Have your say – radio equipment

You can also get involved in forming EU laws. The European Commission offers a platform “Have your say” with the list of all new EU initiatives open for public consultation. You need to register to write your feedback: ec.europa.eu/info/law/better-regulation/have-your-say

Activation of EU rules on radio equipment for reconfigurable radio systems

About this initiative: This initiative aims to ensure that reconfigurable radio systems meet the legal requirements of the rules on radio equipment during their whole life cycle, in particular to avoid issues following a software update or upload.

Feedback period: for stage 3 it is 29 April 2025 – 27 May 2025

Link: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14610-Activation-of-EU-rules-on-radio-equipment-for-reconfigurable-radio-systems_en

Feedback from Europeans for Safe Connections

We “Europeans for Safe Connections” welcome the initiative to update The Radio Equipment Directive (Directive 2014/53/EU). In the document “Call for evidence for an impact assessment”, you present five regulatory options. We support Option 4, as it offers the strongest protection for consumers, especially in terms of safety, privacy, and the right to control exposure to wireless technologies. We do not support maintaining the status quo (Option 0) or relying on industry self-regulation (Option 1), as both approaches have proven insufficient in addressing concerns related to health safety, energy efficiency, privacy, and user control.

In addition to supporting option 4, we propose the following 10 measures be considered in the regulatory update:

1. Wireless functions must be set to “Disabled” by default on all consumer devices (sold to private individuals). This ensures that users actively choose whether they want to be exposed to wireless emissions.
2. Devices must be equipped with a physical external switch to manually enable or disable wireless functionality. This increases transparency and user control.
3. When wireless functionality is activated, the device should default to the lowest effective transmission level. Users can increase power if needed, but starting low minimises unnecessary exposure.
4. Wireless modules should automatically switch to “sleep mode” when not in active use. For example, patent WO2004075583 describes a method for reducing electro-smog in WLANs by deactivating beacon signals after inactivity [1]. We encourage regulators to promote or mandate similar smart power-saving and emission-reducing technologies.
5. Modern smartphones often no longer include built-in power-saving features that automatically disable mobile data (and Wi-Fi) when not actively in use. As a result, users — especially those without technical knowledge or explicit awareness — may be continuously exposed to wireless radiation, even when no wireless functionality is intentionally used. We therefore recommend restoring or mandating such energy-efficient and health-conscious defaults.
6. To reduce environmental impact of radio equipment and the related software, the timeperiod for support by the manufacturer should be at least 15 years
7. The European Union should actively promote the availability and development of communication devices that do not emit wireless radiation, especially in order to protect the health of vulnerable populations, including children, the elderly, and individuals with electromagnetic sensitivity. Furthermore, the EU should encourage the production and accessibility of simplified wireless devices — such as phones limited to calling and texting — that minimise user exposure in terms of time, frequency, and intensity of radiation.
8. All radio equipment should be verified by an independent inspection body prior to market entry, to ensure compliance with applicable safety, performance, and emission standards. Only products that have successfully completed the conformity assessment procedure in accordance with the legal requirements in force at that time should be permitted to enter the EU market.
9. In the document, you note that “software updates and uploads may (accidentally) result in the product no longer being safe or causing harmful interference to essential radio communications services.” We therefore request that manufacturers be explicitly required to ensure continued conformity after any software update — particularly with regard to device transmission power and radiation intensity — so that such updates do not increase users’ exposure or compromise their health.
10. For many years, products emitting radio-frequency radiation — including mobile phones — have been placed on the EU market despite exceeding legal safety limits. These devices may pose long-term health risks to consumers. This issue has already been brought to the attention of the European Parliament, for example through a parliamentary question [2] raised three years ago, which received a response from European Commissioner Thierry Breton [3]:
    
    “Any measures taken by Member States concerning non-compliant products must be published in the ICSMS and, if the non-compliance presents a serious risk, in Safety Gate/RAPEX, which also enables consumers to be aware of the risks.”
    
    However, to date there are no records of non-compliant mobile phones in either ICSMS or Safety Gate/RAPEX databases. The same appears to apply to other wireless products, suggesting that these regulatory mechanisms may not be functioning effectively in practice. We urge the new Commission to make sure that all non-compliant devices are listed in the ICSMS / Safety Gate as stated by Commissioner Breton above, and that the general public as well as concerned authorities are informed where to find this data.

We believe these measures support a health-conscious, privacy-aware, and energy-efficient approach to the future of radio systems in the EU.

[1] Patent WO2004075583 – REDUCTION OF ELECTROSMOG IN WIRELESS LOCAL NETWORKS introduces a system that “after a predefinable time interval without connecting signal, the base station changes over from the normal transmitting−receiving mode into a sleep mode, in which sleep mode no beacon signals and/or other radio frequency signals are transmitted from the base station.“

[2] www.europarl.europa.eu/doceo/document/E-9-2023-002036_EN.html

[3] www.europarl.europa.eu/doceo/document/E-9-2023-002036-ASW_EN.html

Best regards
Europeans for Safe Connections
This feedback was sent from a wired internet connection
– No use of harmful radiation
– Less electricity consumption
– Increased data security

The link to our feedback: ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14610-Activation-of-EU-rules-on-radio-equipment-for-reconfigurable-radio-systems/F3555153_en

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