3 September 2020, 09:00
Throughout the summer, the European Commission (EC) made available a public consultation on a delegated act on Reconfigurable Radio Systems (RRS) under the Radio Equipment Directive (RED).
The EC is collecting input in view of assessing possible issues that may arise when radio equipment can be reprogrammed by software (including firmware). At the same time, the objective of the initiative is to investigate the potential impacts of different policy options to ensure that each reconfigurable radio system remains compliant with the RED after the installation of new or modified software.
In practice, such delegated act would add extra health and safety requirements to some classes of radio equipment. This would oblige manufacturers wanting to place such products in the EU market to adapt their conformity assessment procedures to comply with such new requirements.
On 26th August, CECE provided an answer to this public consultation. Our members believe there is no need for a delegated act on Reconfigurable Radio Systems because there is already enough protection in place for the upload of software into machines. In the construction equipment sector, original equipment manufacturers already have quality control and security systems that take into consideration the upload and protection of their own software.
Moreover, our members believe there would be disadvantages in creating any new regulation. Our manufacturers believe new regulation aimed at software would hamper innovation, create unnecessary burden (administrative and additional testing), and products without significant risk would be in scope as collateral damage.
The EC is expected now to analyse the answers to the public consultation and decide to activate or not the delegated act under the RED.