosive atmospheres equipment turns on ignition prevention. A general guide cannot describe those sector requirements. The value of grouping radio equipment and lifts in this guide is to show how two different families use the same Annex I route, not to suggest that their sector requirements are similar. Each family needs its own sector file, its own standards and its own notified body analysis. A team that copies a radio equipment file into a lifts file, or the reverse, will produce a file that fails on inspection.
Continue with Annex I Section A and Section B.
What does this guide not decide?
This guide does not decide whether any named radio product or lift is high risk, does not reproduce the essential requirements of either directive, and does not describe the conformity procedures in full. It does not address spectrum licensing, building law, lift inspection regimes under national law, or the duties of building owners and maintenance companies, which are separate areas. A manufacturer, installer or operator with a specific product or installation should confirm the sector scope, the conformity procedure and the AI classification with a competent authority or legal adviser and, where relevant, with the notified body. This guide is a route map for two families, not a determination for a product or an installation.
Frequently asked questions
Is a smart speaker high risk because it is radio equipment?
Not automatically. The product must be examined under Directive 2014/53/EU, the AI functions must be examined for a safety component role under Article 3, and the conformity procedure must require third party assessment for Article 6(1) to lead to high risk classification. Many consumer radio products will not meet all of those conditions. The specific product file must be checked.
Is lift traffic optimisation a safety component?
It depends on its function and failure consequences. Optimising waiting time alone may not be a safety function, while a function that controls doors, levelling or movement can be. The function must be described operationally, with failure modes and protective measures, and the conclusion must be recorded with evidence. A general label should not be used as the answer.
Do radio equipment and lifts follow the same conformity procedure?
No. They follow different sector directives with different essential requirements, procedures and notified body roles. They share only the Annex I Section A route under the AI Act, under which the AI requirements are assessed through the sector procedure. Each family needs its own sector file.
When do the Annex I rules apply to these products?
The Chapter III high risk rules for Annex I systems apply from 2 August 2028 under Article 113 as amended by Regulation (EU) 2026/1744. Sector duties under the radio equipment and lifts directives apply under their own timetables and must be checked separately.
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This article is an informational overview, not a legal determination. Check the current legal text and official implementation guidance for your system and role.
Consolidated Regulation (EU) 2024/1689 ↗AI Act Service Desk timeline ↗