We are facing a EU regulation which may make it impossible to install a custom piece of software on most radio decives like WiFi routers, smartphones and embedded devices. You can now give feedback on the most problematic part by Monday, 4 March. Please participate – it’s not hard!
In the EU Radio Equipment Directive (2014/53/EU) contains one highly dangerous article will cause many issues if implemented: Article 3(3)(i). It requires hardware manufacturers of most devices sending and receiving radio signals to implement a barrier that disallows installing software which has not been certified by the manufacturer. That means, that for installing an alternative operating system on a router, mobile phone or any other radio-capable device, the manufacturer of this device has to assess its conformity.
[R]adio equipment [shall support] 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.
– Article 3(3)(i) of the Radio Equipment Directive 2014/53/EU
That flips the responsibility of radio conformity by 180°. In the past, you as the one who changed the software on a device have been responsible to make sure that you don’t break any applicable regulations like frequency and signal strength. Now, the manufacturers have to prevent you from doing something wrong (or right?). That further takes away freedom to control our technology. More information here by the FSFE.
The European Commission has installed an Expert Group to come up with a list of classes of devices which are supposed to be affected by the said article. Unfortunately, as it seems, the recommendation by this group is to put highly diffuse device categories like „Software Defined Radio“ and „Internet of Things“ under the scope of this regulation.
But there is something you can do! The European Commission has officially opened a feedback period. Everyone, individuals, companies and organisations, can provide statements on their proposed plans. All you need to participate is an EU Login account, and you can hide your name from the public list of received feedback. A summary, the impact assessment, already received feedback, and the actual feedback form is available here.
To help you word your feedback, here’s a list of some of the most important disadvantages for user freedom I see (there is a more detailed list by the FSFE):
There will surely be more, so please make your points in your individual feedback. It will send a signal to the European Commission that there are people who care about freedom on radio devices. It’s only a few minutes work to avoid legal barriers that will worsen your and others‘ lives for years.