New Position Paper on proposals for definition of CRA important products
The Cyber Resilience Act (CRA) is expected to be published in the Official Journal of the European Union (OJEU) in September or October this year. This new Regulation will provide essential requirements enforcing protection mechanisms on digital products (hardware and software) to improve their resilience against cyber-attacks. In addition, essential requirements will ensure that identified vulnerabilities are duly handled and result in updates to the products during the whole support period of the product.
The Regulation also imposes conformity assessment procedures for the demonstration of compliance with these essential requirements. While most digital products are announced to benefit from the procedure of selfassessment, regardless of the existence of harmonised standards, and presumption of conformity when a harmonised standard (cited in the OJEU) is applied, categories of important products and critical products are listed in the CRA and associated with a stricter conformity assessment procedure. At least 1 category of important products Class I is of importance for the Euralarm members. This one is listed in Annex III of the CRA as “Smart home products with security functionalities, including smart door locks, security cameras, baby monitoring systems and alarm systems”.
This category will require either the application of a harmonised standard cited in the OJEU or an EU type examination by a CRA notified body. It is therefore of utmost importance to have clear and unambiguous definitions for it.
Euralarm, the European trade association representing the electronic fire safety and security industry, greatly appreciates the opportunity to propose definitions that can be endorsed by the European Commission in the Implementing Act complementing the CRA. After due consideration of the wording of the category in Annex III and the criteria in Article 7(2) of the CRA, the present position paper provides such proposals for the category mentioned above.
