November 17, 2025

EU Cyber Resilience Act (CRA): A Didactic Guide for Manufacturers

The EU Cyber Resilience Act (CRA) introduces new mandatory cybersecurity rules for any product that has a digital element — software, hardware, connected devices, IoT, industrial systems, etc.

If you manufacture anything that runs software, this concerns you.

The purpose of the CRA is simple:

👉 Make digital products secure throughout their entire life.

To help you comply, here is a step-by-step approach‍

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1. First Step: Understand Whether Your Products Are in Scope

A product is covered by the CRA if it has:

  • Software
  • Connectivity
  • Embedded electronics
  • Ability to communicate with networks or other devices

This covers most modern products, from routers to smart washing machines, industrial controllers, apps, medical devices, and AI-driven equipment.

Manufacturers must:

  • List all their products with digital elements
  • Group them into “risk classes” (default, important, critical)

Why this matters:
Higher-risk products will require stricter assessments.

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2. Build Security Into the Product From the Beginning

The CRA is based on two ideas:

  1. Secure by design → security must be built into the architecture and development
  2. Secure by default → when a user opens the box, the product must already be secure

To achieve this, manufacturers must adopt:

✔ Secure software development practices

(threat modelling, secure coding, code reviews)

✔ Regular testing

(penetration testing, fuzz testing, vulnerability scans)

✔ Safe default settings

(no weak passwords, limit unnecessary ports, enable encryption)

✔ Documentation of the design choices

(explain how safety and security risks were managed)

Think of it as:
“Would this product be safe if a non-expert installed it without reading the manual?”
If the answer is no, it fails CRA expectations.

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3. Create a Strong Vulnerability Management Process

This is one of the core obligations of the CRA.

Manufacturers must have the ability to:

  • Monitor new vulnerabilities
  • Fix vulnerabilities quickly
  • Provide signed and secure updates
  • Maintain an SBOM (Software Bill of Materials)
  • Have a Coordinated Vulnerability Disclosure (CVD) policy

The CRA also introduces mandatory reporting timelines:

⏱️ Within 24 hours → Notify ENISA when a vulnerability is being exploited
⏱️ Within 72 hours → Provide an initial incident report
⏱️ Within 14 days → Provide the root-cause & remediation plan for vulnerabilities
⏱️ Within 1 month → Provide the full technical report for serious incidents

This means manufacturers need:

  • A security team
  • A clear workflow
  • Monitoring tools
  • Internal responsibility for reporting

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4. Prepare Documentation (this is mandatory!)

Manufacturers must prepare and maintain:

  • A security risk assessment for each product
  • Technical documentation showing how they meet CRA requirements
  • A Software Bill of Materials (SBOM)
  • User instructions on:
    • how to configure the product securely
    • how to update it
    • how to decommission it safely

This documentation will be checked during audits.

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5. Plan for the Entire Product Lifecycle

CRA requires manufacturers to clearly state:

  • How long they will provide security updates
  • How they will support the product
  • How users will get security patches

This period must be realistic — you cannot say “1 year” for a product that lasts 10 years.

Lifecycle responsibility is a major change:
You are responsible as long as the product is “alive” in the market.

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6. Prepare for Conformity Assessment (CE Mark)

To sell in the EU, products must meet CRA requirements and obtain CE marking.

There are two types of assessment:

1. Self-assessment (for lower-risk products)

The manufacturer verifies compliance and signs the Declaration of Conformity.

2. Third-party assessment (for important/critical products)

A Notified Body must review your product and processes.

Manufacturers must plan early because Notified Bodies will have long waiting lists.

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CRA Deadlines

Here is the timeline in a simple, visual way:

🔹 10 December 2024 — CRA enters into force

This is when the regulation became official.
Manufacturers can start preparing, but nothing is mandatory yet.

🔹 11 September 2026 — EARLY OBLIGATIONS BEGIN

These apply before the full CRA:

What starts in 2026:

  • You must report exploited vulnerabilities within 24 hours
  • You must follow the mandatory incident reporting timelines
  • You must have a vulnerability management process in place

This is the “early warning system” part of CRA.

🔹 11 December 2027 — FULL CRA COMPLIANCE BECOMES MANDATORY

From this date, manufacturers must comply with:

  • Secure-by-design requirements
  • Secure-by-default requirements
  • Lifecycle support obligations
  • Documentation obligations
  • Conformity assessment (self-assessment or third-party)
  • CE marking under CRA

If a product is not compliant after this date, it cannot be placed on the EU market.

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