10. Regulatory Compliance¶

10.1. EU Declaration of Conformity¶

Hereby, TopBytes Ltd declares that the radio equipment type Morse Trainer (Model: MORSETRAINER-01) is in compliance with Directive 2014/53/EU (Radio Equipment Directive).

The full text of the EU Declaration of Conformity is available at:

https://morse.topbytes.net/compliance

10.2. Applicable EU Directives¶

This product complies with the essential requirements of the following EU directives:

Directive	Title
2014/53/EU	Radio Equipment Directive (RED)
2011/65/EU	Restriction of Hazardous Substances (RoHS), as amended by 2015/863
2012/19/EU	Waste Electrical and Electronic Equipment (WEEE)
Regulation (EU) 2023/1542	EU Battery Regulation

Note

The Radio Equipment Directive 2014/53/EU covers the essential requirements of both the EMC Directive 2014/30/EU and the Low Voltage Directive 2014/35/EU for radio equipment. These are therefore not declared separately.

10.3. Harmonised Standards Applied¶

The following harmonised standards have been applied to demonstrate conformity:

Standard	Title	Essential Requirement
EN 300 328 V2.2.2	Wideband transmission systems -- 2.4 GHz band	Article 3.2 -- Radio spectrum
EN 301 489-1 V2.2.3	EMC for radio equipment -- Common requirements	Article 3.1(b) -- EMC
EN 301 489-17 V3.2.4	EMC for radio equipment -- WLAN specific	Article 3.1(b) -- EMC
EN IEC 62368-1:2020 +A11	Audio/video, IT & communication equipment -- Safety	Article 3.1(a) -- Health & Safety
EN 62311:2020	Human exposure to electromagnetic fields	Article 3.1(a) -- RF exposure
EN IEC 62133-2:2017 +A2	Portable sealed secondary lithium cells and batteries -- Safety	Article 3.1(a) -- Battery safety
EN IEC 63000:2018	RoHS technical documentation	RoHS Directive 2011/65/EU

10.4. Radio Equipment Information¶

10.4.1. WiFi Operating Parameters¶

Technology	IEEE 802.11 b/g/n (WiFi)
Operating frequency band	2400--2483.5 MHz
Maximum transmit power	< 100 mW (20 dBm) EIRP
Number of channels	13 (EU)
Channel bandwidth	20 MHz
Antenna	Internal (PCB trace, non-removable)

10.4.2. Operating Restrictions¶

The 2.4 GHz WiFi frequency band (2400--2483.5 MHz) is harmonised across all EU and EEA member states. There are no country-specific restrictions for this product within the EU/EEA.

This device operates as a WiFi client (infrastructure mode) connecting to existing wireless networks. It also supports access point (AP) mode for initial configuration. It does not function as a general-purpose wireless router or repeater.

10.5. RF Exposure Information¶

This device complies with EU requirements for limiting exposure of the general public to electromagnetic fields, as assessed in accordance with EN 62311:2020.

The Morse Trainer is a low-power device that transmits at a maximum of 100 mW EIRP in the 2.4 GHz band. It is designed for tabletop or desktop use and is not intended to be worn on the body or held against the head.

This device has been evaluated for RF exposure compliance at a minimum separation distance of 20 cm between the device and the user's body. At this distance and power level, the electromagnetic field exposure is well below the limits set by Council Recommendation 1999/519/EC (based on ICNIRP guidelines).

Recommendations:

Use the device on a desk, table, or shelf -- not directly against the body
Do not modify the antenna or connect external antennas
If co-locating with other radio equipment, maintain reasonable separation

10.6. Safety Warnings¶

10.6.1. Battery Safety¶

Warning

This device contains a rechargeable lithium-ion (Li-ion) 18650 battery.

Use only replacement batteries of the same type, chemistry, and rating.
Do not short-circuit, puncture, crush, or incinerate the battery.
Do not expose the battery to temperatures above 60°C or below -20°C.
If the battery appears swollen, leaking, or damaged, stop using the device immediately. Do not attempt to charge a damaged battery.
Charge only with a certified USB power supply (5V, CE-marked).
Do not leave the device charging unattended for extended periods.
Keep spare batteries away from metallic objects (coins, keys) that could short-circuit the terminals.
The battery is user-replaceable. When replacing, ensure correct polarity.

10.6.2. Charging¶

Charge the device using the USB-C port with a compliant 5V USB power supply.
The red LED indicates charging is in progress; the blue LED indicates charging is complete.
Do not use damaged cables or power supplies.
Disconnect the USB cable during thunderstorms.
Do not charge the device in direct sunlight or near heat sources.

10.6.3. Operating Environment¶

Indoor use only. This device is not designed for outdoor or weatherproof use.
Operating temperature: 0°C to +40°C.
Storage temperature: -20°C to +60°C.
Humidity: 20% to 80% relative humidity, non-condensing.
Do not expose the device to moisture, rain, or liquids.
Do not use the device in dusty, dirty, or excessively hot or cold environments.
Do not block ventilation openings or place the device in enclosed spaces without airflow.
Maximum operating altitude: 2000 m above sea level.

10.6.4. General Safety¶

This device is not a toy. Keep out of reach of small children.
Do not disassemble, modify, or attempt to repair the device beyond battery replacement. There are no other user-serviceable parts inside.
Do not expose the device to strong magnetic fields, excessive vibration, or mechanical shock.
If the device emits unusual smells, sounds, or smoke, disconnect the power and remove the battery immediately. Contact the manufacturer.
This device is intended for Morse code training and amateur radio hobbyists. It is not intended for use in safety-critical, medical, or life-support applications.

10.6.5. Audio Output¶

When using headphones or earphones via the 3.5mm jack, start at a low volume and increase gradually.
Prolonged listening at high volume may cause hearing fatigue.
The built-in buzzer produces audible tones during Morse code practice. This is normal operation.

10.7. Waste Disposal (WEEE)¶

This product is marked with the crossed-out wheelie bin symbol, indicating that it must not be disposed of with unsorted household waste when it reaches the end of its life.

Correct disposal: Take the product to a designated collection facility for the recycling of waste electrical and electronic equipment (WEEE). Contact your local authority or retailer for information on your nearest collection point.

Separate collection and recycling of waste electrical and electronic equipment helps to:

Conserve natural resources
Ensure hazardous substances are handled safely
Protect the environment and human health

10.7.1. Battery Disposal¶

The 18650 Li-ion battery must be removed and disposed of separately. Do not dispose of batteries in household waste.

Take used batteries to a designated battery collection point. Many retailers and local authorities provide battery recycling facilities.

Per Regulation (EU) 2023/1542 (EU Battery Regulation), portable batteries must be collected separately for recycling.

Producer	TopBytes Ltd
WEEE category	Category 3 -- IT and telecommunications equipment

10.8. Producer Information¶

Producer	TopBytes Ltd
WEEE category	Category 3 — IT and telecommunications equipment

10.9. Manufacturer¶

Name	TopBytes Ltd
Address	55 Kings Ride, HP10 8BP, UK
Website	https://www.topbytes.net
Product support	https://dxspotter.topbytes.net
Email	support@topbytes.net

10.10. Firmware Updates¶

The Morse Trainer supports over-the-air (OTA) firmware and screen updates via WiFi. Firmware updates may include:

Bug fixes and performance improvements
New training modes and features
Updates to maintain regulatory compliance

The device checks for updates when connected to WiFi. Updates are downloaded securely via HTTPS.