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 Internet-connected 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 industries are committed to keeping such products interoperable in the public radio spectrum and safe for all end-users including when these are connected to the Internet, under the framework of the Radio Equipment Directive (RED).
In Orgalim’s view, the resilience of Internet-connected radio equipment to cyber attacks should be addressed in a consistent way in Europe, without creating overlapping and potentially contradicting existing legislation, including the recently adopted European Cybersecurity Act* or the General Data Protection Regulation (GDPR)**. Addressing cybersecurity requirements in a Delegated Act under the RED, which essentially has to stay within the limits of privacy (Art 3.3 (e)) and fraud (Art 3.3 (f)) would be limited to a subset of products and cybersecurity requirements.
Therefore, we deem option ‘0’ (baseline scenario) as the most appropriate policy option under the current RED to prevent overlapping and fragmented legislative requirements on cybersecurity for internet-connected radio equipment.
Orgalim remains at the disposal of the European Commission to provide further details on these initial comments. Furthermore, Orgalim expresses its interest and availability to provide additional explanations and evidence during the next steps of the impact assessment, as well as in the Expert Group on Reconfigurable Radio Systems.
* Cybersecurity Act: https://ec.europa.eu/commission/news/cybersecurity-act-2018-dec-11_en
** Regulation (EU) 2016/679 — GDPR: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32016R0679
The views and opinions expressed here are entirely those of the author(s) and do not reflect the official opinion of the European Commission. The Commission cannot guarantee the accuracy of the information contained in them. Neither the Commission, nor any person acting on the Commission’s behalf, may be held responsible for the content or the information posted here. Views and opinions that violate the Commission’s feedback rules will be removed from the site.