Europeans for Safe Connections
ESC
(1) To constitute a powerful alliance of organizations in Europe that will work together in order to obtain better regulation and a general understanding and acceptance in society that EMFs1 (from now on called EMFs) have adverse effects on life and the environment.
ID: 424431650962-92
Lobbying Activity
Response to Report on the review of the Digital Decade Policy Programme
8 Jan 2026
We, Europeans for Safe Connections, welcome the opportunity to participate in the consultation on the Digital Decade programme. However, we consider it essential that the digitalisation of public services be approached prudently, and with due regard to fundamental rights and public health. Non-discrimination There is no legal obligation for citizens to have internet access or to own internet-connected devices. The digitalisation of public administration must therefore not lead to the indirect exclusion of parts of the population. It is essential to preserve fully functional offline public services that ensure equal access and prevent discrimination. Service availability Offline public services must be maintained in the event of wireless network failures, power outages, or extreme weather conditions. It is essential to ensure that public authorities, healthcare / transport / banking services and cash payments and access to food remain available without requiring digital verification by citizens. Wired connections using optical or metallic conductors are significantly more energy-efficient and provide greater resilience and reliability than wireless systems. Automated data processing Under Article 22 of the GDPR, citizens have the right to be informed about the processing of their personal data, including automated processing. Citizens should have the right to refuse automated processing of their personal data. They should also have the right to refuse the use of their data for the training of algorithms. Specifically, given the concerns of governments related to the international safety of Eu, resilient. Automated data processing and AI training should therefore be based on explicit opt-in models. This is particularly relevant in the context of the rapid development of foundational AI models and the stated EU objective of strengthening digital and technological sovereignty. Data security Users of public digital services should be clearly and comprehensibly informed about the risks associated with the wireless transmission of sensitive data. They should be informed about the availability of safer alternatives - wired connections. Health In practice, the digitalisation of public services is implemented through mobile applications, which leads to the expansion of wireless technologies and infrastructure. This also results in increased exposure of the population to radiofrequency electromagnetic fields (RF EMF). Users of public digital services should be informed about the risks associated with the wireless connection and should have the option to use alternative solutions with less exposure. At the international level, the Budapest Declaration [1] adopted a commitment to pay increased attention to RF EMF and their combined effects together with other environmental and health stressors. This principle is also relevant for EU digital policies to ensure that digital transformation proceeds in line with the precautionary principle. [1] iris.who.int/server/api/core/bitstreams/781a703d-e062-4eba-b11c-a224a7861abf/content Monitoring We propose that the Digital Decade monitoring framework be expanded to include: The impact of wireless data transmission on personal data protection, including differences between technologies and protocols; The impact of long-term RF EMF exposure on public health and the environment; The percentage of public buildings providing standardized wired access for citizens; Ambient RF EMF exposure levels in urban "digital hubs" as an environmental health metric. Alignment with post-2026 funding We recommend that the European Competitiveness Fund and National and Regional Partnership Plans prioritise funding for high-speed wired infrastructure over further wireless densification, particularly where sufficient connectivity already exists. Best regards Europeans for Safe Connections This feedback was sent from a wired internet connection No use of harmful radiation Less electricity consumption Increased data security
Read full responseResponse to Digital Fairness Act
17 Sept 2025
We Europeans for Safe Connections welcome the intention to curb unethical digital practices and protect vulnerable consumers. At the same time, we stress the importance of ensuring that such measures do not undermine fundamental rights, particularly the right to privacy and the freedom to use end-to-end encrypted communications. The regulation must not lead to disproportionate surveillance or mandatory data accessibility for authorities. A revision bill is being prepared by Denmark at the moment for the long awaited CSA Regulation, which may circumvent this legislation by allowing scanning of end-to-end encrypted messages, not only of pictures but in the long run also of text. The intention is to protect children but the measures are not in alignment with the objectives. We can in no way endorse this part of the proposal and we urge the EC to uphold basic human privacy rights. We also call for increased transparency from digital service providers and device manufacturers regarding default settings, data collection practices and the ability of users to retain real control over their digital environment including the right to opt out of manipulative interfaces and data tracking. Only by respecting these boundaries can digital fairness truly be achieved. We have these suggestions: 1) Online platforms shall not be accessible for children via free internet, e.g. Wifi4EU. Children using internet platforms must always be supervised to some degree. At home parents are responsible, at school teachers are responsible, parents are responsible for (not) buying mobile data. The specification of Wifi4EU is: no-password, charge-free, unlimited and children know that and take the opportunity to use it. 2) Online platforms should contain warnings using similar systems to the ones on cigarettes. E.g. "You should prefer real people over our platform" or "You should use our platform via cable rather than wirelessly". Moreover the platform should provide a counter on a visible place informing about the time already spent on that platform and a CO2 footprint. 3) Platforms should minimise data collection. Children must not be monetised by data collectors without the informed consent of parents or legal guardians. All informed consents must be facilitated. The child and guardian must be able to easily understand the data collection and be able to very easily set up an opt-out. 4) Platforms should not be allowed to process automatically the data of children below 18 years old. An artificial intelligence shall not process the data of children below 18 years, and people above 18 should give an explicit agreement (opt-in) to process their data automatically or by AI. The functionality of the system must not be conditional on consent. 5) Platforms aimed at children should be transformed into ethical platforms that do not display unhealthy attitudes, unhealthy behaviour, violent or otherwise inappropriate content and should not manipulate the identity of the child. 6) Regarding educational platforms, the rules must be even more strict. We welcome very much the 2023 Global Education Monitoring Report of UNESCO (https://gem-report-2023) and we would like to refer to PDF page 183: In Denmark, a data protection impact assessment conducted by the Elsinore municipality in relation to Google Workspace for Education and Chromebooks led to banning their use in schools. Frances Ministry of Education and Youth has banned free versions of Microsoft Office 365 and Google Workspace in schools. In Germany, Microsoft products have been banned in the states of Baden-Württemberg and Hessen because they do not comply with the GDPR. The Dutch Data Protection Authority proposed to ban Chromebooks and Google Workspace for Education from schools until August 2023 because of non-compliance with childrens data protection and privacy regulations. Best regards Europeans for Safe Connections
Read full responseResponse to Targeted revision of the EU rules for medical devices and in vitro diagnostics
16 Sept 2025
Europeans for Safe Connections (ESC) fully concurs with the stated objective of Regulation (EU) 2017/745 on medical devices (MDR) and Regulation (EU) 2017/746 on in vitro diagnostic medical devices (IVDR), which is "to establish a robust, transparent, predictable and sustainable regulatory framework for medical devices which ensures a high level of safety and health whilst supporting innovation". ESC places paramount importance on ensuring a high level of safety and health for all patients, with particular emphasis on individuals affected by electromagnetic hypersensitivity (EHS). We strongly believe that electromagnetic fields (EMFs) emitted by medical and hospital structures, as well as by medical devices, can constitute significant barriers to accessibility for EHS individuals. This concern underscores our commitment to patient safety and equitable access to healthcare. EHS is a condition where individuals experience adverse health effects from exposure to electric, magnetic, or electromagnetic fields, with symptoms often occurring at levels well below international safety guidelines. Hospital environments, with their multiple sources of EMFs, pose a considerable challenge for these patients. In line with the Treaty on the Functioning of the European Union, specifically Article 168(4), point (c), a high level of human health protection must be ensured in the definition and implementation of all Union policies and activities. This includes adopting measures that set high standards of quality and safety for medicinal products and devices for medical use. ESC has actively engaged in the consultation process. We previously submitted a comprehensive dossier, in December 2024 and again in March 2025, detailing our considerations and proposals regarding the health implications of artificial electromagnetic fields, our specific requests for technical specifications, and our perspective on the recognition of experts within the EU HTA joint activities. Furthermore, on December 21, 2024, we forwarded a proposal to Mr. Marco Marchetti, Co-Chair of the Medical Device Coordination Group (HTACG), suggesting amendments to the medical devices template to specifically address all wireless connections incorporated within these devices. ESC has also affirmed its readiness to propose qualified, conflict-of-interest-free experts on the health hazards associated with electromagnetic fields to the HTA Stakeholder Network.
Read full responseResponse to EU cardiovascular health plan
15 Sept 2025
The EU cardiovascular health plan aims to improve public health at individual and societal levels, contributing to a reduction in the number of people falling ill with cardiovascular diseases and preventing premature deaths. This objective is pursued by addressing known risk factors such as obesity, high blood pressure, and other related comorbidities. However, E.S.C. suggest that, within a broader context of biological mechanisms, it is crucial to integrate exposure to electromagnetic fields (EMFs), particularly radiofrequency electromagnetic fields (RF-EMF), as an additional significant risk factor for cardiovascular health. Here is how to highlight the necessity of adding EMF exposure to the risk factors in the EU cardiovascular health plan: 1. Recognize EMFs as Emerging Environmental Risk Factors Modern technologies have led to a significant increase in artificial EMF sources, resulting in permanent exposure of people and the environment to "electromagnetic pollution". Although current safety standards primarily focus on thermal effects, there is growing evidence of harmful non-thermal effects at exposure levels well below current limits. This ubiquity and the often involuntary nature of exposure make EMFs a public health concern that needs to be included in the assessment of cardiovascular disease risks. 2. Scientific Evidence of the Link Between EMFs and Cardiovascular Health The sources indicate several mechanisms and studies linking EMFs to cardiovascular problems: Oxidative Stress: Numerous studies have identified an increase in the production of reactive oxygen species (ROS) and oxidative stress as a key mechanism through which EMFs, particularly RF-EMF, influence cellular physiology. Oxidative stress is a well-known factor contributing to cardiovascular diseases. Some studies have even suggested that EMF exposure during spermatogenesis induces an increase in ROS production. Dysfunction of Voltage-Gated Ion Channels (VGCC): It has been proposed that EMFs, including RF-EMF, can cause dysfunction of voltage-gated ion channels, altering the electrochemical balance of cells. Excessive intracellular calcium influx, induced by EMFs, can trigger ROS production. This mechanism has been linked to conditions like Alzheimer's disease and could also have implications for the cardiovascular system. Direct Effects on the Heart and Circulatory System: Studies have shown that exposure to RF-EMF can influence heart rate variability (HRV), an important indicator of cardiovascular health and autonomic balance. A reduction in the β-adrenergic response of ventricular myocytes and an increase in nitric oxide levels in the heart have been observed after EMF exposure. Some research has found myocardial damage induced by microwave radiation, including thermal and non-thermal effects. Earlier studies reported changes in frog heart rhythm, a reduction in blood pressure in exposed animals, and an increase in red blood cell count. An analysis of UK Biobank participants suggested a significantly higher risk of new-onset hypertension in mobile phone users with longer weekly call times. There are also concerns regarding electromagnetic interference with implantable cardiac devices (CIEDs), such as pacemakers and defibrillators, by electronic devices, including smartphones with magnetic charging capabilities. Impact on Stress and Systemic Inflammation: EMF exposure can induce chronic stress and various psychiatric disorders by affecting HRV indices. Inflammation and oxidative stress have been observed in patients with electromagnetic hypersensitivity (EHS), conditions that can be related to cardiovascular problems. 3. Integration into the EU Cardiovascular Health Plan To highlight the need to include EMF exposure as a risk factor in the EU plan, the following points could be considered: Review and Expansion of Risk Factors: The plan should explicitly include EMF exposure among the "risk factors" for car
Read full responseResponse to Digital Networks Act
18 Jun 2025
Digital Networks Act aims to help boost secure high-speed broadband, both fixed and wireless. We "Europeans for Safe Connections" we welcome the emphasis on fixed broadband infrastructure. However, we feel compelled to provide constructive feedback on the health implications of wireless connectivity. Suggestion no. 1: Prioritize cabled connections. Suggestion no. 2: Replace wireless connections with cables immediately in places such as hospitals, kindergartens, schools, retirement homes, all public buildings. Suggestion no. 3: Advise member states to provide low/no radiation zones in municipalities. Declare all nature reserves and parks low/no radiation zones. Suggestion no.4: Require a comprehensive health impact assessment before auctioning new frequency bands (microwave, millimeter waves). Suggestion no.5: We urge that the current proposal be revised to move beyond a narrow focus on technological modernization and industrial gain. It must address the broader implications for public health, the environment, and civil liberties. Higher standards for security, accountability, and citizen protection must be established before implementing technologies with such far-reaching impact. Best regards Europeans for Safe Connections This feedback was sent from a wired internet connection No use of harmful radiation Less electricity consumption Increased data security
Read full response3 Jun 2025
The proposed REGULATION (EU) and its ANNEXES do not specify technical requirements for data transmission from medical devices to IT infrastructure, such as mandating Wi-Fi or other particular communication protocols. Nevertheless, this framework necessitates that information concerning the characteristics and usage of medical devices, including those with connectivity features, be integral to the assessment process. Key aspects of this process include: Dossier Submission by Health Technology Developers (HTDs): HTDs are required to submit comprehensive dossiers. Assessment Scope Development: The scope of the health technology assessment (HTA) is defined. Joint Clinical Assessment Report: This report details the medical device's characteristics, reflecting the information provided in the dossier. It specifically includes a "description of the connected technology" and details on AI/machine learning features, where applicable. Consultation with Experts and Stakeholders: Stakeholder groups, such as patient organizations (e.g., E.S.C.), should be afforded the opportunity to provide input on the medical device, particularly to evaluate health considerations related to its wireless connectivity. E.S.C. provided the HTA with a list of technical specifications in December 2024 and March 2025 for measuring and evaluating non-ionizing radiation (NIR), encompassing both extremely low frequency (ELF) waves and radiofrequencies. Regarding the identification of patient experts for joint working meetings, ESC has confirmed its capacity to nominate scientific experts (e.g., medical doctors, biochemists) qualified to assess the risks of electromagnetic field (EMF) exposure from new devices for: a) The general population b) Electrohypersensitive (EHS) individuals. In summary, while the documents currently under public consultation lack specific guidelines on the use of wireless connectivity, they establish a process within the EU HTA framework where information on connected technology in medical devices is explicitly required and systematically assessed. The strategy for addressing device connectivity within this framework involves the submission of detailed information in the dossier, engagement with experts and stakeholders during consultations, and the potential use of the Joint Scientific Consultation (JSC) mechanism for guidance on evidence generation.
Read full responseResponse to Updated test procedures for eCall
9 Apr 2025
We "Europeans for Safe Connections" suggest to add more changes to this amending regulation: 1) For personal vehicles / private cars, this system must be voluntary and the manufacturer must off er a variant of the vehicle withoutinstalled wireless technologies. However, if the user opts for such an additional feature, the option should be provided for an additionalshutdown / disassembly to cancel the exposure. 2) For all vehicles (private, public, trucks...), the driver and the passengers must be informed about the radiation. 3) The eCall system (IDS) must be located so that it is as far as possible from the interior of the vehicle to irradiate less. Maybe move theexposure out of the vehicle always via external antennas. The reason why Europeans for Safe Connection proposes the above addition is, that some people are more vulnerable toEMFs then average. These people may become ill due to an overdose of EMFs, even when the exposure is below the legalyaccepted limits. EMFs may also have an impact on the brainfunction, which may have an influence on driving skills. One ofthe effects mentioned by EHS people is brain fog. We see various scientific reports that show an impact of EMFs on thehuman brain and bloodcirculation. As safe traffic is dependant on the health of each driver, the impact of EMFs on EMFsensitive people/drivers must also be taken into consideration with the rules. Although there are multiple studies on impact of EMFs on the brain and blood circulation, we mention two recent reports: Johan van der Meer et all; Effects of mobile phone electromagnetic fields on brain waves in healthy volunteers . Brown and Biebrich; Hypothesis: ultrasonography can document dynamic in vivo rouleaux formation due to mobile phone exposure. Kind Regards, Rob van der Boom C hair of Europeans for Safe Connections esc-info.eu This email
Read full responseResponse to Digitalisation of travel documents and facilitation of travel
6 Jan 2025
We "Europeans for Safe Connections" think that this draft regulation appears comprehensive, however, some potential weaknesses and risks could impact its implementation, effectiveness, and compliance. Heres a breakdown of possible concerns: - While Article 7 states that personal data should not be stored beyond necessity, specifics on retention periods and processes for removing data upon consent revocation are limited. These should be clarified to align with GDPR principles, ensuring data is not held indefinitely. Although Article 7(4) specifies that data should not be stored on the backend validation service or Traveller Router beyond necessity, the vague language might leave room for misinterpretation. Clear guidelines on storage, including maximum duration and specific circumstances for data retention, could help mitigate risks of over-retention. - Article 7(5) allows users to revoke their consent to process their data, but the operational implications are unclear. For instance, it does not specify what happens if a user revokes consent mid-travel. This could disrupt border control processes if systems cannot handle real-time data changes. - We suggest to add the following point 3 into the Article 1: "Physical paper documents will continue to co-exist and can not be discriminated in any way." This regulation should take into account largely negative opinions submitted in the public consultation. Moreover, this regulation assumes that biometric verification systems will work smoothly, yet technical issues are likely to occur. The absence of contingency plans for handling system failures (e.g., if a facial recognition system fails or is down) could lead to delays, particularly at borders. Moreover in the present situation with problematic energy supply it is vital to maintain the use of physical documents. In a situation where energy supplies fail and digital solutions cannot be accessed, serious life-threatening situations can arise. It is crucial that physical / analogue documents stay in the system parallel to digital ones. Digital systems are not error-free and cannot be relied on 100%. Sometimes its the citizen's fault, sometimes its the system's fault. - This regulation relies on mobile technology, potentially creating barriers for individuals with limited digital access or proficiency. There is no mention of accessibility standards (e.g., for people with disabilities), which may be required to meet EU inclusivity standards. - We suggest to add the following sentence into the Article 10, Information campaign: "Border checks and scanners will be visibly labelled with a sign that radiofrequency electromagnetic fields are present." This means that a citizen will not be exposed to radiation from a device or infrastructure for wireless scanning of digital documents until informed of the type of radiation and given the option of having the documents scanned in another way: - further from citizen's body - with the cabled scanner - use of physical documents Among the EU's values is that minorities are respected. Electro Sensitive people are a minority and the EU should respect their wish not to be exposed to RF EMF. This includes radio frequency scanners, but also transport without Wi-Fi services. Read more here https://signstop5g.eu/en/solutions/protection-of-all-life-on-earth/proposal-9 Best regards Europeans for Safe Connections This feedback was sent from a wired internet connection - No use of harmful radiation - Less electricity consumption - Increased data security
Read full response26 Nov 2024
We "Europeans for Safe Connections" think that the proposal lacks detailed criteria for selecting individual experts and stakeholders. It also does not manage potential conflicts of interest robustly. The mechanisms for ensuring unbiased and diverse expert opinions must be specified. Article 6(1): Transparency and conflict of interest. This article states that the representatives appointed to the Coordination Group and its subgroups, as well as patients, clinicians, and other relevant experts participating in any joint work, must not have financial or other interests in the industrial sector of health technology developers which could affect their independence or impartiality. This article could be amended to explicitly include the absence of conflicts of interest in relation to technologies and electromagnetic fields. Article 8(6): Initiation of joint clinical assessments. This article defines the scope of assessment for joint clinical assessments, specifying the parameters to be considered. This article could be amended to include among the parameters the assessment of the impact of electromagnetic fields (EMFs) emitted by the device on people's health, with particular attention to EHS. Article 9(4): Documentation for joint clinical assessments. This article lists the information to be included in the documentation for medical devices and in vitro diagnostic medical devices. This article could be amended to explicitly require manufacturers to include detailed information on EMFs emitted by the device, on measurement methods, and on potential health effects. Article 16(2): Principles of joint scientific consultations. This article defines the eligibility criteria for joint scientific consultations. This article could be amended to include among the criteria the potential impact of the device on the health of people with EHS, ensuring that such technologies are subject to in-depth scientific consultations. Annex II: Information to be included in the documentation for medical devices. This annex lists the information to be included in the documentation for medical devices. This annex could be amended to add a specific point dedicated to assessing the impact of EMFs on health, including measurement methods, emission levels and potential consequences for people with EHS. Best regards
Read full responseResponse to Protection of Minors Guidelines
25 Sept 2024
We, "Europeans for Safe Connections" (ESC), welcome the online protection of children. We have the following suggestions: 1) Online platforms shall not be accessible for children via free internet, e.g. Wifi4EU. Children using internet platforms must always be supervised to some degree. At home parents are responsible, at school teachers are responsible, parents are responsible for (not) buying mobile data. The specification of Wifi4EU is: no-password, charge-free, unlimited and children know that and will take the opportunity to use it. 2) Online platforms should contain warnings using similar systems to the ones on cigarettes. E.g. "You should prefer real people over our platform" or "You should use our platform via cable rather than wirelessly". Moreover the platform should provide a counter on a visible place informing about the time already spent on that platform and a CO2 footprint. 3) Platforms should minimise data collection. Children must not be monetised by data collectors without the informed consent of parents or legal guardians. All informed consents must be facilitated. The child and guardian must be able to easily understand the data collection and be able to very easily set up an opt-out. 4) Platforms should not be allowed to process automatically the data of children below 18 years old. An artificial intelligence shall not process the data of children below 18 years, and people above 18 should give an explicit agreement (opt-in) to process their data automatically or by AI. The functionality of the system must not be conditional on consent. 5) Platforms aimed at children should be transformed into ethical platforms that do not display unhealthy attitudes, unhealthy behaviour, violent or otherwise inappropriate content and should not manipulate the identity of the child. 6) Regarding educational platforms, the rules must be even more strict. Best regards Europeans for Safe Connections This feedback was sent from a wired internet connection No use of harmful radiation Less electricity consumption Increased data security
Read full responseResponse to Interim Evaluation of Digital Europe
22 Aug 2024
We, "Europeans for Safe Connections" (ESC), would like to comment on six key capacity areas. To the question "Are the programme's objectives and activities relevant to current and future challenges and needs?" we answer "they are relevant BUT these objectives are not enough there should also be other objectives". 1) High-performance computing We think that besides high-performance computing there should also be low-energy computing. 2) Artificial intelligence We think that deploying trustworthy artificial intelligence is a very responsible task and there should be institutions for regulation and citizens' protection. 3) Cybersecurity and trust We think that cybersecurity and trust is very relevant and therefore we advocate for decentralisation and the right to analogue solutions. 4) Advanced digital skills We think that advanced digital skills are important, but the following should be taken into consideration: Advanced digital skills must be taught in higher education. However, we want to raise a warning not to let this spill over into lower-level schooling, leading to constantly increasing demands based on university-level criteria. 5) Adoption and best use of key digital technologies In this context you must not forget the implementation of cabled connections. 6) Semiconductors Care must be taken not to explore landscapes and nature for mining purposes to a degree where we end up with a Europe reduced to a moon landscape. And we must not exploit 3rd world countries in the same manner. We must maintain high ethical standards and let nature preservation come before nature exploitation. Best regards Europeans for Safe Connections This feedback was sent from a wired internet connection No use of harmful radiation Less electricity consumption Increased data security
Read full responseResponse to Environmental Implementation Review 2025
4 Jul 2024
We, "Europeans for Safe Connections", would like to draw your attention to electromagnetic fields (EMFs) and therefore we have these comments to the areas addressed in the EIR: CIRCULAR ECONOMY AND WASTE MANAGEMENT Every smartphone includes 1000+ substances each with its own energy-intensive, toxic waste-emitting supply chain that is a threat to the environment. The OECD predicts that global use of primary materials will double by 2060, further exacerbating water pollution, water resource depletion, habitat destruction, deforestation and drought. BIODIVERSITY AND NATURAL CAPITAL The increase in electromagnetic pollution, particularly from the use of wireless communication technologies, poses a potential threat to biodiversity. ZERO POLLUTION The advice of the European Environment Agency in the report 'Late lessons from early warnings' is ignored. The Polluter pays principle should also be applied to this type of pollutant.It should be also emphasised that no impact assessment report has yet been produced on the effects of RF EMF on animal and plant species, biodiversity and ecosystems. CLIMATE ACTION Wireless technologies have negative impacts on climate change and energy consumption.The pursuit of economic growth and profit by industrial companies or other entities should not prevail over the primary need to protect the environment, sustainable management of natural resources and the right to health. Without a dedicated policy to limit these environmental impacts, the Green Deal will not be made a reality. Best regards Europeans for Safe Connections This feedback was sent from a wired internet connection No use of harmful radiation Less electricity consumption Increased data security
Read full responseResponse to How to master Europe’s digital infrastructure needs?
25 Jun 2024
We, "Europeans for Safe Connections", are very concerned with this paper. The introduction of the White Paper -How to master Europe's digital infrastructure needs? clearly shows many advantages that are expected from the digital developments. However, in a proper policy document the negative side of developments need to be addressed as well, to achieve the results wanted. Only security threats are called for. We dearly miss a view on the side effects of digitalization. Please find our full feedback attached. Best regards Europeans for Safe Connections This feedback was sent from a wired internet connection No use of harmful radiation Less electricity consumption Increased data security
Read full response24 Jun 2024
We, "Europeans for Safe Connections", fully support managing conflicts of interest within the joint work of the Member State Coordination Group on Health Technology Assessment. We believe that not only new health technologies should be assessed but also existing health technologies should be assessed based on new data evidence. For example there is a new Dr. Panagopoulos study related to gamma radiation treatment. He discovered that mobile telephony electromagnetic fields significantly enhanced the genotoxic action of gamma radiation thus people should be aware of the increased risk during treatment periods. https://esc-info.eu/wp-content/uploads/2024/06/Panagopoulos-MobphoneandgammaradiationHPBLs-2024.pdf Furthermore, we highlight the global implementation of fifth-generation (5G) radiofrequency (RF) radiation without adequate investigation into its potential risks to human health and the environment. This situation has sparked debates among concerned individuals across various countries. In September 2017, an appeal was made to the European Union (EU) by over 390 scientists and medical doctors. They requested a moratorium on 5G deployment until thorough scientific evaluations of potential negative consequences could be conducted. However, recent publications from the International Commission on Non-Ionizing Radiation Protection (ICNIRP), which is tied to EU and government expert groups, have raised concerns. Conflicts of interest and industry affiliations may have influenced biased reports. The lack of unbiased risk assessment for 5G technology poses risks to populations. Additionally, there appears to be a group monopolizing evaluation committees, reinforcing a no-risk paradigm. We believe that such behavior qualifies as scientific misconduct, as it impacts peoples lives. We quote the European Parliamentary Research Service document:"Various studies suggest that 5G would affect the health of humans, plants, animals, insects, and microbes and as 5G is an untested technology, a cautious approach would be prudent. Hundreds of recent scientific studies, including peer-reviewed research, and even rigorously peer-reviewed research demonstrating serious long-term adverse effects on human health from recent and earlier generations of wireless technologies. Therefore we suggest to appoint new ethics committee or expand EGE's activities (EGE - The European Group on Ethics in Science and New Technologies, whose role is defined by Article 2 of Commission Decision 2016/835). We call for the creation of a body that brings together scientists and representatives of different schools of thought, elected in complete independence from business circles and governments. This body would be responsible for creating the conditions for a public debate before any major technology is introduced, and for preparing decisions to be validated by referendum. Read more: https://signstop5g.eu/en/solutions/protection-of-our-data/proposal-23 At the same time, the public is not told that hundreds of independent scientific studies, including peer-reviewed research, and even rigorously peer-reviewed research, demonstrate serious long-term effects on human health from new and earlier generations of wireless technologies on, for example, fertility, the nervous system, the cardiovascular system, and cellular processes. The UN Universal Declaration of Human Rights, the Helsinki Accords and other international treaties recognise that informed consent prior to interventions that might affect human health is an essential, fundamental human right, which becomes even more controversial when considering children's and young people's exposure quoting a statement from a European Parliamentary Research Service document (Effects of 5G wireless communication on human health). Best regards Europeans for Safe Connections This feedback was sent from a wired internet connection No use of harmful radiation Less electricity consumption Increased data securit
Read full responseResponse to Commission Implementing Regulation amending Regulation (EU) 2020/1070 on small cells
9 Jun 2024
We, "Europeans for Safe Connections", have these comments to this amendment: we welcome that in Article 1, the second paragraph is deleted. This means that the regulation will also apply to small-area wireless access points with an active antenna system from now on. we do not care about prolonging deadlines for operators, we think that EU should think more about the health of people Article 4 is only about monitoring We see that in the Annex there are only grammar changes plus one sentence at the end added: "In the case of co-located deployment of antenna systems, or portions thereof, evidence of the compliance of the aggregate EIRP can be submitted jointly by the deploying entities, unless otherwise provided by national law." We agree to this. We have to say that we are deeply concerned with the whole REGULATION (EU) 2020/1070. We draw your attention to the Article 1, para 3, point (a): "...any portion thereof in excess of 30 litres shall be invisible to the general public." and to the original REGULATION (EU) 2020/1070 , article 3, point 1a, which stays unchanged:"be fully and safely integrated in their supporting structure and therefore invisible to the general public" and to the original REGULATION (EU) 2020/1070 , point (8) ...requires that the lowest radiating part of the antenna of a Class E10 has a height of at least 2,2 metres above the general public walkway to ensure a distance of at least 20 cm between the main antenna lobe and the human body of a 2 m tall person This is unacceptable for us. By hiding small area wireless access points from public view, the European Commission may aim to reduce public health concerns arising from an explosion in the number of new transmitters. But this is unacceptable! This action can be interpreted as an action against transparency and against the right to informed consent of the citizen or against the right to health protection. Citizen have the right to know about wireless equipment and the radiation to which they are exposed, since we know that neither governments nor insurance companies will insure or be legally responsible for any harm to the public's health caused by exposure to RF EMF. Also a study funded by European Parliament confirms these risks. For devices of class E2 and E10, we are talking about powers of approximately 2 W and 10 W. Such devices have radiated power emissions that can have an adverse effect on health and should be clearly marked with warning labels indicating a safe distance from the device. Moreover, there is the risk of reduced property values due to the presence of small base stations nearby. It's also worth noting that the Regulatory Scrutiny Board, which was tasked with reviewing the impact of the GIA proposal, found a number of flaws and there was no assessment of the environmental impacts or the human health impacts of 5G deployment. The revised version of the impact assessment acknowledges that "... we did not seek to quantify the deployment-related impacts of different options for mobile networks..." and acknowledges that "the literature on the environmental impacts of 5G deployment is limited as it is an area that is still subject of research." Also European Parliamentary Research Service documents state that "Various studies suggest that 5G would affect the health of humans, plants, animals, insects, and microbes and as 5G is an untested technology, a cautious approach would be prudent. The UN Universal Declaration of Human Rights, the Helsinki Accords and other international treaties recognise that informed consent prior to interventions that might affect human health is an essential, fundamental human right, which becomes even more controversial when considering children's and young people's exposure." Please read more in our article signstop5g.eu/en/solutions/5g-in-depth-analysis-for-itre-committee Best regards Europeans for Safe Connections
Read full response24 Mar 2024
We, "Europeans for Safe Connections", welcome this initiative Here it's enclosed our feedback Best regards Europeans for Safe Connections This feedback was sent from a wired internet connection No use of harmful radiation Less electricity consumption Increased data security
Read full responseResponse to Type-approval templates for certain motor vehicle safety systems
14 Mar 2024
We, "Europeans for Safe Connections", understand that this initiative provides document templates that are undoubtedly thorough and are outlining detailed specifications for each vehicle safety system. Our feedback is not technical but we express concerns about potential wireless connections inherent in the specified vehicle safety systems. Vehicle safety cannot be when it has impact on health. Inclusion of EHS people is required by UN Convention. The integration of intelligent systems raises apprehensions about increased exposure to radiofrequency radiation which poses an increased health risk. While prioritizing safety is paramount, we advocate for thorough assessment and transparent communication regarding the implications of wireless connectivity and data collection in vehicle safety systems. Please find our detailed explanation in the attached PDF file. Best regards Europeans for Safe Connections This feedback was sent from a wired internet connection No use of harmful radiation Less electricity consumption Increased data security
Read full responseResponse to Evaluation of the National Emission reduction Commitments Directive
14 Mar 2024
We, "Europeans for Safe Connections", understand that this initiative evaluates five air pollutants. We would like to provide our comment according to standard evaluation criteria (relevance) and we are offering our perspective for future consideration: In light of developments and technical and scientific progress we would like to point out that the Directives scope in terms of the coverage of pollutants, their sources and their impact on ecosystems should be updated. We propose future broadening the scope to encompass a pollutant of significant concern - radiofrequency electromagnetic fields (RF EMF) spreading wirelessly through the air. It is unacceptable that the EU does not classify RF EMF as a pollutant, while scientists and insurance companies do. Please find our detailed explanation in the attached PDF file. Best regards Europeans for Safe Connections This feedback was sent from a wired internet connection No use of harmful radiation Less electricity consumption Increased data security
Read full response28 Feb 2024
We, "Europeans for Safe Connections", appreciate the opportunity to contribute suggestions for improving the Safety Gate portal. We welcome that the European Union empowers consumers, as residents of Member States, to directly report any non-compliant products or items posing a risk to public health within their respective countries. Our experience so far are only problems with reporting these findings. E.g.: Europeans for Safe Connections and Phonegate Alert Team diligently brought the matter of 42 non-compliant phones to the attention of regulators across twelve European countries, urging them to register evidence such as measurement reports and specifications for each phone type. We have received various types of responses from non-French regulators, but ultimately there has been no registration of non-compliant products. >>> https://signstop5g.eu/en/news/info-request-regarding-sar Our gratitude belongs to Ms. Mazurek, a Polish MEP, who posed a parliamentary question to the Commission. Commissioner Mr. Bretton responded to this discrepancy: "...mobile phones which do not comply with the Radio Equipment Directive (RED) shall not be placed on the EU market" and added "Notifying measures taken against dangerous products in European Rapid Alert system for dangerous products (RAPEX/Safety Gate system) is the responsibility of the market surveillance enforcement authorities which is, again, a competence of the Member States." >>> https://phonegatealert.org/en/european-commission-confirms-phonegate-alerts-call-to-withdraw-dangerous-cell-phones/ As of now, it appears that none of the regulators have registered any relevant information, as the initial obligation lay with the French ANFR as the discoverer of the defect. If the competent authorities in the state of discovery are unable to respond to a situation of non-compliance with the legislation for wireless products, we welcome, therefore, to allow non-compliant products to be reported to Safety Gate via the consumer. Best regards Europeans for Safe Connections This feedback was sent from a wired internet connection No use of harmful radiation Less electricity consumption Increased data security
Read full responseResponse to Report on the application of the General Data Protection Regulation
2 Feb 2024
Herein enclosed you'll find our feedback Best regards
Read full responseResponse to Reporting scheme for data centres in Europe
11 Jan 2024
The Europeans for Safe Connections (ESC) welcomes the European Commission's efforts to develop better regulation for environmental issues related to energy efficiency of datacentres. ESC have already highlighted the enormous electricity consumption and energy waste associated with digitalisation in its European citizens' initiative (Registration number: ECI(2021)000009) in Proposal 12. The rise of digitalisation brings familiar benefits, but also underreported risks. The number of Internet users is growing every year. The facts presented on the first page of the draft Regulation confirm the statements of researchers and the industry that the high energy consumption and large environmental footprint associated with information processing and storing will continue, in the form of linear growth in energy consumption and further increases in greenhouse gases or water consumption. A significant contribution to the huge energy consumption will be the demand for enormous computing power for artificial intelligence, cryptocurrency mining, autonomous vehicles, as well as the widespread rollout of 5G. The environmental footprint of the digital economy will peak with 5G traffic feeding data centres. We welcome activities that reduce environmental impact, but we believe that the problem at the data centre level is only a consequence, not a cause. The cause lies in the huge amount of data generated by some specific usage of the technology, which will have a significant impact on the environment and the management of natural resources. Our recommendations: Companies operating data centres or telecommunications infrastructure with an environmental impact should provide transparent data to the public on their management of energy, water and natural resources. If companies with data centre or telecommunications infrastructure harm the environment or human health, promote the polluter pays principle. The pursuit of economic growth and profit by telecom operators, industrial companies or other entities should not override the primary need to protect the environment, the sustainable management of natural resources and the right to health. The Commission should thoroughly assess all technologies before they are deployed, to ensure that they do not cause massive damage to the environment, natural resources, humankind, fauna, flora. Existing evidence suggests that ICTs are contributing to further burden on the environment or human health rather than solving it. The Commission should prioritise the communications technologies based on wired, cabled connections (to homes, businesses, data centres) as the most sustainable communications technology solution in terms of energy, maintenance and cost efficiency and and protects health because it does not create exposure to wireless radiation. Avoid blanket rollout of the next phase of 5G, as the form of high densification wireless base stations will have a significant negative impact on the environment. For the sake of protection of environment, limit the use of Artificial Intelligence, Autonomous Vehicles and the mining of cryptocurrencies. Support an approach based on energy-efficient and less costly technologies that combine well with renewable energy generation and are resilient to interruptions Promote consumer attitudes towards sober digital practices and the use of sustainable communication technology solutions. Offer a strategy to reduce obsolescence by extending the lifetime of consumer devices (including mobile phones) communicating with datacentres. Kamil Bartošák, Giorgio Cinciripini, Petra Bertová Europeans for Safe Connections
Read full responseResponse to Revision of the specifications for the harmonised provision for an interoperable EU-wide eCall
14 Oct 2023
Since the final aim of this regulation 305/2013 is upgrading public safety, and since it is found in scientific research that exposure to radiation influences responsiveness and quality of decisions, we Europeans for Safe Connections suggest to add more changes to this ammending regulation: 1) For personal vehicles / private cars, this system must be voluntary and the manufacturer must offer a variant of the vehicle without installed wireless technologies. However, if the user opts for such an additional feature, the option should be provided for an additional shutdown / disassembly to cancel the exposure. 2) For all vehicles (private, public, trucks), the driver and the passengers must be informed about the radiation. 3) The eCall system (IDS) must be located so that it is as far as possible from the interior of the vehicle to irradiate less. Explanation: Europeans for Safe Connections is an alliance of European organisations that strives to reduces the impact of modern communications and electricity use on health and the environment. We are not against technology, but we are pro safe technology and safe connections. The electromagnetic radiation emitted by wireless technologies poses an increased health risk, especially when these technologies are used inside enclosed metallic enclosures such as cars, busses, trains. Vehicles often contain different types of wireless technology and there is cumulative exposure to different sources of RF EMF. The metal walls and windows with metal particles create cascade effect of signal reflections but also present significant attenuation for downlink signals, causing the devices inside the vehicle to transmit at significantly higher power. Manufacturers should ensure that wireless technologies communicating with the external environment do not expose vehicle passengers unnecessarily. They should place antennas out of reach of passengers outside of the vehicle, they should also shield radiating components from occupants, and minimize exposure in terms of intensity and timeframe. Each passenger should be given informed consent to the fact that vehicle equipment such as sensors, adaptive systems, infotainment systems and communication systems often emit non-negligible radiation and the vehicle creates very specific conditions for exposure as was mentioned before. While additional protection is offered through eCall, this and other wireless measures should not be forced, but should be a matter of the persons free choice as to whether they wish to use it. At the same time, we feel a pressure to incorporate wireless functions into vehicles. Such impositions discriminate against persons with disabilities or persons who have health problems as a result of exposure to RF EMF. We assume that the promotion of the transition to packet switched networks will further increase the growth of wireless infrastructure and densification of the cellular network, which, while contributing to higher coverage of services, will not benefit the health, the environment and the cost of energy consumption and finance. Best regards
Read full responseResponse to Energy labelling requirements for electronic displays
31 Aug 2023
We "Europeans for Safe Connections" endorses that this initiative would help deliver on the European Green Deal with main goal to reduce consumer energy bills and improve the EUs security of supply by reducing primary energy consumption and decreasing energy imports The current regulations ecodesign and energy labelling have reduced the energy consumption of electronic displays. However, one issue was not identified that can hinder further efficiency gains: the wireless communication. The recent book The dark cloud (How the digital world is costing the earth) By Guillame Pitron (2022) describes how the online world is costing the earth and sets out to scrap the myth of the digitalisation of our plugged-in lifestyles and sheds light on the pollution caused by digital technology: "Digital natives will be the promoters of an increase in electricity consumption by the digital sector as early as 2025, thus accounting for 20 per cent of world production and 7.5 per cent of total greenhouse." The main environmental impacts for this wireless technology arise from use-phase energy consumption. Lower energy use will lower associated environmental impacts, consumer costs and energy supply industry turnover. Energy efficiency requirements will aim to achieve the lowest lifecycle consumer cost level, so cost savings will tend to offset product price rises. On this respect, ESC requires to update Ecodesign and energy labelling Program according to: 1) To enact stronger regulation to protect the environment from all the impacts of 5g and digitalization: this means to update Directive 2011/92/EU to include 5G deployment and all telecommunication as projects in Annex 1 to ensure that such projects are made subject to environmental assessment or a screening as prescribed by the directive; 2)To Reduce the massive electricity consumption caused by digital communication technology, e.g. by prioritizing wired solutions and low energy solutions in the action plan for the European Green Deal. According to Directive 2012/27/EU on energy efficiency, the Union places energy efficiency and the need for decoupling energy use from economic growth at the core of the Union energy strategy. But many devices breach this directive: - many Wi-Fi Routers, because the default transmit power level is set to maximum and they are used in several frequency ranges at the same time: 2.4 / 5 / 6 / 60GHz; - many wireless smart meters, because they needlessly consume energy by constantly monitoring devices and cause dirty electricity. Electrical/Phone and Fibre Cables can all be used to transfer smart meter data; - energy consumption forecast for Information and Communication Technology (ICT) devices and services: smartphones, computers, data centers, antennas, internet, etc.; 3) To Include "Waste from Electrical and Electronical Equipment" (WEEE), other waste products, and the environmental impacts of mining for rare earth minerals and metals used in electronical equipment in the Zero pollution action plan; 4) To Update Ecodesign Directive from 2009 setting tight limits to resource and energy waste of all connected devices including antennas and satellites. Europeans for Safe Connections (ESC) is a umbrella NGO (Transparency Register is: 424431650962-92) born as alliance of organizations in Europe that will work together in order to obtain better regulation and a general understanding and acceptance in society that Electromagnetic Fields have adverse effects on life and the environment.
Read full response