Cyber Resilience Act: What the New EU Regulation Means for Digital Products

How Companies with Well-Structured Product Data and PIM Systems Master the New Challenges

Products with digital components have long been an integral part of our everyday lives – from smart household devices to industrial IoT applications. With the growing number of interconnected systems, however, you also paint a bigger bullseye on yourself for cyber attacks. Security holes do not only put individual users into danger nowadays but even entire companies, critical infrastructures, and, at the end of the day, trust in technology.

Up until now, there have been no consistent regulations by the EU to make the cyber security of products mandatory. The Cyber Resilience Act (CRA) of the European Union changes this fundamentally. Unprecedentedly, it creates an obligatory legal framework for products with digital elements while also turning cyber security into a quality factor.

The Cyber Resilience Act will regulate for all of Europe how secure hardware and software products must be when they are launched on the market. For manufacturers, retailers, and importers, this means: Cyber security turns into an obligation, and it does so throughout the entire lifecycle of a product.

But what exactly is behind the regulation? And why does data management play such a central role therein? This is what you will learn in this blogpost.

 

What is the Cyber Resilience Act?

The Cyber Resilience Act is an EU regulation that defines the minimal standards for the cyber security of products with digital elements. The aim is to identify security gaps well ahead of time, resolve them, and, consequently, make products more resilient against cyber attacks.

Affected are all products that are connected to the internet either directly or indirectly, ranging from routers to smart home devices. Software solutions that interact with such products or are part of the product’s functionality do also fall under this legal category.

The CRA follows the aim of establishing a consistently high cyber security level for products with digital elements – throughout the entire product lifecycle. This concerns nearly all products that contain a piece of software or feature network connectivity, like networked hand devices, operating systems, industrial control systems, or embedded software such as cloud-connected apps and platforms. Excluded are only specific sectors such as medical devices, automobiles, and aircraft technology, since they are already subject to more specialized regulations. Even open-source software is only excluded if it is provided non-commercially. As soon as an open-source component is utilized within a commercial product, the CRA requirements apply.

 

What will Change for Manufacturers and Retailers in Detail?

The CRA comes with far-reaching obligations for manufacturers, importers, and retailers. It dictates that cyber security is now no longer an optional measure secondary to the product launch but a central quality requirement in its own right as early as in product development. In short: Cyber security advances to the position of an integral product requirement, it is no longer something that comes after the fact as an add-on.

• Security-by-Design and Security-by-Default
  Security requirements must be integrated throughout all phases of development from the very beginning. Products must be delivered in a default configuration that can be restored at any time.

• Lifecycle-Overarching Responsibility
  Manufacturers are obligated to observe vulnerabilities across the entire product lifecycle, provide updates, and define support periods.

• Documentation and Verification Requirements
  Companies must provide both technical documentation and a software bill of materials (SBOM) consisting of a list of all utilized software components including open-source libraries. The documentation must be handed over to national authorities such as the BSI in Germany or the ANSSI in France.

• Risk Management and Incident Handling
  Security leaks must be identified, evaluated, and reported. Companies must establish processes for vulnerability management, incident response, and patch management.

• Conformity Assessment and CE Marking
  CRA conformity is the feature requirement for CE marking. Without proof of this requirement, a product can no longer be brought onto the European market.

 

Deadlines and Transitory Regulations

The regulation (EU) 2024/2847 has been enacted on 23rd October 2024 and came into force in December 2024 with a transition period until 2027. The transition period phases were defined as follows:

• December 2024: CRA comes into force.
• Starting in June 2026: Conformity assessment bodies can comply with requirements (auditability).
• Starting in September 2026: Obligation to inform in case of security gaps and leaks.
• December 2027: End of the three-year transition period, from here on all requirements are obligatory: manufacturers, retails, and importers must have established complete CRA conformity, including risk analysis, documentation, update processes, and the procedure of furnishing proof.
• Starting in December 2027: Only CRA-conform products with CE marking can be brought onto the European market.

For many companies this means: The time for strategic preparations is now. Without preparation, the CRA will turn into a business risk. Since, without CRA conformity, there will be no CE marking in the future – and, without CE marking, no sales in the EU.

 

Why Well-Structured Product Data is Decisive

Cyber security makes its beginning not with technology but with clear, consistent, and transparent processes and methodologies. The CRA demands complete technical documentation, risk evaluation, as well as proofs and validations. All this hinges upon a clean data architecture. Wherever central information is missing gaps, duplicates, and errors loom large. This is a compliance risk with potentially high fines.

For manufacturers, retailers, and e-commerce companies in particular: Only those who manage their product data centrally can efficiently handle the effort revolving around documentation requirements, audits, and update tracking.

 

From Cyber Resilience to Data Transparency: The Digital Product Pass as a Logical Expansion

The Cyber Resilience Act does not stand in isolation. Starting from 2027, the Digital Product Pass (DPP) will become obligatory as a further central EU instrument, initially for batteries, textile, and electronics. Additionally, the regulations for product liability will be revised. All regulations follow the same agenda: Trustworthy, secure, and transparent products on the European market and clear rules for responsibilities.

The CRA focusses on security and verifiability. The DDP, on the other hand, lays its focus on transparency and digital accessibility. Product liability governs all consequences caused by damage. The decisive middle term between the two is the underlying data.

One and the same set of data processed and documented for the CRA does also form the very foundation of the digital product pass. Technical descriptions, software versions, security, and lifecycle information must, in the future, not only be well-maintained but also made digitally accessible. Such information must be interoperable, machine-readable, and provided via standardized interfaces. With this, things grow into one another that were previously separate. Security and sustainability become two sides of the same product responsibility.

 

PIM as the Bridge Between CRA Compliance and Digital Product Transparency

In the context of all this, a Product Information Management (PIM) system becomes the central link between technical security and organizational compliance. A modern PIM supports the central management of all product-relevant information, versioning and audit capacities, integrations of SBOM, CE documentation and risk analyses, as well as interface capabilities for the automated processing of data to product passes or government portals. This way, a consistent data foundation comes into being that enables companies to fulfill both the CRA requirements and the DPP regulations with minimal effort.

Those who build on structured data management today will realize two obligatory regulation areas at the same time: security and transparency.

 

Why Data Management is Decisive for Your Business Success

Without uniform data structures, implementing the new requirements is nigh impossible. In many companies, product information is scattered across departments, tools, and even physical locations. This comes with risks concerning compliance, efficiency, and security.

A modern PIM system does away with aforementioned issues:

• Central Data Warehousing: All product-related information in one and the same space.
• Faster Audit Capacities: Proofs and documentation are immediately available.
• Higher Data Quality: Less redundancy, more consistency.
• Automated Reports: Compliance data and product data can be directly exported into the digital product pass.

This saves time, costs, and reduces the margin for error. In the face of possible fines of up to 15 million euros or 2.5 percent of the annual global revenue, this is a decisive competitive advantage.

 

Conclusion: CRA is More Than a Mandatory Necessity

The Cyber Resilience Act is no bureaucratic obstacle but a chance to establish security as a quality factor. Companies that connect cyber security with data management now, secure not only compliance benefits but also the competitive edge and the customers’ trust.

Those who manage product information centrally, document their updates, and design processes in a transparent way, lay the cornerstones for real cyber resilience and will face the upcoming EU requirements with confidence.