EU Cyber Resilience Act: What It Means for Manufacturers and How to Adapt

As the digital landscape expands, cybersecurity has become a cornerstone of economic strength, national security, and public trust. The European Union (EU) has consistently led the way in digital regulation, introducing laws such as the General Data Protection Regulation (GDPR) and the Digital Markets Act (DMA) to enhance digital security and fairness. The latest in this regulatory evolution is the Cyber Resilience Act (CRA)—a transformative regulation that reshapes how manufacturers, distributors, and businesses in the supply chain approach cybersecurity.

The CRA is not just another regulatory hurdle; it is a fundamental shift in how security must be integrated into digital products. Manufacturers can no longer treat cybersecurity as an afterthought—it must be embedded from the initial design phase through ongoing product monitoring. Non-compliance isn’t an option; the consequences include fines of up to €15 million or 2.5% of global annual revenue, sales restrictions, and severe reputational damage.

This guide provides a deep dive into why the CRA is critical, how it impacts different businesses, and the steps organizations must take to stay compliant in a fast-changing regulatory environment.

A Strategic Response to Growing Cybersecurity Threats

The Cyber Resilience Act (CRA) represents the EU’s proactive stance against escalating cybersecurity risks affecting industries worldwide. Recent high-profile cyberattacks, such as the SolarWinds breach and the Colonial Pipeline attack, have demonstrated the devastating consequences of cyber vulnerabilities. While these attacks occurred outside the EU, they highlight the urgent need for robust, standardized security frameworks.

The CRA’s core objectives revolve around three key areas:

1. Cyber Threats and State-Sponsored Attacks

Cyberattacks are increasingly being weaponized in geopolitical conflicts, posing risks to national security, economies, and critical infrastructure. The Russia-Ukraine conflict has demonstrated how cyber disruptions can have far-reaching consequences beyond the battlefield. Recognizing this evolving threat landscape, the CRA requires manufacturers to embed robust security measures at the design stage, reducing vulnerabilities that could be exploited by malicious actors. By prioritizing security-by-design principles, Europe is taking a proactive approach to strengthening its cyber resilience and safeguarding its digital ecosystem.

2. Technological Sovereignty and Economic Security

Europe's growing reliance on digital products from non-EU countries, particularly the United States, China, and South Korea, presents cybersecurity challenges. Over time, unchecked dependence on foreign technologies and regulatory frameworks could introduce risks to the region’s digital resilience. The CRA aims to address these concerns by ensuring that digital products sold in the EU meet stringent cybersecurity standards. By doing so, it strengthens Europe’s digital sovereignty, enhances economic security, and promotes a more self-reliant cybersecurity ecosystem.

3. Consumer Protection and Trust

The rapid proliferation of Internet of Things (IoT) devices, connected vehicles, and smart technologies has dramatically increased the digital attack surface. Many of these products are developed with convenience and functionality in mind, often at the expense of security, leaving them vulnerable to exploitation. The CRA addresses this gap by mandating cybersecurity as an integral part of the entire product lifecycle—from design and development to deployment and maintenance. By ensuring that security is embedded from the outset rather than treated as an afterthought, the CRA enhances consumer protection, strengthens trust in digital products, and accelerates the adoption of secure technologies across Europe.

Key CRA Requirements: What’s Changing?

The Cyber Resilience Act enforces cybersecurity as a mandatory requirement rather than an optional add-on. Here’s what businesses must focus on:

1. Security by Design & Default

Cybersecurity must be embedded into product development from the outset. This includes:

• Implementing secure software development practices such as code reviews, threat modeling, and penetration testing.

• Enforcing strong encryption and authentication mechanisms to protect user data.

• Reducing attack surfaces by eliminating unnecessary features and restricting access to critical systems.

2. Cybersecurity Risk Assessments

Before launching a product, manufacturers must conduct rigorous risk assessments, evaluating:

• Intended use: Where and how the product will be deployed (e.g., homes, hospitals, industrial environments).

• Attack vectors: Potential vulnerabilities that hackers could exploit.

• Impact analysis: Consequences of security breaches for users and businesses.

Regular security audits and proactive vulnerability management will be required to maintain compliance.

3. Secure Supply Chain Management

Manufacturers must secure not just their products but also their entire supply chain. This involves:

• Maintaining a Software Bill of Materials (SBOM)—an inventory of all software components used in a product to track vulnerabilities.

• Ensuring that embedded hardware meets EU security standards and is free from outdated or compromised components.

• Working only with trusted suppliers that adhere to strict cybersecurity best practices.

4. Mandatory Security Updates & Vulnerability Management

Manufacturers must provide security updates for up to 10 years after a product’s release. These updates must be:

• Secure: Delivered safely without introducing new vulnerabilities.

• Transparent: Customers must be notified of updates and their significance.

• Regular: Updates should follow a clear schedule to address emerging threats.

5. Incident Reporting & IT Security Labels

Companies must report cybersecurity incidents within 24 hours and notify affected customers promptly. The CRA will also introduce an IT security labeling system, similar to energy efficiency labels, to inform consumers about:

• A product’s security level based on CRA compliance.

• The duration of security updates, ensuring long-term protection.

CRA Compliance Timeline ₁

The rollout of the Cyber Resilience Act (CRA) will happen in stages, giving businesses time to align with the new cybersecurity requirements:

• December 2024 – The CRA officially comes into force, setting baseline cybersecurity standards for digital products.

• December 2026 – Mandatory incident reporting rules take effect.

• December 2027 – Full compliance becomes mandatory for all digital and connected products sold in the EU.

Who Needs to Pay Attention?

The CRA applies to any company that manufactures, imports, or sells digital or connected products in the EU, including:

• IoT manufacturers – Smart home devices, wearables, industrial sensors.

• Automotive suppliers – Connected vehicle systems, software.

• MedTech startups – Digital healthcare devices, applications, and cloud services.

• Software providers – Companies offering security-sensitive applications.

• Industrial IoT (IIoT) vendors – Connected manufacturing and automation solutions.

• SaaS and AI-driven platforms – Any software handling sensitive enterprise or user data.

CRA Impact on Automotive & MedTech Industries

The automotive and healthcare industries already follow stringent cybersecurity regulations:

• Automotive: Compliance with UNECE WP.29 R155/R156, ISO/SAE 21434, and TISAX is mandatory.

• MedTech: Products must meet EU MDR (Medical Device Regulation) and IEC 62304 (Software Lifecycle for Medical Devices) standards.

However, companies offering connected services, third-party software, or cloud-based solutions must ensure full CRA compliance.

The Cost of Non-Compliance

Failure to comply with the Cyber Resilience Act will result in severe penalties:

• Fines – Up to €15 million or 2.5% of global revenue (whichever is higher).

• Sales restrictions – Non-compliant products will be banned from the EU market.

• Reputation damage – Cybersecurity breaches can significantly impact customer trust and brand credibility.