As researchers in the field of ubiquitous computing and IoT we have been relying on the ability to change the fireware of off the shelf radio devices. Eg. the FP7 research project COBIS, which pioneered the IoT aproach, we were already using wifi routers which were extended with custom radios. This was only possible by using extensible after market firmware.
In other projects e.g. on device free activity recognition we are relying on fireware which allows us to access the channel state information of radio chips. This is custom firmware which needs to is uploaded for research purposes.
I can continue this list. Article 3(3)(i) of the Radio Equipment Directive 2014/53/EU is a huge hazard to research! It will hinder innovation in the EU!
On a side node the directive will also be a great challenge to the open hardware movement and new kinds of business models that separate hardware and software.
I urge the commission to continue allow (and even encourage) the possibility to change the firmware of radio equipment. It should be made clear, that changing the code might lead to violations of the Radio Equipment Directive , but this will be also possible and even more likely if people build their own equipment from scratch from components (which is easy).
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