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Cyber Resilience Act
The CRA pursues the following goals:
Ensuring that manufacturers improve the security of products with digital elements from the design and development phase onwards and throughout their entire life cycle.
Ensuring a coherent cybersecurity framework that makes it easier for hardware and software manufacturers to comply with regulations.
Increasing the transparency of the security features of products with digital elements.
Empowering businesses and consumers to use products with digital elements safely.
What does the CRA mean for manufacturers?
Commitment to security by design: Cybersecurity must be considered and implemented throughout the entire planning, design, development, production, delivery, and maintenance phases of products.
Extensive documentation and reporting requirements for vulnerabilities and security incidents to corporate customers, consumers, and the relevant supervisory authorities.
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The regulation primarily affects all products with digital elements. These are classified into three categories by the CRA. The standard category is expected to cover around 90% of all products and comprises commercially available devices and programs with low criticality, such as photo editing software, video games, and smart speakers.
The remaining 10% are products in critical classes I and II, which pose a higher cybersecurity risk. Therefore, special conformity assessment procedures must be applied here, including external assessment by third parties.
Pure software-as-a-service (SaaS) solutions that operate as standalone cloud services are exempt from the CRA. However, “remote processing solutions” fall under the CRA if they are essential to the functionality of a product with digital elements. Non-commercial open-source software is also exempt; commercial FOSS products, on the other hand, are regulated.
Overall, the scope is deliberately broad and includes:
Traditional IT and consumer products such as routers, smart home devices, cameras, wearables, and connected household appliances.
Software products such as operating systems, applications, browsers, VPN clients, security solutions, or cloud software.
Industrial and KRITIS-related systems, such as control systems, network components, OT/ICS solutions, and embedded systems in machines.
Exceptions include certain medical devices, vehicles, aviation products, and open-source software provided free of charge without commercial use.
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The schedule is key to ensuring CRA compliance, as the obligations derived from the regulation are phased in gradually.
June 11, 2026: The rules for notification and the work of conformity assessment bodies (Chapter IV) become applicable. Manufacturers can then have products with digital elements tested by notified bodies.
September 11, 2026: Article 14 (reporting obligations) comes into force; from this date, the 24-hour/72-hour deadlines for reporting actively exploited vulnerabilities and serious incidents apply.
December 11, 2027: The CRA becomes fully applicable; from this date onwards, new products may only be placed on the EU market if they are CRA-compliant. This also applies to newly delivered batches or newly released versions of existing product lines.
For manufacturers, this means that the period until the end of 2027 is effectively a migration period during which development and security processes, product portfolios, and supplier landscapes must be gradually aligned with CRA compliance.
Products with digital elements (products) will only be allowed on the market if they meet the “essential cybersecurity requirements” listed in Section 1 of Annex I of the CRA. These requirements are designed to ensure the security, confidentiality, and integrity of digital products. In doing so, the EU Commission relies on best practices such as encryption, data minimization, and preventive protection against attacks. Example: Products must “ensure the availability of essential functions, including the ability to defend against and mitigate denial-of-service attacks on servers.”