For businesses exporting goods to the EU, the Cyber Resilience Act (CRA) introduces mandatory cybersecurity requirements for a wide range of digital products. Companies that fail to comply could face restricted market access, penalties, or product recalls.
If your business manufactures, imports, or distributes products with digital components, understanding the CRA is critical to maintaining smooth trade with EU markets.
What Is the Cyber Resilience Act (CRA)?
The Cyber Resilience Act (CRA) is an EU regulation designed to improve cybersecurity across connected products sold within the EU single market. It introduces mandatory security requirements throughout the product lifecycle, from design and development to post-market support.
The regulation officially entered into law in December 2024, and its provisions will become fully applicable in December 2027.
This transition period gives manufacturers, importers, and distributors time to implement the necessary compliance processes.
The core goal of the CRA is simple:
Products connected to networks must be secure by design and maintained securely throughout their lifespan.
What Are “Products with Digital Elements” (PDEs)?
The CRA applies to Products with Digital Elements (PDEs), a broad category that includes most technology products capable of connecting to networks or other devices.
Examples of PDEs include:
- Software applications and platforms
- Connected consumer devices
- Smart devices and IoT products
In practical terms, if a product connects directly or indirectly to another device or network, it will likely fall within the scope of the CRA.
This means the regulation applies to a wide range of industries, including:
- Consumer electronics
- Industrial technology
- Telecommunications equipment
- Smart home products
- Connected vehicles and machinery
Under the EU Cyber Resilience Act (CRA), products with digital elements are grouped into risk categories (“classes”) that determine the level of cybersecurity requirements, the required documentation, and the conformity assessment route.
| Risk Class | Documentation Required at Customs | Notes |
|---|---|---|
| Default Category | CE Mark; Declaration of Conformity (DoC); Technical Documents and Instructions | Manufacturers self-declaration is sufficient |
| Class I | Same as above, with stronger documentation evidence | Documentation must reflect higher security scrutiny |
| Class II/Critical | CE Mark; DoC; Technical Documents; Third-Party Assessment Evidence available on request | Must have notified body reports available |
Companies trading with the EU should carefully review whether their products qualify as PDEs under the CRA framework.
Manufacturer Responsibility Under the Cyber Resilience Act
One of the most important aspects of the CRA is that the primary responsibility for compliance rests with the manufacturer.
Manufacturers must ensure that their products meet the EU’s cybersecurity standards before entering the EU market.
The CE marking indicates that a product meets EU safety, health, and environmental requirements, including cybersecurity requirements introduced by the CRA.
For companies outside the EU exporting products to the European market, this means working closely with manufacturers to ensure all compliance steps are completed.
Importer Obligations Under the Cyber Resilience Act
The new CRA regulations place additional responsibility on importers to ensure manufacturers have completed their required compliance steps.
While the primary responsibility remains with manufacturers, importers still face pressure to ensure these CRA obligations are met.
At TecEx, we’ve built processes to ensure these due diligence requirements are handled seamlessly, preventing delays in the shipping process.
– Amulya Mathew, TecEx Head of IP
Although manufacturers carry primary responsibility, importers also have clear obligations under the CRA.
Companies importing products into the EU must ensure that the goods they bring into the market comply with the regulation.
Importer Responsibilities Under Cyber Resilience Act (CRA) Include:
1. Import Only CRA-Compliant Products
Importers must ensure that the products they bring into the EU comply with the cybersecurity requirements established by the CRA.
Failure to verify compliance could result in liability if non-compliant products enter the EU market.
2. Verify the EU Declaration of Conformity
Importers must confirm that the manufacturer has performed the required testing and issued an EU Declaration of Conformity.
This document confirms that the product meets all applicable EU regulations, including those introduced by the Cyber Resilience Act.
3. Confirm the Product Has Valid CE Marking
Before placing goods on the market, importers must verify that the product carries a valid CE marking demonstrating compliance with EU standards.
4. Ensure Technical Documentation Exists
Importers must confirm that the manufacturer maintains the necessary technical documentation that demonstrates compliance with CRA cybersecurity requirements.
EU authorities may request this documentation during inspections or investigations.
Record-Keeping Requirements Under the CRA
The Cyber Resilience Act also introduces clear record-keeping requirements for importers and other supply chain participants.
Businesses importing products into the EU must:
- Keep the EU Declaration of Conformity for 10 years after the product is imported
- Be able to provide documentation if requested by EU regulatory authorities
These record-keeping requirements are critical for traceability and regulatory oversight. Companies should ensure that their compliance systems and documentation management processes are robust enough to meet these obligations.
Why the Cyber Resilience Act Matters for Global Trade
The CRA is part of the EU’s broader strategy to strengthen digital security and consumer protection across the single market.
For companies trading internationally, the impact is significant because the EU is one of the world’s largest technology markets.
Businesses that prepare early will be better positioned to maintain uninterrupted access to EU markets once the regulation becomes fully applicable in 2027.
Steps Companies Should Take Now to be CRA Compliant
Although full compliance is required by December 2027, companies should begin preparing now.
Alternatively, companies can reach out to a trusted third-party IOR partner, like TecEx, who will take on the burden of import compliance responsibility and risk liability on your behalf.
Final Thoughts on the CRA
For companies that trade with the EU, the message is clear: cybersecurity compliance is no longer optional. It is a market access requirement.
The Cyber Resilience Act (CRA) marks a major shift in how cybersecurity is regulated for products sold in the European Union. By introducing mandatory security requirements for Products with Digital Elements (PDEs), the regulation aims to create a safer digital ecosystem for businesses and consumers.
Manufacturers must ensure their products meet the required standards, while importers must verify compliance before goods enter the EU market.
Organizations that start preparing now will not only reduce compliance risk but also strengthen their cybersecurity practices, an increasingly important competitive advantage in today’s connected economy.
