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Regulation (EU) 2024/2847
CRA
Cyber Resilience Act obligations
What manufacturers, importers, distributors and open-source software stewards must do under the Cyber Resilience Act, chapter by chapter and article by article, with the essential cybersecurity requirements of Annex I that the obligations of manufacturers point to (Art. 13(1)).
70 articles carry obligations; 348 obligations listed, summarised from the article text. The article is one click away every time.
At a glance
Every obligation, in the order of the law
Chapter by chapter, each article that puts an obligation on someone, with who it addresses and what it asks. The wording here is a summary; the article text is the law, and it is one click away.
Who. All products with digital elements (hardware or software) that have direct or indirect data connections to devices or networks, when made available on the EU market, except for specifically excluded categories
Products with digital elements that connect to devices/networks must comply with CRA requirements
Manufacturers must assess if their products fall within scope based on connectivity capabilities
Organizations must verify their products are not covered by exclusions before applying CRA requirements
Who. All economic operators involved in developing, manufacturing, importing, or distributing products with digital elements in the EU market, including manufacturers, open-source software stewards, authorized representatives, importers, and distributors
Economic operators must understand their role classification (manufacturer, importer, distributor, etc.) to determine their specific obligations
Manufacturers must identify if their products qualify as 'products with digital elements' subject to the regulation
Organizations must use these standardized definitions when documenting compliance, reporting incidents, and communicating with authorities
Who. Member States when procuring or regulating the use of products with digital elements, particularly for national security, defense, or public procurement purposes
Member States must ensure CRA compliance is considered in public procurement processes
Any additional national cybersecurity requirements must be consistent with EU law
Additional requirements must be necessary and proportionate to their purpose
Procurement processes must verify manufacturers' ability to handle vulnerabilities effectively
Article 6: Requirements for products with digital elements
Who. Manufacturers and developers of products with digital elements that perform critical cybersecurity functions (authentication, intrusion detection, endpoint security, network protection) or have significant control over other systems, networks, or user safety
Products meeting the criteria in Annex III must undergo conformity assessment procedures under Article 32(2) and (3)
Manufacturers must determine if their product falls under Class I or Class II categories
Products must comply with enhanced conformity requirements if they perform critical cybersecurity functions
Compliance with technical specifications once published by the Commission (by December 11, 2025)
Article 8: Critical products with digital elements
Who. Manufacturers of critical products with digital elements that have core functionality listed in Annex IV (specific critical product categories defined by the Commission)
Obtain European cybersecurity certificate at 'substantial' assurance level or higher for critical products listed in Annex IV
Demonstrate compliance with essential cybersecurity requirements through certification
If no certification scheme exists, undergo conformity assessment procedures under Article 32(3)
Comply with minimum 6-month transitional period when new requirements are introduced
Who. Manufacturers, importers, and distributors of products with digital elements where safety aspects fall outside CRA scope and lack specific EU harmonization legislation
Products with digital elements must comply with general product safety rules for any risks not covered by the CRA
Manufacturers must ensure compliance with Regulation (EU) 2023/988 for uncovered safety aspects
Organizations must identify which safety requirements apply from other regulations when CRA doesn't provide specific coverage
Who. Manufacturers of products with digital elements (hardware or software products that connect to devices or networks) when placing products on the EU market
Design and develop products according to essential cybersecurity requirements
Conduct and document cybersecurity risk assessments
Determine and provide a support period (minimum 5 years)
Handle vulnerabilities effectively throughout the support period
Exercise due diligence when integrating third-party components
Report vulnerabilities found in components to their maintainers
Who. Manufacturers and any other natural or legal persons who discover vulnerabilities, cyber threats, security incidents, or near misses affecting products with digital elements
CSIRTs must process voluntary notifications according to established procedures
CSIRTs must inform manufacturers when others report actively exploited vulnerabilities or severe incidents about their products
CSIRTs and ENISA must ensure confidentiality and protection of information from voluntary reporters
Mandatory notifications must be prioritized over voluntary ones by CSIRTs
Article 16: Establishment of a single reporting platform
Who. Manufacturers (optional - they may choose to appoint a representative) and authorized representatives acting on behalf of manufacturers
Keep EU declaration of conformity and technical documentation available for at least 10 years after product launch or throughout support period (whichever is longer)
Provide all necessary information and documentation to authorities when requested to prove product compliance
Provide copy of manufacturer's mandate to authorities upon request
Cooperate with authorities on actions to eliminate product risks
Who. Importers and distributors who either rebrand products with digital elements under their own name/trademark or make substantial modifications to already-marketed products
Assume all manufacturer obligations under Articles 13 and 14 when placing products under own name/trademark
Comply with full manufacturer requirements when making substantial modifications to existing products
Take on product liability and compliance responsibilities equivalent to original manufacturers
Article 22: Other cases in which obligations of manufacturers apply
Who. Any person or company (other than manufacturers, importers, or distributors) who substantially modifies digital products and makes them available on the market
Must comply with manufacturer obligations under Articles 13 and 14
Responsible for cybersecurity of modified parts
Responsible for entire product if modification impacts overall cybersecurity
Must meet all compliance requirements before making modified product available on market
Who. All economic operators (manufacturers, importers, distributors, or any business entity) involved in the supply chain of products with digital elements
Provide names and addresses of suppliers who provided digital products upon request from authorities
Provide names and addresses of customers to whom digital products were supplied (where available)
Maintain these records for 10 years after receiving the product
Maintain these records for 10 years after supplying the product
Article 24: Obligations of open-source software stewards
Open-source software stewards shall put in place and document in a verifiable manner a cybersecurity policy to foster the development of a secure product with digital elements as well as an effective handling of vulnerabilities by the developers of that product
That policy shall also foster the voluntary reporting of vulnerabilities as laid down in Article 15 by the developers of that product and take into account the specific nature of the open-source software steward and the legal and organisational arrangements to which it is subject
That policy shall, in particular, include aspects related to documenting, addressing and remediating vulnerabilities and promote the sharing of information concerning discovered vulnerabilities within the open-source community
Open-source software stewards shall cooperate with the market surveillance authorities, at their request, with a view to mitigating the cybersecurity risks posed by a product with digital elements qualifying as free and open-source software
Further to a reasoned request from a market surveillance authority, open-source software stewards shall provide that authority, in a language which can be easily understood by that authority, with the documentation referred to in paragraph 1, in paper or electronic form
Article 25: Security attestation of free and open-source software
Who. Developers and users of free and open-source software, third parties performing assessments, and manufacturers integrating open-source components into products with digital elements
The Commission must establish voluntary security attestation programmes through delegated acts
These programmes must allow assessment of open-source software conformity with CRA requirements
Programmes must facilitate manufacturers' due diligence obligations when integrating open-source components
Who. All manufacturers of products with digital elements, with different requirements based on product classification (standard, Class I important, Class II important, or critical)
Perform conformity assessment to verify all essential cybersecurity requirements are met
Use approved assessment procedures appropriate to product risk classification
For Class I important products: must use third-party testing if not fully following harmonized standards
For Class II important products: mandatory third-party involvement through EU-type examination or full quality assurance
For critical products: obtain European cybersecurity certification at 'substantial' level or use Class II procedures
Open-source software manufacturers must make technical documentation publicly available
Article 33: Support measures for microenterprises and small and medium-sized enterprises, including start-ups
Who. Microenterprises, small and medium-sized enterprises (SMEs), including startups, as well as Member States and the European Commission who must provide support measures
Member states must organize awareness and training activities for SMEs
Member states must establish dedicated communication channels for SME queries
Member states must support testing and conformity assessment for SMEs
Member states may establish regulatory sandboxes for product testing
Regulatory sandboxes must ensure open, fair, and transparent access especially for SMEs
SMEs can use simplified technical documentation formats once available
Who. EU institutions negotiating trade agreements; indirectly benefits manufacturers and importers trading between the EU and countries with mutual recognition agreements
No direct obligations for businesses - this article enables the EU to create international agreements that may simplify compliance for companies trading internationally
Who. Notifying authorities (government bodies that authorize certification bodies) and Member States responsible for oversight of notified bodies under the CRA
Notifying authorities must monitor notified bodies for ongoing compliance
Authorities must restrict, suspend, or withdraw notification when non-compliance is found
Authorities must immediately inform the European Commission and other Member States of changes
Member States must ensure continuity of certification files when a body ceases operations
Files must be transferred to another notified body or kept available for authorities
Article 46: Challenge of the competence of notified bodies
Who. Notified bodies (third-party organizations authorized to assess product compliance) and indirectly affects manufacturers who must work with these bodies
Carry out conformity assessments according to specified procedures
Perform assessments proportionately, considering company size and product complexity
Require manufacturers to take corrective measures when non-compliance is found
Issue, suspend, or withdraw certificates based on compliance status
Monitor ongoing compliance after certificate issuance
Respect required protection levels while avoiding unnecessary burdens
Article 48: Appeal against decisions of notified bodies
Who. Member States (EU countries) who must implement the appeal system, and indirectly affects all entities subject to notified body assessments under the CRA
Member States must establish an appeal procedure
Appeal mechanism must be available against all notified body decisions
Companies have the right to challenge notified body determinations
Article 49: Information obligation on notified bodies
Who. Member State governments (must establish authorities), market surveillance authorities (enforcement duties), manufacturers and open-source software stewards (subject to surveillance), and consumers (who can report issues)
Member States must designate one or more market surveillance authorities for CRA enforcement
Market surveillance authorities must monitor compliance of products with digital elements
Authorities must supervise open-source software stewards' compliance with Article 24 obligations
Authorities must cooperate with CSIRTs, ENISA, and data protection authorities
Authorities must report annually to the Commission on market surveillance outcomes
Authorities must monitor manufacturers' support periods for products
Who. Market surveillance authorities in EU Member States, economic operators (manufacturers, importers, distributors) of products with digital elements, notified bodies, and CSIRTs
Economic operators must cooperate with market surveillance authorities during product evaluations
Economic operators must take corrective actions within prescribed timeframes when non-compliance is found
Economic operators must ensure corrective actions are applied to all affected products across the entire EU market
Market surveillance authorities must evaluate products presenting significant cybersecurity risks without undue delay
Market surveillance authorities must coordinate with CSIRTs and competent authorities for NIS2 compliance
Authorities must notify the Commission and other Member States about evaluation results and enforcement actions
Who. Market surveillance authorities, the European Commission, ENISA, and indirectly affects manufacturers and distributors of digital products being investigated
Market surveillance authorities must ensure joint activities don't create unfair competition between businesses
Authorities must maintain objectivity, independence and impartiality when conducting joint activities
Authorities must make agreements on joint activities publicly available, including names of participating parties
Information from joint activities can be used in individual investigations
Who. Market surveillance authorities, ENISA, European Commission, and indirectly all manufacturers/distributors whose products may be subject to sweeps
Market surveillance authorities must conduct coordinated control actions to check CRA compliance
The Commission coordinates sweeps unless authorities agree otherwise
Aggregated sweep results should be made publicly available where appropriate
ENISA can propose product categories for sweeps based on notifications received
Authorities may acquire products under cover identity for inspection
Who. All parties involved in CRA application including market surveillance authorities, the European Commission, Member States, notified bodies, manufacturers, importers, distributors, and any entity handling confidential information during CRA compliance
Protect intellectual property rights and trade secrets (including source code)
Maintain confidentiality of business information obtained during compliance activities
Obtain prior agreement before sharing confidential information between authorities
Protect information that could affect public or national security
Safeguard information that could compromise inspections, investigations or audits
Ensure information exchange doesn't interfere with criminal proceedings
Who. All economic operators subject to the CRA (manufacturers, importers, distributors), with special consideration for microenterprises, SMEs, and exemptions for open-source software stewards
Member States must establish penalty rules for CRA violations
Member States must notify the Commission of penalty rules and any amendments
Market surveillance authorities must communicate fines through the EU information system
Authorities must consider company size, gravity of violation, and prior infractions when setting fines
Member States may decide whether public authorities can be fined
Who. Manufacturers and type-approval authorities for motorcycles, mopeds, tricycles, quadricycles, and other L-category vehicles covered by Regulation (EU) No 168/2013
Vehicle manufacturers must implement protection against cyberattacks for all vehicle categories
Cybersecurity measures must be included in type-approval requirements
All vehicle categories (L1e through L7e) must comply with cybersecurity protection requirements
Who. European Commission (reporting obligations), European Parliament and Council (report recipients), ENISA and CSIRTs network (consultation participants)
Commission must submit evaluation reports to Parliament and Council by December 11, 2030 and every 4 years thereafter
Commission must publish these evaluation reports publicly
Commission must consult ENISA and CSIRTs network before September 11, 2028
Commission must submit effectiveness report on single reporting platform by September 11, 2028
Who. All manufacturers, importers, and distributors of products with digital elements within the EU market
Comply with full regulation requirements by December 11, 2027
Implement Article 14 requirements (reporting obligations for manufacturers) by September 11, 2026
Be ready for enforcement mechanisms and market surveillance activities starting June 11, 2026
Annex I
The requirements the obligations point to
Manufacturers design, develop and produce products with digital elements in accordance with the essential cybersecurity requirements of Annex I (Art. 13(1)). Part I sets the requirements relating to the properties of the product; Part II the vulnerability handling requirements.
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