As the voice of the reputable EU toy sector, Toy Industries of Europe (TIE), welcomes the Commission’s decision to explore whether a delegated act under the Radio Equipment Directive can be a useful and effective part of the EU legal framework, particularly with relation to increasing the security of connected products placed on the EU market, whilst ensuring a level playing field for businesses. Nevertheless, we have several concerns about the content of the IIA that we would like to raise, that we have outlined here and provide more detail about in the document we have attached to this response.
- Given the stated intention of the IIA to consider all internet-connected radio equipment and wearable radio equipment, and the very small proportion of connected toys relative to other connected devices, we are concerned that the content of the ‘context’ section of the IIA is too narrow in its focus.
- It would be useful to have a clearer overview of the concrete security and privacy threats the initiative is aimed at addressing, as well as references to the challenges that reputable businesses face in the connected environment.
- We would ask for the references related to connected toys to be reviewed and revised to correct inaccuracies.
We thank the Commission for the opportunity to provide feedback on the Inception Impact Assessment. We look forward to providing further input into the initiative and are available in case the Commission has any further questions.
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