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  1. <?xml version="1.0" encoding="UTF-8"?>
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  5. <title>Joint Statement against Radio Lockdown</title>
  6. <meta name="description" content="The EU Radio Lockdown Directive threatens Free Software, user rights, innovation, security, and fair competition. We can change that - join us!"/>
  7. <meta name="keywords" content="radio equipment directive, RED, 2014 53 EU, radio lockdown directive, european parliament, european commission, regulation, law, lobby, policy, threat, freifunk, routers, signal"/>
  8. </head>
  9. <body class="article" microformats="h-entry">
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  11. <p id="category"><a href="/activities/radiodirective/radiodirective.html">Radio Lockdown Directive</a></p>
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  13. <h1 class="p-name">Joint Statement against Radio Lockdown</h1>
  14. <div class="e-content">
  15. <div id="introduction">
  16. <div class="right" style="max-width: 506px; width: 30%;">
  17. <img src="img/radiolockdown-cage-open.jpg" alt="a bird cage with a router and a mobile phone imprisoned, both sending radio waves"/>
  18. </div>
  19. <p>The Radio Lockdown Directive threatens users' rights and Free Software, fair
  20. competition, innovation, environment, and volunteering – without comparable
  21. benefits for security. <a href="#sig">Many organisations and companies</a> are
  22. joining up in proposing measures to EU institutions and EU member states to
  23. avoid these negative implications while keeping the Directive's goal intact.
  24. Please also read our in-depth and constantly updated <a href="/activities/radiodirective/radiodirective.html">analysis</a>.</p>
  25. </div>
  26. <blockquote id="statement">
  27. <h2>Avoid Radio Lockdown risks – protect security and innovation</h2>
  28. <p>More and more devices connect to the Internet and each other using wireless
  29. and mobile networks. These include countless devices such as routers, mobile
  30. phones, WiFi-cards and laptops. All of them, as well as all Internet-of-Things
  31. devices, today and in the future, fall under the regulation of the Radio
  32. Equipment Directive 2014/53/EU (hereinafter ‘the Directive’), adopted in May
  33. 2014 by the European Parliament and the European Council. The main purposes of
  34. the Directive are harmonisation of existing regulations, improving security of
  35. radio spectra, and protection of health and safety.</p>
  36. <p>We support the general purpose of the Directive. However, we express our
  37. concerns over the far-reaching consequences of Article 3(3)(i) of the Directive,
  38. which require device manufacturers to check each device software's compliance
  39. in order to comply with the Directive.</p>
  40. <h3>Threats of Radio Lockdown</h3>
  41. <p>We believe such requirement has negative implications on users' rights and
  42. Free Software, fair competition, innovation, environment, and volunteering –
  43. mostly without comparable benefits for security.</p>
  44. <p>Article 3(3)(i) require device manufacturers to assess software for
  45. compliance with existing national radio regulations, a requirement which will
  46. keep users and companies from upgrading the software on devices they own,
  47. unless that software is assessed by the original manufacturer. This not only is
  48. a severe burden for device manufacturers themselves but also violating the
  49. <strong>customers' rights of free choice</strong>.</p>
  50. <p>The requirement enshrined in Article 3(3)(i) will impact the freedom to
  51. conduct business of many companies relying on the abillity to provide
  52. alternative and Free Software firmware on devices. Alternative software is the
  53. foundation of many companies' products, and we should prevent <strong>economic
  54. disadvantages</strong> for these businesses.</p>
  55. <p>Burdensome requirements to check every possible software's compliance will
  56. also have negative implications on <strong>innovation and charitable
  57. non-profit</strong> organisations who rely on software other than the
  58. manufacturers'. Efforts of volunteer associations helping people in need to
  59. connect to the internet, may be rendered void or severely handicapped.</p>
  60. <p>Furthermore, alternative software on radio devices also promotes a
  61. <strong>sustainable economy</strong>. There are many devices still in working
  62. order which do not receive updates from the original manufacturers anymore,
  63. hence alternative software developed and improved by community efforts (such as
  64. Free Software) has a much longer support period which prevent users and
  65. customers having to dispose of still working equipment. In return, this also
  66. improves the <strong>security</strong> of users since older hardware still
  67. receives security updates after a manufacturer stops supporting those.</p>
  68. <p>We are in favor of the Directive's aim to improve security of radio devices
  69. but not at the unbalanced expense of users' freedom and security in other
  70. areas. Firstly, upgrading the software of a device mostly helps increasing the
  71. devices' security. Secondly, we are convinced that such strict regulations are
  72. not necessary for typical consumer products with limited radio output power.
  73. And thirdly, we believe that such technical restrictions will not hinder people
  74. willingly violating applicable radio regulations.</p>
  75. <h3>Our Proposals</h3>
  76. <p>Therefore, we ask EU institutions and the Member States to take these
  77. concerns into consideration and ensure that the Directive does not place
  78. blanket, unnecessary and disproportionate restrictions on the rights of
  79. consumers and businesses when implementing the Directive into national
  80. legislations.</p>
  81. <blockquote>
  82. <h3>What we expect of EU institutions</h3>
  83. <p>We ask the European Commission to adopt delegated acts - as empowered by the
  84. European Parliament and Council (Art. 44) - which either </p>
  85. <ul>
  86. <li>make general exceptions for all Free Software not developed by the
  87. manufacturers of the respective radio equipment themselves but from other
  88. companies or individuals.</li>
  89. <li>do not shift the responsibility for the software's regulatory compliance
  90. from the users to the manufacturers when making changes to the default
  91. configuration. Software and hardware should not be treated differently in
  92. that respect.</li>
  93. </ul>
  94. </blockquote>
  95. <blockquote>
  96. <h3>What we expect of EU member states</h3>
  97. <p>We ask member state legislators to </p>
  98. <ul>
  99. <li>interpret the directive's provisions so that Free Software can still be
  100. installed on radio devices without discrimination, and users' rights are
  101. safeguarded. As pointed out in recital (19), third party software providers,
  102. such as Free Software projects, shall not be disadvantaged.</li>
  103. <li>make sure that small and medium-sized manufacturers will not be burdened
  104. disproportionally by being forced to assess each and every alternative
  105. software.</li>
  106. <li>make sure that users are not forced to install non-free software.</li>
  107. </ul>
  108. </blockquote>
  109. </blockquote>
  110. <h2 id="sig">Signing Organisations and Companies</h2>
  111. <p>This statement has been signed by various organisations and businesses being
  112. concerned by the Directives consequences. Other organisations and companies are
  113. welcome to co-sign the letter. Please help us to raise awareness for this
  114. issue. To sign, please contact <a href="/about/people/mehl/">this campaign's
  115. manager</a>.</p>
  116. <sigtable/>
  117. </div><!--/e-content-->
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  119. <h2>Related news</h2>
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  122. </body>
  123. <tags>
  124. </tags>
  125. <sidebar promo="our-work">
  126. <dynamic-content/>
  127. <h2>Further Reading</h2>
  128. <h3>External links</h3>
  129. <ul>
  130. <li><a href="">Full text of RED 2014/53/EU</a></li>
  131. </ul>
  132. </sidebar>
  133. </html>
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