You are probably aware of significant problems with the implementation of the RE-D (Radio Equipment Directive, 2014/53/EU). If not addressed this will result in products that are the foundation of the digital economy no longer being available after June 2017. I fear this could have real economic and political consequences.
Manufacturers typically need at least one or ideally two years to design and test products to meet a directive such as this. The European co-legislators recognised this and agreed on a transition period from June 2016 to June 2017 (art. 48) which was designed to allow manufactures time to build and test products to over 200 Harmonised Standards (HS) upon which compliance with the RE-D depends. Today, at almost the mid-point in this transition period, only 23 out of these standards have been published in the Official Journal.
Uncertainty regarding compliance with their legal obligations will affect companies’ decisions. It may not only stop firms placing on the market new products that rely on wireless communications, but also prevent them from selling potentially compliant versions of existing smart products; products that use, for example, Wi-Fi, GPS or Bluetooth.
Clearly we need a solution soon. We see no option but to allow industry at least one but ideally two extra years from June 2017 to comply with the RE-D. We have of course raised this with your services and cabinet but we now feel, along with many other industry associations, that this needs to be brought to your personal attention. I will of course make sure that other commissioners deeply involved with the digital economy and better regulation are aware of this problem too, in case you need to draw on their support.
You can of course depend upon us to work with you and your staff and others to help resolve this problem to the best of our ability.
We look forward to hearing from you in due course.