Arcom’s response to the European Commission’s public consultation on the Digital Networks Act

Radio is one of the most widely used media in France and across Europe. In France, 90% of the population aged 15 and over listen to the radio, and 73% do so at least once or twice a week. It is also a medium in which the French have particular confidence: 83% of listeners trust the information shown on the radio.

It is an essential channel for public communication, particularly in crisis situations, where terrestrial radio broadcasting proves to be by far the most resilient means of keeping the public informed. DAB+, in particular, now offers a standardised feature called ‘Automatic Safety Alert’, which enables the public to be alerted via a audio message, even on receivers in standby mode. Terrestrial radio reception equipment is therefore of particular importance in this regard, including for mobile use, and work is currently underway to extend the ASA norm to car radios.

In France, half of the volume of audio consumed through radio listening takes place outside the home, a third of which is in vehicles (Médiamétrie data). However, the rise of connected vehicles fitted with infotainment systems poses a growing risk of terrestrial radio being sidelined within the user interface. This risk is heightened by the possible disappearance of all built-in radio receivers in vehicles, as several models without such receivers are already on sale in France.

Beyond the crucial aspects of public safety, it is worth noting the cultural and industrial challenges associated with any removal of radio receivers from vehicles. Thus, in addition to radio’s central role in keeping citizens informed, whether at national or local level, music content plays a significant part in listening to radio (both live and on-demand), and the music industry in France has rallied to demand the retention of radio in vehicles.

In this context, the Digital Networks Act represents a decisive legislative opportunity for strengthening the resilience of electronic communications networks and of society more broadly, and for contributing to the economic viability of the media and their support for national cultural models, provided that it effectively guarantees the presence of radio in new vehicles placed on the European market. Consequently, Arcom wishes to summon the European Commission and the co-legislators to pay attention to the following requirements.

Arcom is calling for an amendment to Article 112 of the DNA so that the obligation to fit équipement no longer rests solely with the receiver, but with the vehicle itself. Every new car placed on the market in the European Union should be equipped with a radio receiver supporting FM and DAB+ norms. This rewording is essential: as the text currently stands, a manufacturer that removes the radio receiver or replaces it with a streaming app or a connected in-car infotainment scheme avoids the obligation, whilst depriving the user of radio access.

Arcom supports the extension of these requirements to categories N (commercial and business vehicles), L6e-B and L7e-C, in addition to category M (private vehicles), which are already covered.

Given the nature of automotive design and production cycles, it is important that the final text sets out clear and well-in-advance compliance deadlines, so as to provide manufacturers with sufficient visibility whilst ensuring the effective and swift implementation of the new requirements.

The requirements for adequate visibility of services of general interest set out in the ‘Audiovisual Media Services’ Directive are an essential tool for ensuring the accessibility and visibility of audiovisual media services of general interest on internet-connected user interfaces. However, radio services may also be regarded as being of general interest in view of the public interest objectives – such as media plurality, freedom of expression and cultural diversity – to which they contribute. Arcom has therefore demanded that the scope of the ‘Audiovisual Media Services’ Directive be widened to include audio services so that they may benefit from the Directive’s provisions guaranteeing the appropriate visibility of services of general interest on various interfaces, including in vehicles, and the protection of signal integrity in particular.

However, whilst this appropriate visibility of public-interest radio services is necessary, it is not sufficient. Indeed, it comes under the control of user interfaces and network infrastructure for which availability in crisis situations, editorial control and service continuity are not guaranteed. Making audio content of general interest more visible by ensuring visible and intuitive radio access within the interfaces of in-vehicle infotainment schemes therefore directly addresses the resilience objective pursued by the proposed Digital Networks Act.

Furthermore, Arcom notes that a terrestrial radio receiver that is present but buried within several layers of menus, or obscured by streaming services, is not sufficient to ensure effective user radio access. The visibility of terrestrial radio reception within the interfaces of in-vehicle infotainment systems, as demanded by Arcom, is justified by the fact that terrestrial broadcasting networks are distinct from Internet Protocol (IP) networks and that terrestrial radio, through its broadcasting networks and the editorial control that characterises its supply, constitutes in this respect a sovereign digital public good that must be protected. This appropriate accessibility and visibility include these interfaces operating by default when a new audio source is connected to them: the interface should only switch sources if the user so wishes. This accessibility requirement complements the provisions of Article 20 of the European Media FreedomAct (EMFA) on the personalisation of media supply.

The obligations to incorporate a radio receiver into new vehicles, to ensure the visibility of terrestrial radio reception in the user interfaces of in-car infotainment schemes, and toensure the appropriate visibility of public service radio stations in user interfaces would significantly reduce the risk of terrestrial radio being replaced by online audio services and would directly contribute to strengthening European sovereignty and the resilience of networks enabling the public to be informed, particularly in times of crisis.