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<title>Joint Statement against Radio Lockdown</title>
<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!"/>
<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"/>
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<p id="category"><a href="/activities/radiodirective/radiodirective.html">Radio Lockdown Directive</a></p>
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<h1 class="p-name">Joint Statement against Radio Lockdown</h1>
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<img src="img/radiolockdown-cage-open.jpg" alt="a bird cage with a router and a mobile phone imprisoned, both sending radio waves"/>
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<p>The Radio Lockdown Directive threatens users' rights and Free Software, fair
competition, innovation, environment, and volunteering – without comparable
benefits for security. <a href="#sig">Many organisations and companies</a> are
joining up in proposing measures to EU institutions and EU member states to
avoid these negative implications while keeping the Directive's goal intact.
Please also read our in-depth and constantly updated <a href="/activities/radiodirective/radiodirective.html">analysis</a>.</p>
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<blockquote id="statement">
<h2>Avoid Radio Lockdown risks – protect security and innovation</h2>
<p>More and more devices connect to the Internet and each other using wireless
and mobile networks. These include countless devices such as routers, mobile
phones, WiFi-cards and laptops. All of them, as well as all Internet-of-Things
devices, today and in the future, fall under the regulation of the Radio
Equipment Directive 2014/53/EU (hereinafter ‘the Directive’), adopted in May
2014 by the European Parliament and the European Council. The main purposes of
the Directive are harmonisation of existing regulations, improving security of
radio spectra, and protection of health and safety.</p>
<p>We support the general purpose of the Directive. However, we express our
concerns over the far-reaching consequences of Article 3(3)(i) of the Directive,
which require device manufacturers to check each device software's compliance
in order to comply with the Directive.</p>
<h3>Threats of Radio Lockdown</h3>
<p>We believe such requirement has negative implications on users' rights and
Free Software, fair competition, innovation, environment, and volunteering –
mostly without comparable benefits for security.</p>
<p>Article 3(3)(i) require device manufacturers to assess software for
compliance with existing national radio regulations, a requirement which will
keep users and companies from upgrading the software on devices they own,
unless that software is assessed by the original manufacturer. This not only is
a severe burden for device manufacturers themselves but also violating the
<strong>customers' rights of free choice</strong>.</p>
<p>The requirement enshrined in Article 3(3)(i) will impact the freedom to
conduct business of many companies relying on the abillity to provide
alternative and Free Software firmware on devices. Alternative software is the
foundation of many companies' products, and we should prevent <strong>economic
disadvantages</strong> for these businesses.</p>
<p>Burdensome requirements to check every possible software's compliance will
also have negative implications on <strong>innovation and charitable
non-profit</strong> organisations who rely on software other than the
manufacturers'. Efforts of volunteer associations helping people in need to
connect to the internet, may be rendered void or severely handicapped.</p>
<p>Furthermore, alternative software on radio devices also promotes a
<strong>sustainable economy</strong>. There are many devices still in working
order which do not receive updates from the original manufacturers anymore,
hence alternative software developed and improved by community efforts (such as
Free Software) has a much longer support period which prevent users and
customers having to dispose of still working equipment. In return, this also
improves the <strong>security</strong> of users since older hardware still
receives security updates after a manufacturer stops supporting those.</p>
<p>We are in favor of the Directive's aim to improve security of radio devices
but not at the unbalanced expense of users' freedom and security in other
areas. Firstly, upgrading the software of a device mostly helps increasing the
devices' security. Secondly, we are convinced that such strict regulations are
not necessary for typical consumer products with limited radio output power.
And thirdly, we believe that such technical restrictions will not hinder people
willingly violating applicable radio regulations.</p>
<h3>Our Proposals</h3>
<p>Therefore, we ask EU institutions and the Member States to take these
concerns into consideration and ensure that the Directive does not place
blanket, unnecessary and disproportionate restrictions on the rights of
consumers and businesses when implementing the Directive into national
legislations.</p>
<blockquote>
<h3>What we expect of EU institutions</h3>
<p>We ask the European Commission to adopt delegated acts - as empowered by the
European Parliament and Council (Art. 44) - which either </p>
<ul>
<li>make general exceptions for all Free Software not developed by the
manufacturers of the respective radio equipment themselves but from other
companies or individuals.</li>
<li>do not shift the responsibility for the software's regulatory compliance
from the users to the manufacturers when making changes to the default
configuration. Software and hardware should not be treated differently in
that respect.</li>
</ul>
</blockquote>
<blockquote>
<h3>What we expect of EU member states</h3>
<p>We ask member state legislators to </p>
<ul>
<li>interpret the directive's provisions so that Free Software can still be
installed on radio devices without discrimination, and users' rights are
safeguarded. As pointed out in recital (19), third party software providers,
such as Free Software projects, shall not be disadvantaged.</li>
<li>make sure that small and medium-sized manufacturers will not be burdened
disproportionally by being forced to assess each and every alternative
software.</li>
<li>make sure that users are not forced to install non-free software.</li>
</ul>
</blockquote>
</blockquote>
<h2 id="sig">Signing Organisations and Companies</h2>
<p>This statement has been signed by various organisations and businesses being
concerned by the Directives consequences. Other organisations and companies are
welcome to co-sign the letter. Please help us to raise awareness for this
issue. To sign, please contact <a href="/about/people/mehl/">this campaign's
manager</a>.</p>
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<h2>Further Reading</h2>
<h3>External links</h3>
<ul>
<li><a href="http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX%3A32014L0053">Full text of RED 2014/53/EU</a></li>
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