Radio Equipment Directive: Orgalim views on the EC Roadmap for a delegated Act on upload of software to radio equipment

Published: 7 May 2019

Policies & Issues: Internal Market - Product Safety Legislation

As stressed in the Commission Communication on “digitising European Industry” (COM(2016)180), digitalisation has become one of the major drivers of industry’s competitiveness and innovation capacity. This is enabled namely through radio equipment which is increasingly incorporated in technological products such as telecommunication equipment, robotics, automation, laser and sensor technologies, electronics for automotive, household appliances, security and energy markets.

In this context, Orgalim is pleased to provide its views on the particular issue of embedded and business software which may be installed in this equipment and products. Our industry is committed to keeping such products interoperable in the public radio spectrum and safe for all end-users including when further software updates and reconfigurations are applied to the products, under the framework of the Radio Equipment Directive (RED).

In Orgalim’s view, a one-size-fits-all approach is neither realistic nor feasible. Should a delegated act be considered necessary at all, then it should respect the principles of proportionality and better regulation: additional administrative burdens need to be carefully examined and should be deemed justified and applicable only to those product categories presenting a risk of non-compliance. The impact of such measures on innovation and the competitiveness of new products and applications should be carefully examined.

To read our recommendations in full, please download the position paper above. 


Philippe Portalier
Director - Better Regulation, Compliance and Standards

Related Position Papers

Internal Market: Orgalim comments for the upcoming delegated act for internet-connected radio equipment and wearables [9 October 2020]

Internal Market: Orgalim comments on the final report of the impact assessment study on internet-connected radio equipment and wearable radio equipment [31 July 2020]

Internal Market: Orgalim Comments to EMC Directive Roadmap [21 February 2020]

Internal Market: Orgalim reaction - Commission Staff Working Document on the CPR Evaluation study [7 February 2020]

Internal Market: Orgalim comments to proposals tabled for revision of the Machinery Directive 2006/42/EC [3 February 2020]

Machinery Directive: Orgalim Contribution to the Guide of Interpretation to the Machinery Directive [26 September 2019]

Machinery Directive: Orgalim's response to the Open Public Consultation on the revision of the Directive 2006/42/EC on machinery [30 August 2019]

Construction Products Regulation: Orgalim views on shaping a Regulation on Construction Products that strengthens the Internal Market [14 May 2019]

Radio Equipment Directive: Orgalim views on the EC Roadmap for a delegated Act on upload of software to radio equipment [7 May 2019]