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

Orgalim, Europe’s Technology Industries, welcomes the opportunity provided by the European Commission to give comments and suggestions with regard to the activation of a delegated act pursuant to Article 3.3 of the Radio Equipment Directive (RED) (sub-articles d),e),f).

First and foremost, we wish to stress that Orgalim members are still of the opinion that a horizontal approach to cybersecurity requirements would be more beneficial than delegated acts, as this would holistically address the risks and concerns related to cybersecurity and ensure the necessary level of protection without creating a patchwork of requirements in product-specific legislation.

This paper will, however, only focus on the following three aspects which were raised on 17 November at the RED Expert Group (document EG RE (08)04r01), 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 implementation period

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