The EC's recommendation further states that consumers are entitled to clear and simple information regarding the types of data that will be processed by a particular
RFID application. It also recommends a common European symbol for products carrying RFID tags.
Jimenez says her group is also satisfied with this section of the recommendation, which lays out minimum transparency standards but offers retailers the freedom to choose how to inform consumers—for example, via statements on a Web site, through brochures or on posters. Still, she believes a global symbol denoting the presence of RFID would be better than one for Europe only.
"Manufacturers' supply chains are global," Jimenez says. "The obligation for a European logo may be a burden on them. A global logo is a much better way to go."
Implementing the Recommendation
Within the next two years, EU member states must report on their efforts to meet the terms of the recommendation. Three years from now, the commission intends to analyze the impact its recommendation has had on companies, public entities and EU citizens.
For Barrau, implementation remains the big question mark. If her group could change the recommendation, she says, it would like that recommendation to be "more binding," and to cover more than just data privacy. The group would like for the commission to develop guidance pertaining to the health, environmental and competition concerns that she believes surround RFID.
BEUC wants additional information regarding the cumulative effects of electromagnetic fields on human health, and is concerned that
RFID tag disposal may strain recycling systems since tags are composed of different types of metals and are often embedded in packaging. Finally, the group worries that RFID tags could potentially be used to restrict competition by linking products together, such as printers and proprietary printer cartridges.
"While privacy and security are at the top of the list for consumer concerns," Barrau states, "other areas still need to be addressed."