Five requirements for navigating Europe’s cybersecurity compliance rules

The European Union’s Cyber Resilience Act, which took effect last year, marked a significant change in how manufacturers in the EU manage cybersecurity for connected products.

As digital parts are included in everything from industrial machines to smart sensors, the CRA creates a consistent framework to make sure these products remain secure during their entire lifecycle.

See also: What manufacturers risk when they try to patch everything

Although certain products already regulated by existing EU laws and open-source software used noncommercially are excluded, the CRA applies broadly to anything from industrial control systems to smart appliances. 

Manufacturers looking to enter the EU market must understand and implement the CRA’s five key requirements. This will help them comply and build customer trust.

Security by default and design

Under the CRA, products and software must have strong security controls included from the start. This "secure-by-design" principle requires manufacturers to:

• Use a threat modeling process during product development to identify potential attack vectors early.
• Implement authentication controls, encrypted communications, and safe defaults instead of depending on end-user configuration.
• Maintain secure software development practices, such as code reviews and automated testing for common vulnerabilities.

Best practices in manufacturing include adding security gates to the release pipeline, training engineers in secure coding, and using hardware root-of-trust features.

Incident management and reporting

The CRA requires in-scope entities to set up strong processes for detecting, managing, and reporting security incidents. Key elements include:

• A clear incident response plan that defines roles, communication channels, and escalation paths.
• Continuous monitoring of device behavior in the field that uses logging, alerting, and anomaly detection.
• A streamlined reporting procedure that notifies EU authorities within strict timelines when a product’s vulnerability poses a significant risk.

Manufacturers should invest in security operations center capabilities tailored to IoT and embedded systems, ensuring rapid triage of vulnerability reports from customers or third parties.

See also: Human intelligence plus AI and how supply chains are changing with this collaboration

Automated dashboards and predefined templates can speed up meeting reporting deadlines, reducing regulatory risk.

Vulnerability management

Effective vulnerability management is key to the CRA’s goal of reducing risk. Manufacturers must:

• Keep an up-to-date record of all software elements, including components, libraries, and firmware versions used within products.
• Perform vulnerability scans and penetration tests periodically to identify security flaws prior to release.
• Provide security updates and patches to customers on time, along with clear instructions and ways to install them.

In manufacturing, this means creating a coordinated vulnerability disclosure program, building relationships with security researchers, and using over-the-air update systems for industrial devices.

By automating patch distribution and checking installation success, organizations can show regulators that important fixes reach end users quickly.

Third-party risk management

Connected products often depend on third-party parts, outside development, or cloud services. The CRA requires manufacturers to take care of every step in the supply chain:

• Vet suppliers and software vendors for their security posture, ensuring they follow standards such as ISO 27001 or IEC 62443.
• Include security requirements in contracts. This should cover responsibilities for patches, incident notifications, and liability.
• Regularly audit the security performance of third parties, verifying compliance with agreed controls.

Large-scale manufacturers can implement a risk rating system for suppliers, scoring them on criteria like past breach history, encryption practices, and responsiveness to vulnerabilities.

See also: New report sees big increases in cybersecurity risks for ICS/OT devices

This data-driven approach helps procurement teams spot high-risk vendors and take action on supply chain weaknesses.

Product risk assessment

The CRA requires that every product go through a detailed risk assessment before and after it is released into the market. This includes:

• Identifying possible threats, ways attackers could strike, and effects on confidentiality, integrity, and availability.
• Classifying products based on their risk profile, such as critical industrial controllers, which demand stricter controls than consumer electronics.
• Periodic review of risk assessments in light of new threat intelligence, software updates, or changes in deployment contexts.

Manufacturers should adopt standardized methodologies such as Failure Mode and Effects Analysis (FMEA) or Common Criteria evaluation to quantify residual risk.

See also: ‘Legacy’ cyber risk: How to prepare OT for system updates

By combining technical analysis with business impact studies, teams can prioritize mitigation efforts on components whose compromise would have the most severe consequences.

Implementing CRA compliance in manufacturing

Achieving CRA compliance requires teamwork among engineering, legal, and business functions:

1. Governance and policy: Create a CRA task force with members from different functions to define policies, assign responsibility, and track progress toward compliance milestones.
2. Continuous improvement: Use metrics, such as mean time to patch, incident resolution time, and supplier risk scores, to measure effectiveness and drive ongoing enhancements.
3. Aligning processes: Integrate security checkpoints into current workflows in product development, procurement, and customer service operations.
4. Leveraging tools and automation: Use vulnerability scanners, DevSecOps workflows, and automated reporting systems to make routine tasks easier and improve efficiency.
5. Training and culture: Provide regular security awareness training to engineers, quality assurance, and supply-chain managers on CRA requirements and incident response protocols.

By taking these steps, manufacturers meet regulatory requirements and provide stronger products that build trust in competitive markets.

The EU’s Cyber Resilience Act brings a new level of responsibility for the security of connected products. For manufacturers eyeing EU markets, adhering to the five core requirements of security by default and design, incident management and reporting, vulnerability management, third-party risk management, and product risk assessment, is non-negotiable.

Following these best practices ensures CRA compliance and improves an organization’s overall cybersecurity posture, leading to safer and more reliable products in the long run.