Feedback (16)

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  • Toy Industries of Europe (Belgium)
    4 March 2019 Business association
    Toy Industries of Europe (Belgium)

    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...

  • Orgalim, Europe's Technology Industries (Belgium)
    4 March 2019 Business association
    Orgalim, Europe's Technology Industries (Belgium)

    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,...

  • Eurosmart (Belgium)
    4 March 2019 Business association
    Eurosmart (Belgium)

    Eurosmart, the voice of the digital security industry welcomes the European Commission (DG GROW) proposal to strengthen the security approach of internet-connected radio equipment and wearable radio equipment. Reaching a trustworthy and secure IoT market is paramount for the achievement of the European Digital Single Market. By 2025, the projected IoT connections are expected to exceed the 25 billion of units’ threshold . In the meantime,...

  • Mobile & Wireless Forum (MWF) (Belgium)
    4 March 2019 Business association
    Mobile & Wireless Forum (MWF) (Belgium)

    Comments on the Inception Impact Assessment on “Internet-connected radio equipment and wearable radio equipment” The MWF and its members appreciate the opportunity to submit comments on the inception impact assessment regarding “Internet-connected radio equipment and wearable radio equipment”; please find our contribution attached. About the Mobile & Wireless Forum The Mobile & Wireless Forum (MWF, www.mwfai.org) is an international...

  • BEUC - The European Consumer Organisation (Belgium)
    4 March 2019 Non-governmental organisation (NGO)
    BEUC - The European Consumer Organisation (Belgium)

    Several tests done by consumer organisations have shown that connected products that land on the market come with multiple security risks and basic flaws. Besides obvious risks related to data protection and the loss of privacy, these flaws directly pose safety and security threats. Consumer organisations have provided the evidence that consumer products and services are not secure due to a legislative gap. As mentioned in the IIA of the...

  • APPLiA - Home Appliance Europe (Belgium)
    4 March 2019 Business association
    APPLiA - Home Appliance Europe (Belgium)

    DUE TO LIMITED SPACE FULL SET OF COMMENTS IN THE ATTACHED PAPER: The problem the initiative aims to tackle here appears to be the aim to define IoT device as “internet-connected radio equipment, i.e. radio equipment intended to be (i) connected (directly or indirectly) to or (ii) controlled through the internet. “ Whilst we agree with the concept given by this definition, we are unclear if this clarification will be part of the future...

  • Verband der TÜV e.V. (Germany)
    4 March 2019 Business association
    Verband der TÜV e.V. (Germany)

    Verband der TÜV (VdTÜV) welcome and support the EU Commission’s initiative to address the issue of cybersecurity and privacy of products. According to Article 169 of the TFEU, the legislator is obligated to ensure a high level of consumer protection. The European regulatory framework must guarantee that the relevant public can sufficiently trust in the security and safety of IoT products such as toys so that innovations gain the necessary...

  • DIGITALEUROPE (Belgium)
    4 March 2019 Business association
    DIGITALEUROPE (Belgium)

    DIGITALEUROPE submits that the adoption of a delegated regulation under the Radio Equipment Directive (RED) would not be an appropriate instrument to address risks for the protection of personal data, privacy and cybersecurity. While potential risks do exist, existing legislative and regulatory instruments are at present better able to address them. As such, we support Options O and 1 identified in the inception impact assessment. Should the...

  • Cetome (France)
    4 March 2019 Company/business organisation
    Cetome (France)

    Cetome is an independent security consultancy with a recognised expertise in IoT. We believe security and privacy in IoT must follow a holistic approach and that they must adapt to each use-case scenario with the objective to reduce business risks. For that purpose, we believe in the global harmonisation of IoT security and privacy requirements, with the definition of a cross-sector baseline that would be complemented by sectorial...

  • Code Mercenaries GmbH (Germany)
    3 March 2019 Company/business organisation
    Code Mercenaries GmbH (Germany)

    I am providing this feedback on behalf of my company Code Mercenaries GmbH which produces some wireless products. This is a cyber security issue, it should not be addressed as part of RED since this would create redundant and potentially concurrent requirements with the cyber security regulation.

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