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

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 was only possible by using extensible after market firmware. In other projects e.g.

The OpenWrt project provides a Linux based open source firmware for embedded devices like home routers, customer premises equipment and IoT devices with a focus on security and freedom for the end user. The OpenWrt project tries to enforce the local regulatory restrictions based on the vendor provisioned data found on the device.

We are a small company developing and manufacturing industrial sensors. Our products focus on innovative network applications. We enjoy the fortunate situation of being based in a city with a university, a makerspace and a vibrant wireless community ("Freifunk"). The university is useful for giving our potential future employees a good formal basic education.

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 flourishing ecosystem of inventors, makers and SMEs as well as local wireless networks.

Electronic Frontier Norway (https://efn.no) is a a Norwegian digital rights NGO We believe the right to change software in general has been and still is one of the major driving forces behind the value creation in today’s economy. On a daily basis we see this mechanism at work both in commercial telecommunications settings, in amateur radio, in academia and many other fields.

As a security researcher and software developer, I often re-purpose existing hardware as part of projects and demonstrations, this legislation would prevent this and so kill research and innovation. Some examples: Researchers find a vulnerability in a wireless access point which is no longer supported by the manufacturer.

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 products such as telecommunication equipment, robotics, automation, laser and sensor technologies, electronics for…

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 incentives that small companies and startups have. Blocking startups would block innovation.

The Osmocom (Open Source Mobile Communications) project is a non-for-profit project developing a variety of mobile communications systems as open source software. In many areas of the IT Industry, Free/Open Source Software has been hugely successful since the 1990ies.

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 3(3)(i).

sysmocom - s.f.m.c. GmbH is a German SME. Our core business area is the development of protocol stacks and other software implementing network elements of cellular infrastructure. This includes software ran on cellular base stations (BTS) and up into the cellular core network. We implement [parts of] a variety of ETSI and 3GPP systems with a big focus on GSM/GRPS/EGRPS/UMTS, but also e.g.

Forcing (or even encouraging) users to trust one and only one provider of software has not played out well in the past, for many reasons - the EU is aware of this, and I applaud their efforts to shield customers and users from software (and hardware) companies and their never ending demand for user data.

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 security of products placed on the market.

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 requirement will have to be demonstrated for the purposes of market access.

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 contribution attached.

Hello Expert Group, thank you for giving the possibility to give feedback. Article 3.3(i) will kill the development progress of wireless technologies like IoT in Europe espcially for SME. Therefore the Option 0 will be the best to keep Europe alive in the development progress against the rest of the world and the leading position will be given to America and Asia.

Dear Sirs, this initiative is very problematic, and I am surprised that this discussion comes up again. I strongly recommend that the zero-option be adopted: Option 0, baseline scenario: a situation in which manufacturers are not obliged to implement any specific measures as it is currently the case.

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.

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 networks, cyber-physical systems and internet-of-things.

I am a self-employed software developer who writes wifi device drivers for open source and free software operating systems for a living. The result of my work is published by the OpenBSD project, based in Canada, and is made available worldwide under permissive licensing terms: https://www.openbsd.org/policy.html My drivers end up being packaged into IT security products by various companies around the world.

Feedback to Inception Impact Assessments – Ares(2019) 476957 03/04/2019 Shure is a well-known professional audio manufacturer producing, for example, high quality wireless microphones and In Ear Monitoring equipment (www.shure.com). Shure’s products are well received in Europe and widely used by many professional users in a variety of industries requiring high-quality audio production.

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 non-compliance with the RED due to software uploads have not been clearly identified.

The options considered in the Directive to restrict the upload of software put at risk the success of the necessary policies already called for by the EU Commission to extend the lifetime and repair of consumer products. Higher security requirements on the Internet of Things must not jeopardise the higher quality requirements of environmental and resource protection.

Filed in German · English published by the European Commission

Dear all, In response to the European Commission Initiative titled ‘Commission delegated regulation on Reconfigurable Radio Systems (RRS)'. As a Notified Body, we always in favor of regulations, however we also understand that we cannot block the evolution already mentioned in the majority of the feedbacks.

Dear Sir/Madam, I am 1. Chairwoman of the non-profit association “Freundfunk Uelzen e.V.”. Our association has several objectives: 1 Information to members, the public and any interested parties on free networks, in particular via the Internet and through conferences, events, demonstrations and publications; 2 Provision of know-how on technology and application of free networks; Information on social, cultural…

Filed in German · English published by the European Commission

Itron, although cognizant of the risks associated with the ability for radios to be upgraded over the air, believes that caution should be taken in restricting such activities, and that additional administrative burdens and delays should be very carefully considered.

I am writing on behalf of my company Code Mercenaries GmbH, which produces some wireless products. Article 3.3i should not be activated at all. The option 0, no regulation, or option 1, self regulation, should be used. Article 3.3i would eliminate the larger part of the SMEs from the wireless market. Programmable radio modules are an important factor for that market.

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 software updates and reconfigurations are applied to the products, under the framework of the Radio Equipment Directive…

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 and Think Tanks).

Dear Ladies and Gentlemen, I am writing on behalf of AMA Association for Sensors and Measurement, a network of 460 companies and institutes concerned with sensors. Most of our members are SMEs. Our main office is located in Berlin, Germany. Of the Objectives and Policy options presented in the "Inception Impact Assesment" paper [Ref.

As a manufacturer of professional radio equipment, we need to comply with the Regulation on the protection of personal data and the applicable directives. In our area of solutions and products for buildings/houses, the use of the certification scheme for ICT products, which is being set up, will become a duty driven by demand from customers and the market.

Filed in French · English published by the European Commission

As a global manufacturer of assisted listening devices for the hearing impaired with a number of offices and many customers within the European Union, Starkey Hearing Technologies respectfully submits the following comments on this proposal: We believe that regulatory options 0 or 1 are appropriate for assisted listening devices and their associated accessories: The following regulatory options will be considered: •…

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 Impact Assessment on the planned Commission delegated regulation on Reconfigurable Radio Systems.

Dear Sirs, Equipment for the maritime mobile service under the Radio Equipment Directive is falling under the scope of Article 3(3)(g). The potential of radios the parameters of which are determined by internal software, i. e. reconfigurable and also software defined radios (SDR), is recognized.

Source: ROHDE & SCHWARZ VEGA Grieshaber KG 2pi-LABS GmbH European GPR Association Continental Automotive GmbH DecaWave Ltd Honeywell Enraf BV Marquardt GmbH KROHNE Messtechnik GmbH EMERSON Process Mgt Limited Novelda AS 3d-Radar AS Geoscanners AB Geophysical Survey Systems Inc HILTI AG IDS Georadar srl Impulse Radar International Groundradar Consulting Inc Mala Geoscience PipeHawk plc Proceq SA Roadscanners Oy…

Response to the European Commission Initiative titled ‘Commission delegated regulation on Reconfigurable Radio Systems (RRS). We appreciate the early circulation of this initiative to all stakeholders and respectfully makes the following comments:- 1.