Dear Ladies and Gentlemen,
I am writing on behalf of AMA Association for Sensors and Measurement, a network of 460 companies and institutes concerned with sensors. Most of our members are SMEs. Our main office is located in Berlin, Germany.
Of the Objectives and Policy options presented in the "Inception Impact Assesment" paper [Ref. Ares(2019)476957 - 28/01/2019] We very strongly recommend either regulatory "Option 0", baseline scenario, or regulatory "Option 1", industry self-regulation.
We remark that Article 3(3)(i) when drafted, neglected the case of wireless sensors. The provisions of this Article endanger the use of wireless sensors in Europe as well as endangering the industry that produces this technology. Furthermore, it increases the risk for cyberattacks on industry in general and creates insurmountable practical hurdles for the development and deployment of modern wireless sensor applications. It disproportionately disadvantages the EU states in the global competition for the digital economy which fundamentally depends on sensor data.
We kindly ask you to consider the reasoning behind our conclusions, which is summarized in the attached document “Wireless Sensing at Risk in Europe?”, an opinion paper by AMA Association for Sensors and Measurement concerning EU Directive 2014/53/EU – ‘Radio Equipment Directive’.
Thank you very much!
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