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Application of Article 3 (3) (i) and 4 of Directive 2014/53/EU relating to Reconfigurable Radio Systems

Single market

The Radio Equipment Directive establishes a regulatory framework for placing radio equipment on the market. Among others, it ensures a Single Market for radio equipment by setting essential requirements for safety and health, electromagnetic compatibility, and the efficient use of the radio spectrum. This initiative aims at specifying the categories of radio equipment concerned by additional essential requirements relating to reconfigurable radio systems.

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Public consultation

ID: 2042

Lobbying Activity

15 responses

Consultation response

DIGITALEUROPE, 4 Mar 2019

DIGITALEUROPE believes that this initiative should only be limited to classes of radio equipment for which there is a clear evidence showing that the upload of software on radio equipment could lead to a serious risk of non compliance in the EU market. So far, problems causing a risk of…

Consultation response

Orgalim – Europe's Technology Industries, 4 Mar 2019

As stressed in the Commission Communication on “digitising European Industry” (COM(2016)180), digitalisation has become one of the major drivers of industry’s competitiveness and innovation capacity. This is enabled namely through radio equipment which are increasingly incorporated in technological…

Consultation response

APPLiA (Home Appliance Europe), 4 Mar 2019

Full details in the attached paper: • RRS are a specific class of equipment based on SDR (Software Defined Radio) and CR (Cognitive Radio) technologies that are able to change the radio parameters of a device via firmware/software update. The SW installed in the consumer devices under the RED…

Consultation response

ARD-Verbindungsbüro Brüssel, 1 Mar 2019

ARD-Liaision Office Brussels Transparency Register No.: 6774178922-55 ARD views on the Inception Impact Assessment on the Commission delegated regulation on Reconfigurable Radio Systems We would like to thank the European Commission for the opportunity to comment on the Inception…

Consultation response

ZVEI e.V. - Verband der Elektro- und Digitalindustrie, 3 Mar 2019

ZVEI is pleased to provide its views on the particular issue of embedded and business software which may be installed in this equipment and products. Our industry is committed to keeping such products interoperable in the public radio spectrum and safe for all end-users including when further…

Consultation response

Free Software Foundation Europe e.V., 4 Mar 2019

The Free Software Foundation Europe (FSFE) would like to thank the European Commission for asking for public feedback. Since 2011, the FSFE has been working to protect and enhance freedoms of technology users in Europe. Therefore, we are pleased to provide our expertise for the matter of Article…

Consultation response

Karlsruher Institut für Technologie, 4 Mar 2019

As researchers in the field of ubiquitous computing and IoT we have been relying on the ability to change the fireware of off the shelf radio devices. Eg. the FP7 research project COBIS, which pioneered the IoT aproach, we were already using wifi routers which were extended with custom radios. This…

Consultation response

EUROSMART, 4 Mar 2019

Eurosmart, the voice of the digital security industry supports the political commitment in strengthening reliability of radio equipment placed on the Market. The growing number of internet-connected radio-equipment and more precisely IoT devices, constitute a challenge to ensure both safety and…

Consultation response

Mobile & Wireless Forum (Mobile Manufacturers Forum), 4 Mar 2019

Comments on the Inception Impact Assessment on “Upload of Software on Radio Equipment” The MWF and its members appreciate the opportunity to submit comments on the inception impact assessment regarding “Reconfigurable Radio Systems / Upload of Software on Radio Equipment”; please find our…

Consultation response

Technische Universitaet Berlin, 4 Mar 2019

I am voicing my strong disagreement with the proposed barrier mechanisms in Article 3(3)(i). The ability to freely customize the firmware or the operating system on commercial radio equipment is a very important facilitator for systems-related research in a number of domains like wireless…

Consultation response

Alexander von Humboldt Institut für Internet und Gesellschaft, 3 Mar 2019

To whom it may concern, I am a member of the Commission's Expert Group on Reconfigurable Radio Systems as the representative of the Alexander von Humboldt Institute for Internet and Society (HIIG, https://www.hiig.de) in Berlin, Germany (member type C - Organisation: Academia, Research Institute…

Consultation response

Stichting Vrijschrift, 4 Mar 2019

Options 0 or 1 would be the preferred options. Suppliers cannot envisage all possible combinations of hardware and software. Especially not what combinations of open source firmware and their hardware could do. Option 2 through 4 would contravene recital 19 of the RED and would negatively impact a…

Consultation response

Tanaza S.p.A., 4 Mar 2019

We strongly advise against blocking the possibility to load new and third-party software (including firmware) on hardware devices manufactured by any vendor. That would have serious implications from multiple stand-points: 1) innovation: large companies building hw/sw do not have all…

Consultation response

IARU - International Amateur Radio Union Region 1, 4 Mar 2019

This delegated act under Article 3(3) of the RED seeks to require that radio equipment supports certain features in order to ensure that software can only be loaded into the radio equipment where the compliance of the combination of the radio equipment and software has been demonstrated, and this…

Consultation response

, 4 Mar 2019

Die in der Direktive erwogenen Wege, den Upload von Software einzuschränken, gefährden den Erfolg der von der EU Kommission bereits geforderten notwendigen Strategien zur Nutzungsdauerverlängerung und Repararierbarkeit von Konsumgütern. Höhere Sicherheitsanforderungen im Internet der Dinge dürfen…