A few weeks ago, our Wi-Fi world was shaken to its foundations. In October we learned that the introduction of a new EU Radio Equipment Directive (RED 2014/53/EC) for radio products is threatening to cause a complete blockade to market access of Wi-Fi products from mid-2017.
If the current situation does not change, the consequences will be devastating. We as manufacturers will no longer be able to deliver legal products to the market, retailers will be unable to obtain Wi-Fi access points and routers, and the entire supply chain to the customer will collapse. This unbearable situation has recently been addressed in an open letter to the EU commission by DIGITALEUROPE Director General John Higgins (Link to PDF) and another one by ORGALIME (Link to PDF).
Directives and standards
But one thing after the other: In 2014, the EU adopted the new “Radio Equipment Directive – RED” (2014/53/EC). The directive came into force in the middle of this year, although until mid-2017 there remains a transitional period away from the previous directive R&TTE (1999/5/EC).
From June 13, 2017, however, only devices with wireless interfaces that fully meet the RED specifications are permitted to go on sale—and this includes wireless LAN equipment.
The RED is based on some new underlying ideas, which we very much welcome. Among others, these include a more efficient use of the radio spectrum. Implementing this demands new norms and standards that define the required specifications. Consequently, the standardisation bodies were commissioned by the European Commission in mid-2015 to revise a large number of standards. The technical jargon for this is “harmonization”.
Delays with dramatic consequences
In the meantime it has become clear that many of the necessary standards will not be ready in time, including some that are absolutely necessary for developing CE-compliant Wi-Fi products. One example is the EN 301 893 standard for the 5-GHz band, which according to ETSI will be complete only in 2018—around 8 months after the RED comes into force.
The consequences for us manufacturers are devastating. Without harmonized standards, we are unable to guarantee the RED-compliant development of our Wi-Fi products. It is also impossible for us to use internal tests and production controls as a basis for our declarations of conformity, now a common practice since the introduction of the previous R&TTE directive in 1995. Products cannot be marketed without a declaration of conformity. Access to the market is blocked.
It gets worse
And if you think that this only affects new developments, you’d be wrong. With the mandatory application of the “Radio Equipment Directive”, even those radio products that have been legally marketed under R&TTE for years must be re-assessed. This threatens not only to delay new developments in Wi-Fi, including the exciting new 802.11ac Wave II, but also to block the market access of any Wi-Fi products at all. All over Europe!
However, Wi-Fi products represent only a small proportion of the technologies concerned. Also under threat are countless other radio products, from smartphones and wireless microphones to the DVB-T2 antennas required for digital terrestrial TV reception from March 2017. The overall extent: massive! The economic damage? Probably billions. Countermeasures at EU level? There’s nothing in sight.
The supposed way out
Apparently it was only after issuing the standardization mandates that the EU Commission was for the first time informed that the transition period would be too short for a timely harmonization of all the necessary standards. Since then, associations and enterprises have been lobbying Brussels ever more intensively, unfortunately without success so far. Even the national regulators approached the EU Commission some months ago with a whole series of proposals on how to correct the problem. They too were stonewalled.
The EU Commission is happy to point out that there is a second way—next to the self-declaration of conformity—for manufacturers to verify the conformity of their products: namely to approach a Notified Body (NB). Their opinion is that there is a way to legally deliver products to the market even without standards in place.
A Notified Body can be commissioned by a manufacturer to assess a product’s compliance. Theoretically, the NB could do this even in the absence of harmonized standards. Just how this would work is unclear.
The real problem, however, is the available capacity. Throughout the whole of Europe there are only about four dozen NBs for this type of product. They would be unable to test thousands of radio products in such a short time—which they already clearly communicated to the EU Commission back in October. They lack suitable personnel and test equipment.
But even if this path were open to us, it would be very laborious, time-consuming, and expensive. Each radio product has to be assessed separately, and every software update requires a re-assessment. In particular smaller manufacturers with a wide range of Wi-Fi products and short software-update cycles would face an extreme financial burden.
What to do
Weighing up the possibilities quickly makes one thing clear: It is naive to believe that the standardization bodies could simply “hurry up” and harmonise the standards in time. Here, too, there simply are no capacities, and the delay is already too long. What’s more, the assessment by the European Commission even of the standards that are already complete takes an extremely long time. Right now almost 80 standards await approval by Brussels.
If the standardisation process cannot be accelerated, we have to take another approach and look at the directive itself. More specifically: the transitional period.
EU Commission must react
When the RED was adopted, the transition period was set to a year, which ends on June 12, 2017. Even today we foresee that some standards will be ready at the earliest in 2018, so the transitional period must be extended by one or better two years. This is the only way to resolve the situation that is so critical to the market as a whole and the companies that depend on it.
So, the ball is once again in the court of the EU Commission. They are the only ones who can instigate a change to the directive. As yet it is unclear whether they can be convinced. So far, all of the warnings by industry associations, standardisation institutes, Notified Bodies and governments have been ignored by the Commission. We, too, have joined with other manufacturers to persuade Brussels to extend the transition period—we are still waiting for a response.
If the EU Commission does not relent, it knowingly accepts that the European Wi-Fi and radio products market will completely implode, which for the manufacturers of Wi-Fi infrastructure products alone is likely to lead to damage amounting to several hundred million Euros every month. That is not to mention the losses in retail, for system integrators, and industries relying on wireless infrastructures.
The clock is ticking
The countdown is running. This pre-programmed market collapse is just six months away. But that does not mean that the Commission can take half a year to take their decision. Just the opposite: We need the assurance now that they will extend the transition period.
If the extension comes too late, we need to do all we can right now to make at least some products RED compliant, even in the absence of harmonised standards. Whether we can succeed is written in the stars. The biggest loser is already clear: progress. There would simply be no time for any real innovation.
We need a decision. Now. This is the only way to safely avert the impending total loss in the European Wi-Fi market.