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<?xml version="1.0" encoding="UTF-8"?>
<html newsdate="2019-11-20">
<version>1</version>
<head>
<title>Input for the BEREC's guidelines on Router Freedom in Europe</title>
</head>
<body>
<h1>Input for the BEREC's guidelines on Router Freedom in Europe</h1>
<p>
Router Freedom is the right of customers of any Internet Service
Provider (ISP) to choose and use a private modem and router instead
of a router that the ISP forces them to use. The Body of European Regulators for Electronic Communications (BEREC) drafted guidelines for national agencies how to deal with
Router Freedom in their countries. The Free Software Foundation
Europe (FSFE) provided mixed feedback to an ongoing public
consulation.
</p>
<p>
The status of <a href="/activities/routers">Router Freedom</a> in
Europe differs from country to country as the <a
href="https://wiki.fsfe.org/Activities/CompulsoryRouters/#Router_Freedom_in_Europe">monitoring
by the FSFE</a> shows. The core of the debate is the question of
where the Network Termination Point (NTP) is located. This defines where
the network of the ISP ends and where the network of the user begins. If
the modem and router are considered part of the ISP's infrastructure, a user cannot claim
sovereignty of their communication and security.
</p>
<p>
The patchwork rug of different rules may change soon as BEREC, the
Body of European Regulators for Electronic Communications, has been
commissioned to create guidelines for the National Regulatory
Agencies (NRAs) and help them with implementing European regulation
in a harmonised way. <a
href="https://download.fsfe.org/policy/routers/8821-draft-berec-guidelines-on-common-approac_0.pdf">BEREC's
current draft of the guidelines</a> is up for public consultation
until 21 November 2019. We analysed this draft and the EU
Directives and Regulations it references, and provided our conclusion in a <a
href="https://download.fsfe.org/policy/routers/20191121-BEREC-Guidelines-Consultation.pdf">brief
document</a>.
</p>
In short, BEREC puts three different models forward to discussion:
<figure>
<img
src="https://pics.fsfe.org/uploads/big/37c03c4a34cb2a6c58d347c0b29f0a4d.png"
alt="Three options shared by BEREC for the location of the NTP"/>
<figcaption>
The three discussed options for the location of the NTP. Source: BEREC
</figcaption>
</figure>
<ol>
<li>
The network termination point is at location A. This means that
routers and modems are under the user's control, who can decide which
device to use – either the one recommended and provided by the ISP
or one by a third party. That would result in Router Freedom.
</li>
<li>
The NTP is at B. This means that only the modem (so the device
connecting to the ISP) will be part of the ISP's network, but
routers or media boxes will be in the user's domain.
</li>
<li>
The NTP is at C. That's the most restrictive option as it results
in the modem and router or a combined device being solely under the
control of the ISP.
</li>
</ol>
<p>
Understandably, we argued in favour of making point A the network
termination point to establish and protect freedom of choice, privacy
and data protection, fair competition of device manufacturers, as well as
security. Furthermore, we made a few suggestions to improve the
guidelines and their implementation by the National Regulatory
Agencies:
</p>
<ul>
<li>
In this draft, the guidelines carefully weigh up the different
possible locations for the NTP. However, it is clear from the
arguments that only point A makes sense from a perspective of
customers and businesses, and that no serious technological reasons
speak against it. BEREC should take a more firm stand on this and
discourage National Agencies from making any other choice to reduce
a patchwork rug of different regulations.
</li>
<li>
There is a whole section discussing the impact of the different NTP
locations on ISPs and network operators, but users' necessities are
only implied, although a EU Directive from 2008
and a EU Regulation from 2015 clearly state that customers have to
have Router Freedom. We ask BEREC to elaborate the
different options also more prominently from the perspective of
technology users.
</li>
</ul>
<h2>Get active</h2>
<p>
You can still participate in the public consultation by just sharing
your feedback on the draft BEREC guidelines <a
href="https://berec.europa.eu/eng/news_consultations/ongoing_public_consultations/5912-public-consultation-on-draft-berec-guidelines-on-common-approaches-to-the-identification-of-the-network-termination-point-in-different-network-topologies">by
sending an e-mail to them</a> <strong>before 21 November 2019 17:00
CET</strong>. It's a short deadline, so feel free to use our <a
href="https://download.fsfe.org/policy/routers/20191121-BEREC-Guidelines-Consultation.pdf">full
response</a> as an inspiration.
</p>
<p>
If you need more arguments in favour of Router Freedom, please read
our <a href="/activities/routers/">summary page</a>. For individuals
and groups who want to become even more active for Router Freedom, we
have created an <a
href="https://wiki.fsfe.org/Activities/CompulsoryRouters/">activity
package</a> with more background information, experience reports of
how the FSFE managed to turn the situation around in Germany, and
other tips and tricks.
</p>
</body>
<tags>
<tag key="routers">Router Freedom</tag>
<tag key="competition">Competition</tag>
<tag key="policy">Policy</tag>
<tag key="front-page"/>
</tags>
<author id="mehl" />
</html>