argante Please note that Wi-Fi uses radio waves to transmit data. I agree that this regulation could make it impossible to unlock the bootloader. If there's any uncertainty, it's done to minimize the risk.
I think many are aware of that. I am even professionally aware of that.
But the directive does not say that all risk must be reduced, bootloaders must be locked, etc. And in fact it very clearly contemplates installable software. Here is paragraph 16 of the "whereas" section of the document, with emphasis added:
The compliance of some categories of radio equipment with the essential requirements set out in this Directive may be affected by the inclusion of software or modification of its existing software. The user, the radio equipment or a third party should only be able to load software into the radio equipment where this does not compromise the subsequent compliance of that radio equipment with the applicable essential requirements.
The authors of the Directive very clearly understand that end users load software into radios, and are explicitly ok with end users loading software into radios as long as appropriate results are achieved.
But there's more! Paragraph 19, again with my emphasis added:
Verification by radio equipment of the compliance of its combination with software should not be abused in order to prevent its use with software provided by independent parties.
So the authors of the Directive would actually prefer for radio manufacturers to allow end users to install software that wasn't written by the manufacturer.
I think if anybody wants to argue that this Directive will require cellular handset manufacturers to lock bootloaders then it would be good for such a party to read the whole document and present an argument based on the entire document (including not just the "whereas" clauses but the text of the Articles, which are the parts that are the most directly operative).