This can be regarded as a potential issue for replacing the initial Firmware with OpenWRT, because manufacturers might decide to comply with article 3(3)i by making it hard to replace their firmware (locked-down hardware). TP-Link did so in the past when they tried to be more FCC compliant Example: Routers affected by FCC restrictions
The relevant article says:
- Radio equipment within certain categories or classes shall be so constructed that it complies with the following essential requirements:
(i) radio equipment supports 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.
Mostly, we might cause non-compliance because OpenWRT might allow users to exceed TX-power or devices might not correctly apply DFS (~radar detection). The difference to the original-manufacturers-compliance is not large and this might reduce our efforts if we just need to show OpenWRT does not invalidate the original-manufacturers-decalartion-of-conformity.
Whats the long term strategy for us?
- Simply ignore and rely on unlocking hardware?
- Offer regional builds that comply with the relevant regulation?
- Reach out and cooperate with manufacturers?
I am pretty sure, ignoring this topic will put us in a bad, defensive position and might lead to Regulators constraining us, so that's probably not a long term solution.
We as individuals are IMHO allowed to replace firmware as long as we do not cause interference. But this is not so easy anymore if OpenWRT is to be used in a commercial setup. More important: original-manufacturers might decide they need to lock us out, thus giving us a hard time reusing and improving their hardware.
I am interested in your opinions. What can we do?