Protest against the EU radio lockdown(blog.mehl.mx)
blog.mehl.mx
Protest against the EU radio lockdown
https://blog.mehl.mx/2019/protect-freedom-on-radio-devices-raise-your-voice-today/
78 comments
I haven't read the EU proposal, but for the corresponding US rule, the motivation was to reduce interference with other radio users. In many of these products, the radio is capable of frequencies, power levels, and modulation modes that are not legal, and the device relies entirely on the firmware not choosing an illegal combination to stay legal. People have used third party firmware to allow choosing illegal radio settings.
The regulations were written in the US to be compatible with open source and customization, only requiring that outside software not be able to set the radio to transmit outside the legal limits that applied to that type of device.
A router manufacturer does not have to lock down all the firmware to satisfy this. They can make it so that the "set radio parameters" part of the firmware is separate from the rest, with only the former being restricted. This is the approach the FCC encourages, rather than simply locking down the whole thing.
In fact, when TP-Link was making routers that could operate outside legal power levels, and the FCC went after them, the consent decree they agreed to required TP-Link to work with OpenWrt and the radio chipset manufacturers to ensure that they could build compliant routers without locking out third party firmware.
The regulations were written in the US to be compatible with open source and customization, only requiring that outside software not be able to set the radio to transmit outside the legal limits that applied to that type of device.
A router manufacturer does not have to lock down all the firmware to satisfy this. They can make it so that the "set radio parameters" part of the firmware is separate from the rest, with only the former being restricted. This is the approach the FCC encourages, rather than simply locking down the whole thing.
In fact, when TP-Link was making routers that could operate outside legal power levels, and the FCC went after them, the consent decree they agreed to required TP-Link to work with OpenWrt and the radio chipset manufacturers to ensure that they could build compliant routers without locking out third party firmware.
Basically the EU has discovered SDR (Software Defined Radio) and wants to limit its use.
The usual excuses are given, electrical safety, emission on protected bands...
The usual excuses are given, electrical safety, emission on protected bands...
Right, but why would they want to regulate SDR?
maybe because they can be used for many nefarious purposes?
So can wheels.
You shouldn't ban general purpose technology because of particular bad uses.
You shouldn't ban general purpose technology because of particular bad uses.
I agree with you, but for anyone following EU rules and regulations, this ship has sailed a long time ago. Drugs, guns, radio are just part of a huge long list of "general purpose technology" that have been regulated out of existence.
That sounds like a hot take. I'm pretty sure most EU residents are very satisfied that they don't have to fea for their safety for gun violence when they walk home late at night or just in general.
>don't have to fea for their safety for gun violence when they walk home late at night or just in general.
Neither do "most US residents".
More to the point, your focus on guns is missing the larger point. There is very real and immediate dissatisfaction with the EU regulatory landscape. See: Brexit.
Neither do "most US residents".
More to the point, your focus on guns is missing the larger point. There is very real and immediate dissatisfaction with the EU regulatory landscape. See: Brexit.
A lot of general purpose technologies are restricted to safe use.
Restricting it to safe use is what the preexisting law does.
“Regulate” != “Ban”
And in this case, the proposed regulation is:
“””[R]adio equipment [shall support] certain features in order to ensure that software can only be loaded into the radio equipment where the compliance of the combination of the radio equipment and software has been demonstrated.”””
Now I don’t think that’s a well written rule, but my problem is the specifics rather than the general idea. I think that either all broadcasts should be digitally signed, or it should not be possible for hackers to remotely modify many other people’s radios to broadcast false signals. (One-on-one modifications I don’t care about so much, but how do you write/pass such rules, given the difficulty getting people to care about or believe the scale difference between automated and manual hacking?)
And in this case, the proposed regulation is:
“””[R]adio equipment [shall support] certain features in order to ensure that software can only be loaded into the radio equipment where the compliance of the combination of the radio equipment and software has been demonstrated.”””
Now I don’t think that’s a well written rule, but my problem is the specifics rather than the general idea. I think that either all broadcasts should be digitally signed, or it should not be possible for hackers to remotely modify many other people’s radios to broadcast false signals. (One-on-one modifications I don’t care about so much, but how do you write/pass such rules, given the difficulty getting people to care about or believe the scale difference between automated and manual hacking?)
The problem is that we already have regulations to avoid broadcasting on restricted/licensed bands.
In general, current regulation makes the owner of the equipment responsible for the broadcast.
This new regulation will just stifle development on SDR technologies
In general, current regulation makes the owner of the equipment responsible for the broadcast.
This new regulation will just stifle development on SDR technologies
And the current regulations are impossible to enforce. If they would work we wouldn’t be in this situation.
> If they would work we wouldn’t be in this situation.
What situation? What crisis is happening I'm completely missing?
What situation? What crisis is happening I'm completely missing?
> “Regulate” != “Ban”
Imagine how ridiculous it would be to have a regulation on wheels that they must try to prevent being installed on non-approved devices.
Imagine how ridiculous it would be to have a regulation on wheels that they must try to prevent being installed on non-approved devices.
[deleted]
Like what? I'm not being flippant here, I'm really in the dark. What harm can one do with an SDR, and how does the potential for abuse compare to e.g. a cell phone?
FUD. Fear, uncertainty, doubt
That's how. The question is "what problem do they think they're solving"?
The availability of easily-hackable, low-cost Chinese hardware?
I'm not as familiar with EU law, but similar changes in the US were prompted by "Import hardware configured legally, but manufacturer winks / doesn't care about flashes to illegal specifications" scenarios (indeed, it may be a way to boost sales).
The correct legislative solution seems to mandate locked RF firmware... while also mandating customer access to tinker with the remainder of functionality.
This addresses the tendency for manufacturers to simply lock down everything as the cheapest path to legal compliance.
TBH, if you want a right to tinker with RF firmware, a ham (or equivalent) license seems a low (probably too low) but necessary and fair burden.
I'm not as familiar with EU law, but similar changes in the US were prompted by "Import hardware configured legally, but manufacturer winks / doesn't care about flashes to illegal specifications" scenarios (indeed, it may be a way to boost sales).
The correct legislative solution seems to mandate locked RF firmware... while also mandating customer access to tinker with the remainder of functionality.
This addresses the tendency for manufacturers to simply lock down everything as the cheapest path to legal compliance.
TBH, if you want a right to tinker with RF firmware, a ham (or equivalent) license seems a low (probably too low) but necessary and fair burden.
Disclaimer: Automated hardware unit tests and test devices, including RF tests for firmware developers, are bringing bread to my table.
Looking at this rule from another angle, I think the objective is to have a single entity to blame if interfering device is found. In this context this may seem rational -- all the firmware released that is mangling with intentional radiators needs to be tested to prove it is compliant. However, the method creates extra complexity for the device manufacturers and as time has shown -- does not really improve the matters in the long term, you will just get a fleet of devices running old firmware with unfixed bugs. Manufacturers often do not like it either, specially in the management.
I think it may be a classical example of "The road to hell is paved with good intentions" or Hanlon's razor*
* https://en.wikipedia.org/wiki/Hanlon%27s_razor
Looking at this rule from another angle, I think the objective is to have a single entity to blame if interfering device is found. In this context this may seem rational -- all the firmware released that is mangling with intentional radiators needs to be tested to prove it is compliant. However, the method creates extra complexity for the device manufacturers and as time has shown -- does not really improve the matters in the long term, you will just get a fleet of devices running old firmware with unfixed bugs. Manufacturers often do not like it either, specially in the management.
I think it may be a classical example of "The road to hell is paved with good intentions" or Hanlon's razor*
* https://en.wikipedia.org/wiki/Hanlon%27s_razor
Allowed frequencies and transmit power varies in the world, so the cheapest way sell to all markets is to set a few different bits in firmware to make it fit for those regulations. That could be a factor.
This is what this change is about. It follows similar regulations in the US, btw. Smartphones should be mostly fine if the radios are controlled entirely by the baseband. Then changing the main OS cannot have any effect on the compliance of the device.
[deleted]
[deleted]
Also this feels like an ugly interaction with the right to repair. Old devices will become even harder to update and patch due to legal requirements.
We have existing regulations stating what is allowed on which frequencies.
Is there evidence that the devices prohibited by the proposal lead to widescale breaking of these regulations? And if so, is there evidence that this causes harm?
It's harsh to assume that people can not be trusted with SDRs and therefore we should ban them outright. I'd like these sorts of blanket bans to come with a strong evidence backed reason.
I am currently in the process of a obtaining a ham radio license specifically so I can experiment and innovate with SDRs and IOTs and be confident that I do so in compliance with the regulations. This proposal will make it much harder for ham radio enthusiasts and innovators to experiment and learn in a compliant way.
^ Above submitted as feedback
Is there evidence that the devices prohibited by the proposal lead to widescale breaking of these regulations? And if so, is there evidence that this causes harm?
It's harsh to assume that people can not be trusted with SDRs and therefore we should ban them outright. I'd like these sorts of blanket bans to come with a strong evidence backed reason.
I am currently in the process of a obtaining a ham radio license specifically so I can experiment and innovate with SDRs and IOTs and be confident that I do so in compliance with the regulations. This proposal will make it much harder for ham radio enthusiasts and innovators to experiment and learn in a compliant way.
^ Above submitted as feedback
> Is there evidence that these devices lead to widescale breaking of these regulations? And if so, is there evidence that this causes harm?
Yes there is. A lot of people now import devices from countries with different frequencies causing a mess. This is especially a problem if frequencies are used for other purposes.
Yes there is. A lot of people now import devices from countries with different frequencies causing a mess. This is especially a problem if frequencies are used for other purposes.
> A lot of people now import devices from countries with different frequencies causing a mess.
If they are already using devices that are not compliant with EU regulations, then I don't see how stricter regulations would solve this. This sounds like an enforcement issue. What prevents people from importing the very same non-compliant devices under the proposed regulations?
In fact, I can see more of this import happening as the domestic devices will now be more expensive and crippled.
If they are already using devices that are not compliant with EU regulations, then I don't see how stricter regulations would solve this. This sounds like an enforcement issue. What prevents people from importing the very same non-compliant devices under the proposed regulations?
In fact, I can see more of this import happening as the domestic devices will now be more expensive and crippled.
You could destroy such devices at customs inspection. Currently such devices are legal. The use outside of the legal frequencies is not and enforcement is almost impossible.
It would be much easier to protest for the creation of a law that punishes the attempt to create or the creation of bad laws. After all when you propose a bad law, you can just propose it again and again and again until it gets implemented, then good luck getting rid of it.
As for "how do you define bad laws?". We know it's possible because we have constitutions. We know they can be expanded. We know it's possible to get people jailed if they violate rules, and legislators are people even if they tend to forget this little detail.
As for "but what about evil corporation that will not be stopped by the law?". Well, even corporation is the one that usually wants more laws and even discuss the laws that should stop them.
If you want any semblance of freedom under a State you need a way to make legislators think very long before legislating.
As for "how do you define bad laws?". We know it's possible because we have constitutions. We know they can be expanded. We know it's possible to get people jailed if they violate rules, and legislators are people even if they tend to forget this little detail.
As for "but what about evil corporation that will not be stopped by the law?". Well, even corporation is the one that usually wants more laws and even discuss the laws that should stop them.
If you want any semblance of freedom under a State you need a way to make legislators think very long before legislating.
Reminds me of the ongoing fight over crypto-legislation.
"They only have to win once, you have to be vigilant and win every single time"
I also suspect that the current patent mess is a result of failing to win the continual defensive battle.
I'd be interested to hear from any law or political theorists regarding this seemingly deep flaw in the system. What could be done to mitigate it? How do we stop the same bad laws being proposed in slightly different forms again and again when vested interests combine with a poorly informed legislature?
"They only have to win once, you have to be vigilant and win every single time"
I also suspect that the current patent mess is a result of failing to win the continual defensive battle.
I'd be interested to hear from any law or political theorists regarding this seemingly deep flaw in the system. What could be done to mitigate it? How do we stop the same bad laws being proposed in slightly different forms again and again when vested interests combine with a poorly informed legislature?
>They only have to win once, you have to be vigilant and win every single time
The law is not a blockchain ledger. If bad law gets in, it can also get removed later.
The law is not a blockchain ledger. If bad law gets in, it can also get removed later.
It can be but it's an uphill battle the entire way and opponents try to shame crypto supporters with the Four Horsemen of the Crypto Apocalypse: Terrorists, Child Pornographers, Tax Evaders and Those Who Have Something To Hide.
Any objection to government surveillance is met with "Well you must be a member of or support the activities of" one or more members of the aforementioned groups. It's better to never let a bad law in than remove it later because people are irrational and bring these emotional arguments into play.
Any objection to government surveillance is met with "Well you must be a member of or support the activities of" one or more members of the aforementioned groups. It's better to never let a bad law in than remove it later because people are irrational and bring these emotional arguments into play.
That takes a long time. In USA we've been trying to end drug prohibition for decades.
That's because there's a big amount of people, myself included, who feel like drug prohibition is good, all things considered. Not because "editing" the law is hard. (I am not American).
That doesn't make the situation different. All of these bad laws have supporters. (Largely because charlatans in government, law enforcement, and media constantly exaggerate dangers, but that's beside the point.)
That's not so easy for EU laws. The only body that can propose new EU laws is the European Commission, which ordinary voters have essentially no influence over. (Some of the non-EU Europe-wide bodies are even worse.)
But how can groups debate if a law is good or bad, isn't proposing such a law the way the debate is started? Maybe some bad laws have good intentions but some poor wording can have bad consequences.
Also why do we think constitutions are perfect, don't countries have to update them periodically to fix them?
Also why do we think constitutions are perfect, don't countries have to update them periodically to fix them?
Then let courts take stated intent of lawmakers into account and throw out cases where the application of the law is different from the stated intent.
I am not an expert, but I see a problem with this idea too, the lawmaker will need to also write what the intention is, then you can find loopholes in the text of what the intention is. or the intention could be very general so ambiguous to interpret. In some countries there is a way for the people to contest laws as unconstitutional and have judges not politicians decide.
the issue is the usual: eu is so far removed from constituents it's pointless to try and save it.
After a quick read, the amendment in this directive seems far too general to be enforced effectively. If you parse it with the FOSS principles and revoking the ability to flash or install LineageOS, OpenWRT, Tasmota etc., it is counter-intuitive to some of the principles empowering consumers e.g. restricting locked bootloaders by carriers.
If passed into law, it might make a test-case for sales of rogue drones but it won't be able to stop Baofeng handsets flooding a market. The EU needs reminding that restricting freedom in this way is a terrible idea.
If passed into law, it might make a test-case for sales of rogue drones but it won't be able to stop Baofeng handsets flooding a market. The EU needs reminding that restricting freedom in this way is a terrible idea.
Who in their right mind is thinking up of these stupid rules? Are they aware of the world around them? I assume no :-(
If this is approved, I expect a few other similar laws to protect the "common good". Car manufacturers should verify and approve all possible combinations of modifications. You shouldn't be able to increase your horsepower (and possibly kill more people), surely the car manufacturer should take the blame and responsiblity for whatever you do with your car ;-)
As a matter of fact our good EU government (overlords) should regulate and ban whatever is not safe for us, they know better.
Being in EU, I'm going to add my comment to the official link provided in the OP blog post and I encourage everyone in the EU to do the same.
If this is approved, I expect a few other similar laws to protect the "common good". Car manufacturers should verify and approve all possible combinations of modifications. You shouldn't be able to increase your horsepower (and possibly kill more people), surely the car manufacturer should take the blame and responsiblity for whatever you do with your car ;-)
As a matter of fact our good EU government (overlords) should regulate and ban whatever is not safe for us, they know better.
Being in EU, I'm going to add my comment to the official link provided in the OP blog post and I encourage everyone in the EU to do the same.
The are going to be mandating GPS based speed limiters on all new vehicles for the EU, as has been reported recently.
https://www.forbes.com/sites/carltonreid/2019/02/27/all-new-...
https://www.forbes.com/sites/carltonreid/2019/02/27/all-new-...
This is bad for many reasons
* Security, device manufacturers stop supporting updates after a certain while
* The environment, lots of devices will become obsolete with no software updates. Free software provides such updates. This will contribute bad towards global warming.
* Being able to experiment with hardware you own and run open source.
I remember that the FCC has a similar requirement, and that was one of the issues behind "no open source drivers for wifi modules"
This shouldn't affect OpenWRT if it uses a standard driver, unless I'm mistaken (or "radio equipment" means the whole thing and not just the radio module - but that's up to debate)
This shouldn't affect OpenWRT if it uses a standard driver, unless I'm mistaken (or "radio equipment" means the whole thing and not just the radio module - but that's up to debate)
> I remember that the FCC has a similar requirement...
Which is better IMHO.
You can sue the FCC if you think they overstepped their bounds as opposed to getting a bunch of politicians behind the repeal of a bad law (which otherwise can only be overturned if it violates the constitution).
Or, as sometimes happens, the FCC realizes they made a mistake and/or "conditions on the ground" change and they decide to change the requirements -- also without involving the lawmakers.
Which is better IMHO.
You can sue the FCC if you think they overstepped their bounds as opposed to getting a bunch of politicians behind the repeal of a bad law (which otherwise can only be overturned if it violates the constitution).
Or, as sometimes happens, the FCC realizes they made a mistake and/or "conditions on the ground" change and they decide to change the requirements -- also without involving the lawmakers.
You're probably right, and the FCC is more technically competent
[deleted]
the eu is really on a streak with counterproductive legislature atm
Does the Raspberry PI count as IOT?
Crazy.
Crazy.
faissaloo(2)
ycombonator(1)
Are the national governments pushing for more radio control? Is there some kind of crisis of radio abuse? Or is it an indirect way to give governments more punishment tools, by making radio modification a subversion of manufacturer controls, so you can be slapped with an additional charge if you ever use a custom radio device in a crime?