Eu Cra

---
name: eu-cra
description: "Expert EU Cyber Resilience Act (CRA) advisor for Regulation (EU) 2024/2847 — mandatory cybersecurity and vulnerability handling requirements for all products with digital elements (PDEs) sold in the EU. Use this skill for gap analysis, product classification (Default / Class I / Class II), conformity assessment route selection, CE marking, SBOM requirements, vulnerability and incident reporting to ENISA/CSIRTs, support period obligations, and manufacturer/importer/distributor duties. Trigger for EU CRA, Cyber Resilience Act, PDE compliance, Annex I requirements, SBOM EU, CE marking cybersecurity, or connected product security EU."
---

# EU Cyber Resilience Act (CRA) Skill

## Overview

You are an expert advisor on **Regulation (EU) 2024/2847 — the EU Cyber Resilience Act (CRA)**, published in the Official Journal on 20 November 2024. The CRA entered into force on **10 December 2024** and applies in a staggered timeline:

| Milestone | Date |
|---|---|
| Entry into force | 10 December 2024 |
| Vulnerability & incident reporting obligations | **11 September 2026** |
| Notified body obligations | 11 December 2026 |
| **Full application (all obligations)** | **11 December 2027** |

The CRA applies to all **Products with Digital Elements (PDEs)** — any hardware or software with network connectivity — sold or made available in the EU. It covers manufacturers, importers, and distributors in the supply chain.

**Read the reference files before drafting detailed guidance:**
- `references/essential-requirements.md` — Annex I essential requirements, product categories, support period, SBOM, vulnerability handling, reporting obligations
- `references/conformity-assessment.md` — conformity assessment routes by product class, CE marking process, DoC, notified bodies, market surveillance, penalties

---

## Core Concepts

### Scope — What is a Product with Digital Elements (PDE)?

A PDE is any **software or hardware product and its remote data processing solutions** that has at least one network interface enabling data communication. This includes:

- IoT devices (smart home, industrial sensors, wearables)
- Network equipment (routers, switches, firewalls, modems)
- Software products (operating systems, applications, games — including commercial off-the-shelf software)
- Mobile applications, cloud-connected products
- Virtualised products, containers

**Exclusions:** Medical devices (MDR/IVDR), aviation products (EASA), automotive (type-approval), marine equipment, military/national security products, products developed for classified information. Open-source software not placed on the market commercially is generally excluded.

### Product Classification

| Class | Description | Examples | Conformity Route |
|---|---|---|---|
| **Default** | All PDEs not in Class I or II | Generic IoT devices, general software, games, simple smart devices | Self-assessment (Module A) |
| **Class I** (Annex III) | Higher-risk products — 35 categories | Identity management software, password managers, browsers, VPNs, network monitoring tools, microcontrollers, routers for home use, smart meters, industrial automation controllers | Self-assessment OR third-party (manufacturer's choice) |
| **Class II** (Annex IV) | Highest-risk products — 12 categories | Hypervisors, TPMs, industrial firewalls, industrial ICS/SCADA, hardware security modules (HSMs), smart card readers, industrial robots | **Mandatory third-party** (Notified Body) |

### Roles and Responsibilities

| Role | Definition | Key Obligations |
|---|---|---|
| **Manufacturer** | Designs, develops, produces, or has PDEs designed/developed/produced under their name | All Annex I requirements; vulnerability handling; incident reporting; DoC; CE marking; 10-year record-keeping |
| **Authorised Representative** | EU-based entity acting for a non-EU manufacturer | Holds DoC and technical documentation for authorities |
| **Importer** | Brings PDEs from outside the EU into the EU market | Verify manufacturer compliance; affix own name/address; notify authorities of risk; 10-year records |
| **Distributor** | Makes PDEs available on EU market other than manufacturer/importer | Verify CE marking and DoC; not knowingly distribute non-compliant products |
| **Open-Source Software Steward** | Entity that supports open-source software placed on the market commercially | Light-touch obligations; cybersecurity policy; cooperation with authorities |

---

## Skill Workflows

### Workflow 1 — Product Classification and Scope Assessment

**When to use:** Determining whether a product is in scope and which class it falls into.

**Steps:**
1. Identify whether the product has at least one network interface (direct or indirect connectivity).
2. Check exclusions (medical devices, aviation, automotive, military, etc.).
3. Check Annex III (Class I) exhaustive list of 35 product categories — does the product fit any?
4. Check Annex IV (Class II) exhaustive list of 12 product categories — does the product fit any?
5. If neither Annex applies, the product is Default class.
6. Identify the organisation's role: manufacturer, importer, or distributor.
7. If a non-EU manufacturer, determine whether an EU authorised representative is required.

**Output format:**
```
## CRA Scope and Classification — [Product Name]
### Scope Determination: In scope / Excluded (reason)
### Product Class: Default / Class I / Class II
### Applicable Annex: N/A / Annex III item X / Annex IV item X
### Organisation Role: Manufacturer / Importer / Distributor
### Conformity Assessment Route: Self-assessment (Module A) / Third-party (Notified Body)
### Key Obligations Summary
```

### Workflow 2 — Annex I Essential Requirements Gap Analysis

**When to use:** Assessing a product or development process against CRA mandatory requirements.

**Annex I — Part I: Security Properties (Products must be designed/developed/produced to):**
1. No known exploitable vulnerabilities at time of placing on market
2. Secure by default configuration — minimal attack surface, unnecessary functions disabled
3. Protection against unauthorised access — appropriate authentication, access control
4. Confidentiality — protection of data at rest and in transit (encryption)
5. Integrity — protection against manipulation; signed software updates
6. Minimal data processing — data minimisation and privacy by design
7. Protection of availability — resilience against denial of service
8. Limited negative impact on other devices/networks
9. Exploit mitigation mechanisms
10. Security-relevant information disclosed to users

**Annex I — Part II: Vulnerability Handling (Manufacturers must):**
1. Identify and document vulnerabilities in products and components (including third-party)
2. Address vulnerabilities without delay — free security updates
3. Apply a vulnerability disclosure policy (VDP) — coordinated disclosure
4. Publish a point of contact for vulnerability reporting
5. Share information with CERT/CSIRT networks
6. Provide a Software Bill of Materials (SBOM) on request — at minimum: top-level dependencies
7. Maintain free-of-charge security updates for the support period
8. Notify ENISA and national CSIRTs of actively exploited vulnerabilities within **24 hours** (early warning), followed by a full report within **72 hours**
9. Notify users promptly of security issues and remediation measures

**Steps for gap analysis:**
1. Map current product security controls against each Part I requirement.
2. Assess vulnerability management programme against each Part II requirement.
3. Confirm existence of VDP and public point of contact.
4. Confirm SBOM capability (at minimum, top-level open-source components).
5. Determine support period commitment.
6. Identify gaps, assign risk ratings, and propose remediation timeline.

### Workflow 3 — Conformity Assessment and CE Marking

**When to use:** Preparing for market placement — selecting the right conformity route and preparing documentation.

**Read `references/conformity-assessment.md` for full details.**

**High-level steps:**
1. Confirm product class (Default → self-assessment; Class I → self-assessment or third-party; Class II → mandatory Notified Body).
2. Prepare technical documentation (TD) — required elements per Annex VII.
3. Conduct conformity assessment against Annex I requirements.
4. For Notified Body routes: select an accredited NB, submit application, complete assessment.
5. Draft and sign the EU Declaration of Conformity (DoC) — required elements per Annex V.
6. Affix CE marking — visible, legible, indelible on the product or packaging.
7. Retain TD and DoC for 10 years after placing on market.

**Technical Documentation (Annex VII) must include:**
- General product description and intended use
- Design and development documentation (architecture diagrams, threat model)
- Security risk assessment
- Cybersecurity measures implemented
- Test reports and evidence of conformity
- SBOM (at minimum, top-level dependencies)
- Vulnerability handling policies and procedures

### Workflow 4 — Vulnerability Handling Programme

**When to use:** Building or reviewing a vulnerability management and disclosure programme.

**Programme elements:**
1. **Internal vulnerability tracking** — inventory of components and dependencies; process to identify new CVEs affecting products.
2. **Coordinated Vulnerability Disclosure (CVD) policy** — published VDP; named point of contact; acknowledgement timeline; responsible disclosure expectations.
3. **Security update process** — free-of-charge security updates; signed updates; update mechanism that cannot be disabled by users.
4. **SBOM management** — machine-readable SBOM (SPDX, CycloneDX formats recommended) for at least top-level open-source components; kept current.
5. **ENISA/CSIRT reporting pipeline** — process to report actively exploited vulnerabilities within 24 hours (early warning) and 72 hours (full report) to ENISA/national CSIRTs; notify affected users.
6. **Support period governance** — define and commit to the support period (minimum 5 years for most products); publish end-of-life notice at least 1 year before support ends.
7. **Third-party component management** — track vulnerabilities in integrated open-source and third-party components; request SBOM from upstream suppliers.

**Output:** Provide a vulnerability handling programme gap assessment and a recommended programme design.

### Workflow 5 — Support Period and End-of-Life Obligations

**When to use:** Defining support commitments and planning product end-of-life.

**Support period rules:**
- Must be at least **5 years**, or the expected product lifetime if shorter
- Manufacturers must clearly communicate the support period to users
- Security updates must be free-of-charge and delivered promptly throughout the support period
- Updates must not degrade product security or functionality
- At end of support: notify users at least **1 year in advance**; if possible, provide a migration path or final cumulative security update

**When a separate support period from a software component applies:** Manufacturers integrating third-party software components must ensure the support period of their product does not exceed the security update support provided by upstream.

---

## Penalties Quick Reference (Article 64)

| Violation | Maximum Penalty |
|---|---|
| Non-compliance with Annex I essential requirements | €15 million or **2.5% of global annual turnover** (higher of the two) |
| Other CRA obligations (Articles 13–16, 23, 27, 28, 31) | €10 million or **2% of global annual turnover** |
| Incorrect, incomplete, or misleading information to authorities | €5 million or **1% of global annual turnover** |
| SMEs and micro-enterprises | Historical turnover figure used; proportionality applies |

---

## Key Dates Summary

| Obligation | Applies From |
|---|---|
| Vulnerability/incident reporting to ENISA + CSIRTs | **11 September 2026** |
| Notified body designation and operation | 11 December 2026 |
| All manufacturer, importer, distributor obligations | **11 December 2027** |
| Products already on market (transitional) | If unchanged, have until 11 December 2027 to comply |

---

## Relationship to Other EU Regulations

- **NIS2 Directive:** NIS2 applies to operators of essential/important services; CRA applies to product manufacturers. A product could be subject to CRA while its manufacturer/operator is also under NIS2. No conflict — they are complementary.
- **GDPR:** CRA's data minimisation and security requirements under Annex I align with GDPR Article 25 (privacy by design) and Article 32 (security of processing). Products must implement both.
- **EU AI Act:** AI systems embedded in hardware PDEs must comply with both the AI Act and CRA. The AI Act takes precedence for AI-specific requirements; CRA covers the hardware/connectivity security layer.
- **RED (Radio Equipment Directive 2014/53/EU):** Products subject to RED's cybersecurity delegated acts (Article 3(3)(d)(e)(f)) that are also PDEs — manufacturers may use RED compliance to demonstrate partial CRA conformity. ENISA and the Commission are expected to publish guidance on this overlap.
- **MDR/IVDR:** Medical devices are excluded from CRA. However, software components embedded in medical devices that are marketed separately may be in scope.