Radio Equipment Directive (RED) Cybersecurity & Privacy Compliance for Open Telemetry Adapter

Regulatory Scope

The Px2 OpenTelemetry Adapter executes on radio equipment incorporating cellular (4G/5G) and Wi Fi radio interfaces and therefore falls under the scope of the Radio Equipment Directive (RED) 2014/53/EU.

In accordance with Delegated Regulation (EU) 2022/30, the cybersecurity-related essential requirements of Articles 3.3(d), 3.3(e), and 3.3(f) are applicable to radio equipment placed on the EU market from 1 August 2025.

This section describes how the OpenTelemetry Adapter design addresses these requirements.

RED Article 3.3(d) – Protection of Networks and Network Resources

Requirement: Radio equipment shall not harm the network or its functioning nor misuse network resources, thereby causing unacceptable degradation of service.

Design Measures Implemented:

  • The adapter exposes network interfaces only when explicitly enabled by configuration.

  • Telemetry export intervals are user-configurable, preventing uncontrolled traffic generation.

  • The OTLP/HTTP exporter implements:

    • Connection reuse (keep-alive).

    • Retry backoff with jitter.

    • Retry caps and cooldown after repeated failures.

  • Non-retriable failures (HTTP 4xx, invalid URLs) immediately suspend export attempts to prevent network misuse.

  • The Prometheus scrape endpoint supports a single, well-defined path (/metrics) and returns errors for invalid access attempts.

Operational Assumptions:

  • The adapter does not automatically modify firewall rules.

  • Access control and network exposure are expected to be restricted according to system deployment guidelines.

These measures ensure the adapter cannot be trivially abused for traffic amplification, scanning, or sustained network misuse, in line with RED Article 3.3(d).

Software Impact on Radio Compliance

The OpenTelemetry Adapter:

  • Does not modify radio parameters..

  • Does not affect spectrum usage

  • Does not alter RF behavior or regulatory characteristics.

The adapter is strictly observational and export-oriented and therefore does not impact compliance with RED Article 3.2 (efficient use of the radio spectrum).