• European digital SMEs have largely centred business activities around software innovation, making use of third-party hardware to run their software. A certain degree of openness is thereby required from the part of hardware vendors for the sustainability of their business model.
• It is crucial to avoid a very narrow interpretation of the provisions of the Radio Equipment Directive, which would promote proprietary methods and only allow hardware vendor-provided software to be accepted by the hardware.
• Enabling a horizontal market goes beyond competitiveness and allocative efficiency considerations and has considerable ramifications on the circular economy.
• While SBS welcomes the efforts to reduce as much as possible the margin for interpretation via a new approach in the ongoing standardisation work around Article 3.3.(d)(e)(f) of the RED, and calls for it to be maintained in the future work on reconfigurability, it urges the European Commission to not over-prolong the decoupling in timing of the respective delegated acts for Article 3.3.(d)(e)(f) and Articles 3.3.(i) and 4.
• SBS calls for the introduction of a new work item to be put forward in line with the future activation of Articles 3.3.(i) and 4, centred around open standard mechanisms such as asymmetric key and certificate-based authentication.
