2019-03-04 Radio equipment in the EU

This is the feedback I provided after reading Protect freedom on radio devices: raise your voice today! More information is available from the FSFE, EU Radio Lockdown Directive.

I’d like to give some feedback on Article 3(3)(i) of the Radio Equipment Directive 2014/53/EU. The passage “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” is going too far.

Use cases I am interested in: installing an update on my wifi router, phone, and smart home wireless product. There are many reasons why this is desireable:

  1. official security updates from the original vendor are no longer available
  2. I no longer trust the original vendor
  3. I want to develop alternatives (adding compatibility with other devices, for example)

Alex Schroeder

(I did this even though I am not a citizen of the EU.)



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