Same problem here: We added the ST25DV04K to a battery-powered "EMC-product".
Apart from external access via NFC to the memory (where the ST25DV can be assumed to be passive) only the EMC directive (2014/30/EU) and RoHS apply.
Adding the requirement to conform with the Radio Equipment Directive (RED, 2014/53/EU) also enforces conformity with the Low Voltage Directive (LVD, 2014/35/EU), as the RED negates the lower voltage limit of the LVD.
This means:
- Safety tests (EN 62368) are mandatory.
- EMC-tests are shifted away from the generic standard (EN 61000) towards RED-standards (EN 301 489, based on EN 55032).
- Additional measurements regarding efficient frequency use (EN 300 330).
- Exact standard revisions have to be listed in the OJEU to grant "presumption of conformity".
- The lab chooses the applicable standard (not the manufacturer via risk assessment).
(list not exhaustive)
Maybe when talking to a smaller (flexible, more competitive) lab you will be able to negotiate a broadening of 1.6.3.13 of the "RED Guide", use the EMCD and do a risk assessment for that.
But if you want an international type approval (read: "FCC Grant") in parallel to you CE mark, you will talk to a bigger (more agency-like) lab. And they will be fixed to the "combined equipment" approach described above.
(BTW: Ironically the FCC doesn't care about passive tags and continue to treat the product as a regular "unintentional radiator".)
The Eurosmart position paper of 06 Nov 2017 "Radio Equipment directive and passive RFID products" is not helpful either, because it narrows it's scope to exclude "active RFID products using a battery or an active antenna". And our product contains a battery and the microcontroller can supply power to the ST25's Vcc-pin.
On the other hand it excludes ST's other RFID chips from CE marking - so there are no DoCs, which you could incorporate into your own risk assessment.
"ANNEX I" does not list "Dynamic NFC/RFID tag IC" (only cards and FIDO tokens).
Conclusion:
Technically SFish.1's question is answered, but the not in a satisfying way.
ST's "White Paper: How can NFC add value to your brand and enhance the user experience ?" concentrates only on benefits and leaves out all of the drawbacks. Not only can test and certification effort for the European Single Market easily triple in the described scenario, but "Cyber Security for Consumer Internet of Things" could also come on top of it (if your app has an internet connection).
Personally I hope that, at least as a member of Eurosmart, ST impactfully advocates for broader exclusions from the RED as well as their accurate definition.
In the meantime a white paper on the proper conduct of the RED risk assessment for Dynamic NFC/RFID tags IC with EEPROMs would be highly appreciated.
Or at least an entry in the knowledge base (which currently counts zero entries for "ST25NFC/RFID readers").
