Foundation Licences, Amateur Radio Kits and IR 2028

One of the most common topics that we’re asked relates to the restrictions about using transmitter kits at Foundation. Here’s my take on this:

First, as a reminder, here is the relevant clause from the amateur radio licence:

7(2) Where this Licence is a Foundation Licence, the Licensee shall only use commercially available Radio Equipment which satisfies IR 2028. Foundation Licence holders may also use Radio Equipment constructed using commercially available kits which satisfy IR 2028.

Why no kits at Foundation?

Well actually, you can build all sorts of kits at Foundation – you can build a receiver, antenna, filter, balun, ATU, PSU… all sorts of things – the restriction is there for using transmitters built from kits. Why? Here’s the wording from Ofcom:

Holders of the Foundation Licence have demonstrated only limited technical competence and so pose a greater risk of causing harmful interference (even if inadvertently) if they construct their own apparatus. We therefore restrict holders of the Foundation Licence to apparatus that conforms to Interface Requirement IR 202835 or is assembled from kits, which conform to IR 2028. We believe that if apparatus conforms to IR2028 it should be possible to demonstrate its conformity with the essential requirements of the RED (Radio Equipment Directive). Through IR 2028, we therefore manage the risk of inadvertent harmful interference. (Source – Section 2.75 Guidance for licensees)

The syllabus (as of 2020) has items like soldering, construction, use of a multimeter, VFO characteristics and harmonics all at Intermediate – this is required learning for transmitter construction and testing.

Can someone make my kit for me?

My take is “no”… partly because 7(2) is clear on the word “use”, but also because of two other clauses in Section 7:

7(3) Notwithstanding any other terms of this Licence, the Licensee shall ensure that the Radio Equipment is designed, constructed, maintained and used so that its use does not cause any Undue Interference to any wireless telegraphy.

7(5) The Licensee shall conduct tests from time to time to ensure that the requirements set out in this Clause 7 are met.

To me, these paragraphs say that a Foundation licence holder needs to be confident that the kit is properly designed and constructed, and to be technically competent to “maintain” and “test” it. By Ofcom’s definition, Foundation licence holders are not.

What IR 2028 Kits are available?

None that we know of.

Know of one? Let us know!

It’s always struck me as a little odd that I’ve never seen a kit advertised as IR2028 compliant. A kit manufacturer would likely be able to sell loads by marketing a kit that meets this standard, so there’s presumably a reason why no kit maker is willing to state compliance. I can only assume that manufacturers aren’t willing to risk that one of their kits may be assembled incorrectly, cause interference, lose them their compliance listing and damage their brand.

Is Kit X IR 2028 Compliant?

You’ll need to ask the kit developer / supplier to confirm this. 

How can I get around this?

By getting an Intermediate licence – you can then build what you want.

If a Foundation licence holder really wants to get into kit construction (with testing and maintenance) and feels they can cope with building a transmitter, then they probably have the skills needed to pass Intermediate without much trouble!

The above summary is just my personal take. Got a different opinion? Know of a compliant kit? Add a message below, and share it!

Pete M0PSX