Internal Market: Orgalim comments for the upcoming delegated act for internet-connected radio equipment and wearables

Published: 9 October 2020

Policies & Issues: Internal Market - Product Safety Legislation

Orgalim welcomes the opportunity provided by the European Commission to give comments and suggestions in view of the activation of a delegated act pursuant to article 3(3) of the Radio Equipment Directive (RED) (sub-articles d,e,f).

We would first and foremost like to stress that Orgalim members are still of the opinion that a horizontal approach to cybersecurity requirements would be more beneficial than delegated acts by holistically addressing the risks and concerns related to cybersecurity, without creating a patchwork of requirements in product specific legislation, while ensuring the necessary level of protection.

This paper will however only focus on the following four aspects which were raised at the RED Expert Group, in order to support the Commission in drafting the delegated act, namely:

  • The definition of the scope of the delegated act

  • The applicable articles

  • The exemptions

  • The implementation period

To read our comments and proposals in full, please download the document above.


Ioana Smarandache
Senior Adviser - Internal Market
Christoph Luykx
Policy Director

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