Have your say – Digital Networks Act (stage 5)
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
Digital Networks Act
About this initiative: The initiative aims at improving access to secure, fast, and reliable connectivity for the transition towards cloud-based infrastructure and Artificial Intelligence. To this end, it aims to help boost secure high-speed broadband, both fixed and wireless, and incentivise and encourage investments in digital infrastructure. It builds on the Commission’s White Paper: “How to master Europe’s digital infrastructure needs” adopted on 21 February 2024.
Feedback period: for stage 5 it is 16 February 2026 – 28 April 2026
(our feedback to stage 2 was here: esc-info.eu/have-your-say-digital-networks-act)
Feedback no.1
We « Europeans for Safe Connections » propose amendments in the article 21 Individual rights of use for radio spectrum. We suggest to add points 6 to 11:
6. When granting rights of use for radio spectrum, Member States shall ensure that such rights are subject to the principle of proportionality.
7. Before granting new rights of use for radio spectrum intended for the provision of electronic communications services, competent authorities shall assess whether the deployment of radio-based infrastructure is objectively justified in light of:
(a) the availability of equivalent fixed wired connectivity solutions;
(b) environmental and public health considerations;
(c) the principle of minimising unnecessary exposure to electromagnetic fields.
8. Rights of use shall only be granted where the use of radio spectrum constitutes a necessary and proportionate means to achieve the connectivity objective pursued.
9. Member States may designate sensitive public health zones, including schools, hospitals, childcare facilities and long-term care institutions.
10. In such zones, competent authorities shall give priority to fixed wired electronic communications infrastructure where technically and economically feasible.
11. The installation of new radio-based infrastructure within designated sensitive zones shall require a specific justification demonstrating that equivalent wired solutions cannot reasonably ensure the required connectivity.
Explanation:
While 5G and 6G technologies exhibit improved spectral efficiency per transmitted bit, this progress is completely overshadowed by a massive rebound effect that aggressively accelerates the total energy demand of globalisation.
Under EU law, the principle of proportionality requires that technological choices be appropriate and necessary. Applied to connectivity policy, this implies that wireless technologies should be deployed where their specific advantages — mobility — are genuinely required.
Wireless networks are inherently designed to support mobile use cases. For fixed, stationary applications, equivalent wired solutions provide higher energy efficiency, greater stability, and lower environmental and health impact. Therefore, fixed wired infrastructure should be prioritised, particularly for static devices and permanent installations.
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: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14709-Digital-Networks-Act/F33376975_en
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Feedback no.2
The three documents provided European Commission (EC) report that the ESC’s specific proposals are not accepted, and for the most part, are not mentioned or reported in the EC documents. While the EC documents acknowledge internal criticisms regarding their impact assessment, the core demands of the ESC regarding health-based restrictions on wireless technology are explicitly contradicted by the Commission’s industrial and technological strategy.
1. Priority of Wired vs. Wireless Connections ESC Proposal (DNA_v5): Demands prioritizing cabled (wired) connections over wireless for stability and health, particularly for children.
EC Response: The EC documents move in the opposite direction. They mandate an EU-wide copper (wired) switch-off by 2030 in areas with 95% fiber coverage. While fiber-to-the-premises (FTTP) is promoted, the EC considers wireless (5G/6G) and satellite connectivity essential for « ubiquitous and seamless » coverage, including for « populated areas ».
Status: Rejected.
2. Restrictions in Sensitive Locations (Schools/Hospitals) ESC Proposal (DNA_v5): Suggests the immediate replacement of wireless with cables in schools, kindergartens, hospitals, and retirement homes.
EC Response: The DNA proposal specifically facilitates the deployment of small-area wireless access points (small cells) on public buildings, streetlamps, and traffic lights. It grants operators the right to access these public sites to meet connectivity demands.
Status: Rejected/Contradicted.
3. Low-Radiation Zones and Biodiversity ESC Proposal (DNA_v5): Proposes low/no radiation zones in municipalities and nature reserves to protect biodiversity and « electrosensitive » persons.
EC Response: The EC documents never mention radiation-free zones or « electrosensitivity. » Instead, the Commission aims for « connectivity for everybody and everywhere in the Union, » including rural, remote, and mountainous regions.
Status: Not mentioned.
4. Comprehensive Health Impact Assessments ESC Proposal (DNA_v5): Demands a comprehensive health impact assessment regarding RF-EMF radiation before auctioning new frequency bands.
EC Response: The Commission maintains that current protections are sufficient. It refers to the precautionary approach defined in Council Recommendation 1999/519/EC as the standard for limiting public exposure to electromagnetic fields. While the Regulatory Scrutiny Board (RSB) did issue a negative opinion and later a positive opinion with reservations on the EC’s Impact Assessment, their critiques focused on economic modeling, lifecycle CO2 emissions, and social inclusion, not the biological health risks of EMF raised by ESC.
Status: Not accepted.
5. Environmental Impact Definition ESC Proposal (DNA_v5): Argues that the Impact Assessment ignores the impact of 5G on biodiversity and human health.
EC Response: The EC frames the environmental impact purely in terms of energy efficiency and CO2 reduction. The Commission claims that 5G/6G networks will lead to a « reduced ecological footprint » because they consume less energy per gigabyte compared to older technologies.
Status: Mentioned as a general « shortcoming » by the RSB (lack of monetized environmental impact), but defined strictly as a climate/carbon issue, not a biological/radiation issue.
6. Privacy and « Cloudification » ESC Proposal (DNA_v5): Warns of an erosion of privacy rights and security vulnerabilities due to shifting data to cloud/edge networks managed by large corporations.
EC Response: The EC explicitly promotes the « cloudification » of 5G and the transition to cloud-based and AI-enabled infrastructures. It views the convergence of networks and cloud/edge computing as a « technological transformation » necessary for EU competitiveness.
Status: Rejected.
We attach also a further proposal of modification of the EC’s proposal
Best regards E.S.C.
The link to our feedback: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14709-Digital-Networks-Act/F33376447_en