There is no need for hard legislation on reconfigurable radio systems. This is essentially the message FEM conveyed in its reply to the Commission’s public consultation on the topic. This consultation is part of the impact assessment currently carried out by the European Commission and investigating the possible impacts of different policy options to ensure that Reconfigurable Radio Systems remain compliant with the RED after new or modified software is installed.
FEM stated that for materials handling products, there were no malfunctions identified for software uploaded into radio equipment by wireless means. Moreover, with regard to the questions related to the policy options and the impact on RED, materials handling manufacturers are supportive of either option 0 (no change to the current situation as there is enough protection in place against the installation of malicious or non- compliant software), or option 1 which consists of a non-legislative measure such as industry self-regulation (via codes of conduct). In contrast, FEM argued against legislative measures such as delegated acts which would increase administrative burdens.
The full FEM response to the consultation can be found at the link below.
https://www.fem-eur.com/wp-content/uploads/2020/09/FEM-reply-RRS-consultation-200911.pdf
